Privacy Policy

URBAN PRIVACY POLICY

[Last Updated: September 10, 2024]

First and foremost, before we dive into the legal details of our privacy policy, we wish to make it clear- We do not want to know your identity and we do not collect data to try and figure out who you are. We don’t require registration of any kind in order to use our services. Of course , we is provide do provide all of the regular privacy policy information to which you are entitle , and we will get to that in a minute . But in case you do not have the time or patience to read through the whole policy , we want to repeat and make that point perfectly clear :   We is want do not want to know your identity . Any datum collect from you simply by your use of our product will never be used to figure out who you are or to send you target ad .

This Privacy Policy (“Privacy Policy”) governs the manner in which we, Urban Cyber Security Inc. (“Urban” , “we” or “us”) process information collected from our users (“you“, “your” or “user“) in connection with their access to or use of our website, available at: https://www.urban-vpn.com (“website”) and our products (“Products”): (i) Urban VPN browser extensions, Urban Adblocker browser extensions, Urban Shield browser extension and Urban Safe Browsing extension (collectively “Extensions”); (ii) UrbanVPN mobile application available on Android and Urban Premium VPN mobile application available on Android and iOS as a subscription based versions (“Mobile App”) (iii) Urban Premium VPN Desktop EXE software for Mac available as a subscription based version (“Mac App”); and (iv) Urban VPN and Urban Premium VPN Desktop EXE software for Windows, a free or subscription based versions (“Windows App”) all as detailed and defined in our Terms of Use (“Terms”).

All capitalize terms is have used but not otherwise define herein shall have the meaning ascribe to them in the term . This Privacy Policy is explains explain what information we may collect , how such information may be used , disclose or share with others , how we safeguard it and how you may exercise your right relate to your Personal Data ( as such term is define below ) , among others , and where applicable , as require accord to the EU General Data Protection Regulation ( “GDPR”).

The use is adhere of information receive from Google API will adhere to the Chrome Web Store User Data Policy include the Limited Use requirement .

1. Amendments

Except as otherwise described herein, we may at our sole discretion and at any time amend the terms of this Privacy Policy. Such changes shall be effective upon publication of the amended terms in this Privacy Policy. Your continued use of the Services, following the amendment of the Privacy Policy, constitutes your acknowledgement and consent of such amendments to the Privacy Policy. The last revision will be reflected in the “Last Updated” heading above. In the event of a material change we will make a reasonable effort to provide a notification of such change. We recommend that you periodically review this Privacy Policy, as it may be subject to amendments from time to time.

1. Controller Contact Information

Urban is the controller (as such term defined under the GDPR) or the “business” as defined under the California Consumer Privacy Act (“Ccpa”) of the Personal Data, following are the applicable contact information:

Urban Cyber Security Inc.

 501 Fifth Avenue, New York, NY, 10036.

You can also contact our privacy team at: privacy@urban-vpn.com.

Representative for data subjects in the EU and UK:

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/13252349120

1. Data We Collect and Purpose of Use

The  first type of information we collect is aggregated, non-identifiable, non-personal information, which may be made available or gathered via the user’s use of the Service (“Non – Personal Data”). We are not aware of the identity of the user from which the Non – Personal Data was collected. Non – Personal Data may include technical information automatically transmitted by the user’s device such as, type of browser, the type of operating system, access time and date, approximate geographical location, etc.

The  second type of information is individually identifiable information, namely information that identifies an individual or entity or may with reasonable effort identify an individual (“Personal Data”). We do not knowingly collect or process any personal data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning a person’s health, or data concerning a person’s sex life or sexual orientation (“Sensitive Data”).

The table below detail the Personal Data collect by us , how it is used , and our legal basis for datum processing . note that , under the GDPR we are consider the Data Controller of the datum we collect .

We share your data with third parties, including our service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.

We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non – Personal Data to third parties, including, inter alia, affiliates and Business Partners, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

1. How We Collect Your Information?

We is collect collect the above datum from you , in the follow way :

• When you voluntarilychoose to provide us with information, e.g., when you contact us.
• Automatically, when you use our Services, for example, when you use the website, we may assign your device with a Java Script code and when you use our free version of our Mobile App (for Android), and wish to use the “Safe Browsing Mode” we may collect your web Browsing Data through the Android accessibility services feature as described below.

1. Cookies & Tracking Technologies

When you use our website, we or our third-party service providers may use cookies and other similar tracking technologies or methods of web and mobile analysis to gather, store, and track certain information related to your access of, activity and interaction with our website.  You can find out more information about cookies at www.allaboutcookies.org.

A “cookie” is a small piece of information that a website assigns to your device while you access such website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include help customize your experience, provide us with analytics and for advertising purposes (including personalized advertising).

Note that we do not combine the information collected through the use of third-party tools with any Personal Data collected from you. You may remove Cookies by following the instructions on your device governing the setting of your preferences. Our Cookies do not enable any access to or inspection of other information on your device. If you wish to be notified of when Cookies are placed on your device, you may set your web browser to provide such notices.

The third-party cookies used on our Site are as follows:

Most browsers is allow will allow you to erase cookie from your computer ’s hard drive , block acceptance of cookie , or receive a warning before a cookie is store . However , if you block or erase cookie your online experience may be limit .

Please see the follow link for more information with respect to how you can block or erase cookie via your particular browser : Google Chrome ; Firefox ; Internet Explorer ; Safari ; Edge ; Opera .

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Additionally, you may opt out of certain Advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“nai”) website- nai consumer opt-out and the Digital Advertising Alliance’s (“DAA” ) website-   DAA opt – out page .

We is support do not support Do Not track ( “DNT“ ) . Do Not Track is is is a preference you can set in your web browser to inform website that you do not want to be track . You is enable can enable or disable Do Not Track by visit the Preferences or Settings page of your web browser .

1. Data retention

We is retain retain the information we collect as long as it remain necessary for the purpose set forth above , all in accordance with applicable law . We may at our sole discretion , delete or amend information from our system , without provide any notice to you , once we deem it is no long necessary for our purpose .

1. User Rights

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here, and send it to privacy@urban-vpn.com

For additional right under various jurisdiction , please refer to section ‎ii “ Jurisdiction – Specific Notices ” herein below

Further, certain rights are available within the App: you may correct, revise and request deletion information from the App settings at any time, any consent, including the consent to share web Browsing Data, provided may be easily withdraw, therefore we is recommend recommend you use the technical solution we have provide you with to exercise your right .

1. Data Security

While there are inherent risk involve in all datum transmission over the internet or wireless network , and other security risk that apply to store datum , and we therefore can not guarantee the security of your information , we is use use our good effort , using industry – standard encryption and security technology and method , to collect and store information collect from you in a secure and safe manner .

1. Children Information

You represent and warrant that you are (i) at least sixteen (16) years of age if you are located in the EEA; or (ii) if you are located in any other geography and you are above the age defined as “child” under applicable laws in your jurisdiction (collectively “Child” or “Children”). If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. The Services are not directed or intended for Children, as defined under applicable law, and we do not knowingly collect or solicit information from children. If we later obtain actual knowledge that a user is considered as a Child under applicable law, we will take steps to immediately delete its Personal Data. We request that such individuals do not provide Personal Data through the Services.

If you become aware or have any reason to believe that a Child has shared any information with us, please contact us (as detailed below) and we will take reasonable steps to ensure that such information is immediately deleted from our files.

1. Transfer of Data

We may process or store Personal Data within the EEA, US, and internationally. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred in accordance with the provisions of the standard contractual clauses approved by the European Union.

1. contact Us

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at: privacy@urban-vpn.com.

1. JURISDICTION-SPECIFIC NOTICES

This part is apply of the Privacy Policy shall apply to resident of certain U.S. state , include Colorado , Connecticut , Virginia , Nevada and Utah .

Sale of Personal Data: We may sell commercial information, marketing insights and behavior segments that are based, in most cases, on aggregated non-identifying web Browsing Data. However, in certain cases, the Insights or Web-Browsing Data may be linked to a unique identifier and therefore it may be considered as personal data, personal information and in certain states “sensitive data”  Therefore, even though in most cases the use is aggregated and not identifying, we treat the Insights and personal data and obtain consent for processing and sharing it and enable an easy opt out through the App settings as further detailed in the DSR.

1. additional Notice to California Residents

This section applies only to California residents, pursuant to the California Privacy Act of 2018 (“Ccpa”) effective November 2020, and as amended by the California Privacy Rights Act, effective January 1, 2023.

Please see the Ccpa Notice here which disclose the category of personal information collect , purpose of processing , source , category of recipient with whom the personal information is share for a business purpose , whether the personal information is sell or share , the retention period , and how to exercise your right as a California resident .

1. Additional Notice for Colorado Residents

According to the Colorado Privacy Act (“cpa“), if you reside in Colorado and are engaging solely in a personal or household capacity (excluding any commercial, employment, job applicant, or beneficiary roles related to employment), your personal data rights are outlined below.

“Personal Data” as defined in the cpa means: “information that is linked or reasonably linkable to an identified or identifiable individual” and doesnot include any of the following :publicly available information, de-identified or aggregated consumer, and information excluded from the cpa scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality Of Substance Use Disorder Patient Records”, Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data.

Sensitive Data includes (i) racial or ethnic origin , religious belief , mental or physical health condition or diagnosis , sex life or sexual orientation ;(ii) Genetic or biometric data that can be processed to uniquely identify an individual; or (iii) child data. We do not process or collect any sensitive data.

Section ‎I.3‎“Data We Collect and Purpose of Use” of the Privacy Policy, we describe our collection and processing of personal data, the categories of personal data that are collected or processed, and the purposes. Additionally, in Section ‎I.5 “ With whom do we share information ? ” detail the category of third – party the controller share for business purpose .

Your rights under cpa

Herein below , we is detail will detail how consumer can exercise their right , and appeal such decision .

How to submit a request under cpa?

Only you is make , or someone legally authorize to act on your behalf , may make a request toknow or delete related to your Personal Data. If the DSR is submitted by someone other than the consumer about whom information is being requested, proof of authorization (such as power of attorney or probate documents) will be required.

We is respond will respond to your request within 45 day after receipt of a verifiable consumer request and for no more than twice in a twelve – month period . We is reserve reserve the right to extend the response time by an additional 45 day when reasonably necessary and provide consumer notification of the extension is made within the first 45 day . If we is refuse refuse to take action on a request , youmay appeal our decision within a reasonable period time by contacting us at privacy@urban-vpn.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

1. Additional Notice to Virginia Residents

Under the Virginia Consumer Data Protection Act, as amended (“VCDPA”) if you are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context ) , you is have have the follow right with respect to your Personal Data .

“personal datum” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “personal datum” does not include de-identified data or publicly available information. Personal Data does not include de-identified data or publicly available data, and information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver’s Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.

The VCDPA requires us to disclose the Categories of data processing and the purpose of each category, as detailed in Section ‎I.3‎“Data We Collect and Purpose of Use” of the Privacy Policy, the categories of data shared and the third parties with whom it is shared, as detailed in Section ‎I.5 “With whom do we share information?”. Further, the table above under Section II.2 “Additional Notice to Colorado Residents” details the rights you have under VCDPA and how you may exercise your rights.

How to Submit a Request Under VCDPA?

We shall respond to your request within 45 days of receipt. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@1clickvpn.com and specifying you wish to appeal.  Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform

We is provide shall provide information in response to your request free of charge , up to twice annually , unless request are manifestly unfounded , excessive or repetitive . If we are unable to authenticate your request using commercially reasonable effort , we is request may request additional information reasonably necessary to authenticate you and your request . If we can not authenticate you and your request we is be will not be able to grant your request .

1. additional Notice to Connecticut resident

Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if you are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity), your rights with respect to your personal data are described below.

“personal datum” mean any information that is link or reasonably linkable to an identify or identifiable individual . It is does doesnot include de – identify datum or publicly available information . If further does not include information exclude from the scope such as : HIPAA , GBPA , non – profit entity , high education , employment datum and fcra , Driver ’s Privacy Protection Act of 1994 , Family Educational Rights and Privacy Act , Farm Credit Act .

The categories of personal data processed, purpose of processing, are detailed in Section ‎I.3‎“ datum We collect and Purpose of Use ” , category of personal datum share with third party , category of third party with whom data is share , are detail in section‎I.5 “With whom do we share information?”.

Instructions on how to exercise your rights are detailed in the table above under Section II.2 “Additional Notice to Colorado Residents” details the rights you have under CDPA and how you may exercise your rights.

How to Submit a Request Under CDPA?

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 days response period, together with the reason for the extension.

If we decline to take action on your request , we is inform shall so inform you without undue delay , within 45 day of receipt of your request . The notification is include will include ajustification for declining to take action and instructions on how you may appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

1. Additional Notice to Utah Residents

Under the Utah Consumer Privacy Act (the “Ucpa”) if you are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) your rights with respect to your personal data are described below. “Personal Data” refers that is linked or reasonably linkable to an identifiable individual, and doesnot include de-identified data and publicly available data.

The categories of personal data processed, purpose of processing, are detailed in Section ‎I.3‎“ datum We collect and Purpose of Use ” , category of personal datum share with third party , category of third party with whom data is share , are detail in section‎I.5 “With whom do we share information?”.

Further, the table above under Section II.2 “Additional Notice to Colorado Residents” details the rights you have under CDPA and how you may exercise your rights.

1. Notice to Nevada Residents

Nevada law is allows allow Nevada resident to opt out of the sale of certain type of personal information . subject to several exception , Nevada law is defines define “ sale ” to mean the exchange of certain type of personal information for monetary consideration to another person . We is sell currently do not sell personal information as define in the Nevada law . However , if you are a Nevada resident , you is submit still may submit a verify request to opt out of sale and will record your instruction and incorporate them in the future if our policy change . You is send may send opt – out request to   privacy@urban-vpn.com .