Privacy and Policy
Welcome to KonnektVPN and our website at www.konnektvpn.com. You are about to read more about which Personal Data we collect from you via our website and shop, what we use it for, when we delete it and how your data is protected. In addition, we will inform you of the respective legal basis that allows us to process your data. Further, we will also tell you about your rights in connection with the processing of your data. What is Personal Data? Personal Data is information that makes it possible to identify a natural person. This includes in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made. What is Processing? "Processing" means and covers virtually any handling of data. What law applies? We will only use your Personal Data in accordance with the applicable data protection laws, in particular the Delaware Personal Data Privacy Act (“DPDPA”) and the EU’s General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy. Who is responsible for data processing? The responsible party within the meaning of the DPDPA and the GDPR is Synthia Group LLC of 1111b South Governors Avenue Ste 6711 - Dover - Delaware - 19904, Delaware, USA (“Synthia Group”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please feel free to email us using info@synthia.group, or use our Contact Form. Data collection All Personal Data that we obtain from you will only be processed for the purposes described in more detail below. In particular, we collect Personal Data only if: you have given your consent; the data is necessary for the fulfillment of a contract / pre-contractual measures; the data is necessary for the fulfillment of a legal obligation; or the data is necessary to protect the legitimate interests of our company and business. We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with Delaware`s Commercial Law and Fiscal Code and others for up to 6 years. The corresponding data is routinely deleted once the purpose has been achieved or the retention period has expired. Data transfers In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients. Internal If necessary, we transfer your Personal Data within KonnektVPN. Of course, we comply with the associated legal framework and ensure that your data is processed properly. Access to your Personal Data is only granted to authorized employees who need access to the data due to their job, e.g., to fulfill your order or to contact you in case of queries. External bodies Personal Data is transferred to our service providers in the following instances: in the context of fulfilling your orders, shipping, and delivery, to use marketing services and to advertise our social media channels and merchandise online, to communicate with you, to provide our website and shop, and to state authorities and institutions as far as this is required or necessary. We usually do not transfer Personal Data to countries outside the USA. However, if we do, we ensure that the processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection. Links to other websites Please note that if you use a link from our website to a third-party website, that third party may also set new cookies that are not covered by this policy. In such cases, we recommend that you read the cookie policy on the third-party website itself. Security of your data In order to protect the data stored with us in the best possible way against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons, we use appropriate technical and organizational security measures. The security levels are continuously reviewed in cooperation with security experts and adapted to new security standards. Nevertheless, Internet-based data transmissions can always have security gaps, so absolute protection cannot be guaranteed. Databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after discovering the breach. Your Rights and Privileges Privacy rights Under the DPDPA and GDPR, you can exercise the following rights: Right to information Right to rectification Right to deletion Right to data portability Right of objection Right to withdraw consent Right to complain to a supervisory authority Right not to be subject to a decision based solely on automated processing. Updating your information If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us. Withdrawing your consent You can withdraw consent you have given at any time by contacting us. Access Request In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we cannot provide you with any Personal Data or make a correction requested by you, we will tell you why. Complaint to a supervisory authority You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority. Processing of your Personal Data Log files As mentioned above, we want to provide you with an optimal user experience in our online shop and with our advertisements, which is tailored to your individual needs. To this end, we work together with various service providers and technology providers and use cookies and tracking methods. The following data is collected anonymously for the purpose of demand-oriented design and optimization of this website: Information on the device used (e.g., operating system, browser, screen resolution, language set. Information on pages viewed during the website visit (e.g., category or product detail pages) Information within the ordering process (e.g., order number, delivery, and payment method, shipping and/or billing address) Information on access data (e.g., entry via email newsletters, other websites or online advertising measures). The scope of the stored and processed data is limited purely to the performance of statistical evaluations. Your IP address is made unrecognizable immediately after receipt, which means it is impossible to assign usage profiles to IP addresses. The collection of the data is necessary from a technical point of view to continuously optimize the functions and the presentation of our website on different devices, operating systems, and browsers and to make our offer more interesting for you as a user. It is therefore based on the legitimate interest. Cookies We distinguish between two categories of cookies: Essential and Necessary cookies. These cookies are essential or necessary to ensure that a website works properly and is secure so that you can navigate a website and use its features. Without these cookies, certain features of a website would not function, and thus you would not be able to use certain services. Optional cookies. These cookies are non-essential for the website to function and require your consent. When it comes to optional cookies, the following distinctions are made: Functional cookies are sometimes called convenience cookies. These cookies allow a website to remember a user's options (including user IDs stored, consents given, or languages selected) and other personalization options you have selected when browsing. Analysis and performance cookies are used to monitor and improve the function and service of a website. Those can track down problems when using a website, facilitate online surveys, record visitor numbers, and provide analytics metrics. Advertising cookies or targeting cookies. They are used to deliver customized advertising to the user. This can be very convenient, but also very irritating. The DPDPA and the EU`s Privacy and Electronic Communications Directive (“PECD”), require us to ask for your consent when using specific cookies (in particular any cookie that is not strictly necessary for the operation of the website, for example, Functional cookies, Analysis and performance cookies and Advertising cookies or targeting cookies “Optional cookies”). Further and as the DPDPA and the GDPR also require a legal basis for the use of personal data in relation to cookies, the use of cookies would then be your consent as well as our legitimate interest. We only use optional cookies with your prior consent. If you are visiting our website for the first time, a banner will appear on our website asking for your consent to use optional cookies. If you consent to this, we will store a cookie on your computer and the banner will not be displayed again for the lifetime of the cookie. Thereafter, or if you actively delete this cookie beforehand, the banner will be displayed again the next time you visit our website in order to obtain your consent again. Of course, you can also use our website entirely without cookies. You can configure the use of cookies in your browser settings by following the relevant link Google Chrome, Mozilla Firefox, Flash cookies, Microsoft Internet Explorer and Edge, Opera, Safari at any time or deactivate them completely. However, this may lead to restrictions in the functions or user-friendliness of our offer. Pixel Cookies and Tags We use so-called Pixel Cookies and Tags (“Pixel Cookies”). A Pixel Cookie is an advertising tool and typically consists of a JavaScript code snippet that allows us to understand and track visitors' activity on our website. For this purpose, Pixel Cookies collect and process information about visitors of our website and the device used (so-called event data). Event data collected through Pixel Cookies is used for targeting our advertisements and improving ad delivery and personalized advertising. For this purpose, the event data collected on our website by means of Pixel Cookies is transmitted to the relevant operator of the Pixel Cookie and in part, also stored on your device. However, this only happens with your consent, and we and the relevant operator of the Pixel Cookie are considered joint controllers. Nonetheless, for the subsequent processing of the transmitted Event Data, the relevant operator of the Pixel Cookie is the sole controller. For more information about how the relevant operator of the Pixel Cookie processes personal data, including the legal basis on which they rely on and how you can exercise your rights against, please refer to the following Privacy Policies: Facebook, X (formerly Twitter) and YouTube, Google. Opting Out Facebook If you do not wish to participate in usage-based advertising through Facebook you can object here: https://www.facebook.com/settings?tab=ads X If you do not wish to participate in usage-based advertising through X you can change your ad settings by following these instructions: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads YouTube and Google If you do not wish to participate in usage-based advertising through YouTube and Google you can change your ad settings by following these instructions. General If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices and the European Interactive Digital Advertising Alliance (Europe only). Hosting of our website We use the hosting services of Amazon (AWS), for the purpose of hosting and displaying our website. AWS does so on the basis of processing on our behalf, and that also means that all data collected on our website is processed on AWS' servers.The basis for processing is our legitimate interest, and the initiation and/or fulfillment of a contract. Contact options We process and store the Personal Data provided in the contact enquiry solely for the purpose of processing and responding to your enquiry and contacting you. If you contact us, we will process the data you provide to respond to you and answer your questions and requests. In doing so, the principle of data economy and data avoidance is observed in that you only have to provide the data that we absolutely need from you in order to contact you. These are usually your first and last name, your email address, the topic selection and the message field itself. In addition, your IP address is processed out of technical necessity and for legal protection. The legal basis for processing is our legitimate interest, the provision or initiation of a contractual service and your consent. Account Registration If you register, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form. The entry of your data is encrypted so that third parties cannot read your data when it is entered. The basis for this processing is our legitimate interest and to fulfill our contractual obligations. Of course you can delete your account at any time using the Delete Account Feature in our App. When using our services in general We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfillment of our accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations. Shopping with us We process your first name, last name, e-mail address, billing and shipping address for the delivery of your order and the data related to your contract with us to handle the contractual relationship. When you use our VPN service To protect your privacy, we only collect the minimum information necessary, and that is your userId to let you access our service. We store your userId encrypted on our secured servers. We keep a temporary log of connection data for troubleshooting purposes, which includes a randomly generated userId and is securely deleted every few hours. This randomly generated userId cannot be linked to you. We have deliberately and consistently chosen not to log all other data in order to limit our legal liability. We do, however, log the Connection status, bandwidth consumption so that we can bill you properly and maintain a high quality of service. All usage data is anonymised and not linked to your real, public IP address. We do NOT log your VPN sessions, browsing behavior, the websites you visit, or any other activity related to your VPN connection. In addition, we NEVER store VPN connection logs and timestamps that associate your incoming and outgoing IP address or session duration. Referrals To implement our referral program, we process the data of the referrer and the referral recipient that we have collected in connection with the referral. The processing is carried out exclusively for the implementation of our Referral program and is necessary for this purpose, as participation would otherwise not be possible. The personal data will be transmitted and used there exclusively for the implementation of our referral program. The basis for this processing is our legitimate interest, to fulfill our contractual obligations and your consent. Account Administration We process data such as your email, and account details, the subscription plan subscribed to (if any), the platform where the subscription is managed through (e.g. IOS, Android,) in the context of administrative tasks as well as organization of our business, and your subscriptions and compliance with legal obligations. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest. Connecting your Wallet To use our services, you may connect your crypto wallet and some Personal Data may be collected by the relevant wallet provider (MetaMask, or Coinbase). The data transmitted to MetaMask or WallectConnect is processed by the respective wallet service and thus subject to MetaMask`s or WallectConnect`s Privacy Policy. We would like to point out that we are not responsible for any processing of Personal Data when connecting your crypto wallet. The legal basis for the provision of a crypto wallet system is the establishment and implementation of the contract. Purchases and subscriptions When you make a in app purchase, our payment service providers Google, Apple may collect the following data from you to process the desired order: a)user ID; b) Email address; c) Payment confirmation from the payment data collected depending on the payment method; and d) Device IP and device serial number to link the story history to the device. If you make a purchase for our physical products through our App your payment will be processed via our payment service provider Stripe or your chosen crypto wallet service provider. Payment data will solely be processed through Stripe or the crypto wallet service provider as selected by you. In both cases,we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract. Social Media General We are present on social media on the basis of our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest. Market research and advertising In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. The legal basis is our legitimate interest. When you visit our profiles and interact with us and others When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent. Marketing General Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to. You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us. Direct Marketing generally takes the form of email or our newsletter but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out. Changes We are constantly developing and improving our website - and as a result, some of the information in this Privacy Policy is likely to change. We therefore recommend that you read this Privacy Policy again from time to time so that you are informed about the current status. Validity and Questions This Privacy Policy was last updated on Sunday, October 26th 2023, and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any questions about this policy or our data protection practices, please contact us using info@synthia.group, or use our Contact Form.