Last updated:11 January, 2023
We, Greyla LTD. and its affiliates, are committed to protecting your privacy. We limit the collection of your data. We only collect data that is required to maintain the service.
1.1. Data we do not collect
We do not collect the following data:
1) Names (including subscriber names, user names, and screen names);
2) Addresses (including residential addresses and business addresses);
3) Telephone numbers; and
4) Payment details:
a) We do not collect your payment details for La VPN. We do not collect or store credit card numbers, bank account numbers, or billing records.
We do not collect sensitive data as we’ve engineered our systems to categorically eliminate the storage of sensitive data.
We do not collect any data related to your online activities. We do not collect data logs of your activity, including:
1) Browsing history;
2) Traffic destination;
3) Data content; and
4) DNS queries.
We do not collect data of your connection logs, including:
1) Your IP address;
2) Your outgoing VPN IP address;
3) Connection timestamp; and
4) Session duration.
As we do not collect data logs of your activity or connection logs, we do not know:
1) The websites you visit;
2) The time you connected to La VPN; and
3) The set of original IP addresses of your computer or the temporarily assigned network addresses.
1.2 Data we collect
We limit the collection of your data. We only collect data that is required to maintain La VPN.
1.2.1 Data that you give us
We collect the data that you give us through your interaction with La VPN. When you register for an Account, we may ask for your email address. The amount of data you give us depends on your privacy settings.
We use your email to:
1) Communicate with you;
2) Send you updates and announcements; and
3) Send marketing information, such as our offers, surveys, invitations, and other content.
If you contact us directly, we may receive data such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other personal data you may choose to provide to us in your communication to us.
You may withdraw your consent to our use of your email address for the above purposes.
1.2.2 Data necessary for us to maintain the quality of La VPN
We collect the following data related to your use of La VPN:
1) Data related to versions of La VPN: we collect data related to your version of La VPN. This allows us to efficiently identify and eliminate technical issues that you may face.
2) Data related to VPN connection: we collect abstracted data related to your use of La VPN. This includes the success of VPN connections, the VPN location you connected, your country, and your internet service provider. You cannot be identified from this abstracted data.
3) Amount of data transferred: we collect the aggregate sum of data transferred to ensure individual users do not use too much data at the expense of other users.
4) Anonymous data for network diagnostics, study and analysis: We collect anonymised data to operate La VPN, including diagnostic data VPN connection failures, speed test data, and crash reports.
2. USE OF DATA
We use, combine, and process your data for the following purposes:
We authenticate your use of La VPN by assigning a unique identifier to you while you register for the service via your email address. This unique identifier identifies you through your device identification code without reference to other data. The purpose of the unique identifier is for us to determine the level of service you have signed up for before we establish your La VPN connection.
We do not use other forms of your data to verify your identity.
2.2 System diagnostics
We use your data related to your La VPN usage to perform internal operations necessary to maintain La VPN. This includes troubleshooting operational problems, conducting data analysis, and analysing activity trends.
2.3 Customer support
We use your data to resolve customer support issues. For example, we may investigate and address concerns, monitor and improve our customer support responses, respond to your questions and feedback, and inform you of steps taken to resolve customer support issues.
We may communicate with you to provide you with updates relating to La VPN, and for marketing and promotional purposes.
2.4 Research and development
We use your data to understand and analyse your use of La VPN to develop new products, services, features, and functionality.
2.5 Service providers
We use data from service providers and third-party vendors to provide and market La VPN.
3. SHARING AND TRANSFER OF DATA
We share and transfer your data in various ways, including the following:
3.1 Aggregated anonymous data
We use and share your data with our partners in aggregated or anonymised form that cannot be used to identify individual users.
If you sign up for La VPN through a referral from a friend, we may let your friend know that you used their referral to sign up for La VPN.
We share and transfer your anonymised statistics and analytics data for network diagnostics.
3.4 Business transfers
Your data may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership.
3.5 With your consent
With your consent and instruction, we may share your data.
3.6 International data transfers
3.7 We may process your data to any countries in which we engage service providers. You acknowledge the transfer of your data outside of the country where you reside. We will ensure your data is protected before transferring the data.
4. SECURITY MEASURES
We implement robust security measures to protect your data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks. We ensure that our computer networks are secure. We adopt access control measures. Our staff’s access to your data is restricted to a need-to-know basis.
We do not collect or store any traffic data or personal data in our data centres.
5. DATA RETENTION
We retain your data when we have an ongoing legitimate business need to do so, such as providing you with a service you requested, or complying with applicable legal, tax, or accounting requirements.
When we have no ongoing legitimate business need to process your data, we will delete or anonymise it. If it is not possible to delete or anonymise your data (for example, because it has been stored in backup archives), then we will securely store it and isolate it from any further processing until deletion is possible.
6. RIGHT TO BE FORGOTTEN
We will erase your data when:
1) Your data is no longer necessary for the purpose which we originally collected or processed it for;
2) You withdraw your consent to us holding your data, and we are relying on your consent as the lawful basis for holding on to your data;
3) You object to our processing of your data, and there is no overriding legitimate interest for us to continue such processing; or
4) We are processing your data for direct marketing purposes and you object to that processing.
7. THIRD PARTY SERVICES
You may access other third party services while using La VPN, for example, by clicking on links of third party services from within La VPN. We are not responsible for the privacy policies and/or practices of these third party services. We encourage you to carefully review their privacy policies.
1) Paid La VPN
For paid La VPN, we do not work with third party advertising partners.
2) Free La VPN
For free La VPN, we work with third party advertising partners to offset the cost of providing our services. We do not target advertisements based on your data. We do not share or use your data in connection with third party advertisers without your prior consent.
Third party advertising partners may set and access their own cookies, pixel tags, and similar technologies on our services, and may otherwise collect or have access to data about you which they may collect over time and across different online services.
9. CHILDREN’S PRIVACY
We encourage parents and guardians to teach their children about privacy and how their information may be used on the Internet. Children should never disclose their name, address or phone number, or any personal information, without their parents’ or guardian's prior permission.
We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their state of residence.
If we consider that any of our services are directed at users under the minimum legal age required in their country of residence, we can block such users from using the services or from providing information and/or limit the collection of information from such users as described below in more detail.
No personal information should be submitted to La VPN by users under the minimum legal age required in their state of residence. We apply the following limitations to personal information collection for a user that is not of the minimum legal age required in their state of residence.
Such a user cannot:
l display their real name or any information in La VPN
l access the chat, leaderboard, forums, SNS (Facebook, Game Center, etc.)
l subscribe to newsletters
l use any other feature where users could appear under their real names
With respect to such a user, we will prevent the collection and use of their precise geolocation data and display to them contextual advertising only (excluding any behavioral advertising).
Children can be invited to take part in testing our apps with their parents' or guardians’ authorization and/or their parents' or guardians’ physical presence being required depending on the state where the playtest is conducted.
10. ORDERS COMPELLING THE DISCLOSURE OF YOUR DATA
Our collection of your data is limited. We collect your device identification code, and other data you may volunteer to us when you voluntarily contact us by way of email, phone, or interactions on La VPN’s application page on Google Play or App Store. We do not collect IP addresses, browsing history, traffic data, or DNS queries that could be used to identify you. As such, the extent of any disclosure of your data is limited.
We are committed to safeguarding your data. Nonetheless, we may be compelled to disclose your data where we are served with a valid court order that is enforceable in Singapore, an order from law enforcement agencies, or where we are legally obligated to disclose your data. We will require the recipient of your data to undertake to protect your data, to a standard that is at least comparable to the protection required under Singapore’s Personal Data Protection Act (“PDPA”).
When you become a user of La VPN, you may request to access your data that is associated only with you by emailing [email protected] .
To protect your privacy and security, we may take reasonable steps to verify your identity before acceding to your request. Upon our approval of your access request, we will provide you with your data that is in our possession or under our control. Where applicable, we will provide you with information about the ways in which your data has been or may have been used or disclosed by us within a year of your request. We may charge you a fee for the access request.
You may make a request to correct an error or omission about your data that is in our possession or control, by emailing [email protected]
We will consider whether the correction should be made. If such correction is to be made, we shall correct your data as soon as practicable and send the corrected data to every other organisation to which your data was disclosed by us within a year before the date the correction request was made, unless that other organisation does not need the corrected data for any legal or business purpose.
To protect your privacy and security, we may take reasonable steps to verify your identity before correcting your data. Your data may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes.
If you are a resident of the EEA, we ask that you keep the information that you provide to us updated. You can correct any information you have provided by contacting us through this form.
You represent and warrant that all information you provide us is true and correct, and relates to you and not to any other person.
You can exercise your rights at any time and ask La VPN for access to, or rectification or erasure of, your information.
Please note that other third parties (our data partners) may be controllers of your information. You can obtain more details and opt out of the sharing of your personal information to third parties for any purpose by contacting us by emailing [email protected]
If you have previously consented to any direct marketing communication from us or subscribed to our newsletters, you can unsubscribe by clicking on a link available in each communication and newsletter we send you.
Please note that VPN functionality, services and features can be affected by your actions. Some of your information and its processing is mandatory for La VPN to provide the services.
Your actions may force La VPN to cease providing the services. When the conditions below apply, it will be reset:
- If you ask for the modification of this mandatory information, we may not be able to continue to link La VPN or our services to you.
- If you request limitations to processing that are mandatory for La VPN, or you object to such processing (in which case, we may not be able to provide you with La VPN or our services).
- If you withdraw your consent or ask for the deletion of your information.
- If you withdraw your consent or ask for the deletion of your information, we will not use or process your information anymore but we will store it to answer regulatory or police requests. We also reserve the right to retain an archive of such information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such information.
Please specify your request by emailing [email protected]
If you are the parent of a child who is under 13 years of age (or under another age specified by applicable regulations) and believe your child has provided us with information, please fill out by emailing [email protected] and we will delete the information from our system.
To preserve the confidentiality of your information, we must be able to correctly identify you. For this reason, please provide us with a copy of an official document to prove your identity. This copy will be safely destroyed within two months of your request being received and closed.
Our team will look into your request and answer you within one month, unless your request requires further investigation. You’ll be specifically informed if that is the case.
The California Consumer Privacy Act of 2018 (CCPA) permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has collected, shared with, and/or sold to third parties for a business or commercial purpose during the immediately preceding calendar year.
As a Californian consumer, you also have the right, at any time, to opt out of any type of selling of your personal information.
13. BREACH NOTIFICATION
We will report serious breaches of your data to the relevant supervisory authority to ensure your data is protected.
If we materially change the ways in which we use or share your data previously collected through La VPN, we will notify you through La VPN, email, or other communication.
15. DATA PROTECTION OFFICER
HP Yeo is our Data Protection Officer ("DPO"). The DPO may be contacted at [email protected]