Privacy Policy

This Privacy Policy (hereafter referred to as “This Policy”) outlines the manner in which Adventrum AB handles the information and personal data which You have provided to Us and which enables Us to be able to effectively manage the relationship which You have with Us.

This Policy applies to Our websites, applications, products and/or services that link to this policy or do not have a separate privacy policy (hereinafter referred to as Our services). This privacy policy is intended to give You a better understanding of the data We collect, the reason why We collect such data, the manner in which We process this data, the entities with whom We share the said personal data, Your rights in relation to the collection, processing and sharing of such data and any other pertinent matter relating to privacy and security.

Any personal data You will provide or which We already hold will be processed in line with and in the manner set out in this Privacy Policy. Any and all information will be provided through any of the Adventrum  website (“The Website”) or any other means which Adventrum may make available from time to time.

By reading This Policy You understand and acknowledge that Your personal data may be processed in the manner set out in this policy. If You do not agree with the terms of this Privacy Policy please do not use the Website or otherwise provide Us with Your Personal Data.

Any references in this Policy to “Adventrum ”, “Us”, “We” or “Our” relate to the Data Controller, namely, Adventrum AB, a Maltese company bearing registration number and having its registered address at of Karlavägen 86, 115 22 Stockholm, Sweden and registered under the Laws of Sweden with registration number 556420-9632 and which is the owner of the website http://vpnro.net/

All processing of Personal Data performed by Adventrum  as envisaged in this Privacy Policy shall be carried out in line with:

–      Regulation (EU) 2016/679 of The European  Parliament And of The Council of 27 April 2016  On The Protection of Natural Persons With Regard to The Processing of Personal Data And On The Free Movement of Such Data, And Repealing Directive 95/46/EC (General Data Protection  Regulation)” (hereinafter referred to as “the Regulation” or “GDPR”).

The DPA and the GDPR shall hereafter be collectively referred to as the “Data Protection Laws”.

Adventrum  determines the means and purposes of the processing of Personal Data and therefore acts as the “Data Controller” in terms of the applicable Data Protection Laws.  

DEFINITIONS

Cookies

“Cookies” means small set of data stored in the User’s device

The Data Controller

Adventrum AB

DPO contact Email: [email protected]

The Data Processor

“The Data Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

The Data Subject

“The Data Subject” is the natural person to whom the Personal Data refers.

Personal Data

“Personal Data” means any information that identifies You individually or relates to an identified or identifiable natural person.

Usage Data

“Usage Data” means information collected automatically through the website (or third party services employed by Adventrum ), which can include: IP addresses, the various tie details per visit and the details about the path followed with special reference to the sequence of the pages visited and other parameters about the device operating system and/or User’s IT environment.

User

“User” is the individual using http://vpnro.net/  who unless otherwise specified coincides with the Data Subject

SECURITY

Adventrum stores Your Personal Data digitally on encrypted hard drives.

PERSONAL DATA PROTECTION

Personal Data held by Us is protected using the highest industry standard security processes and systems. Our commitment to protect personal data is not merely through quality and high standards but also through the best and most efficient application of the law. We are bound to only process personal data if such processing is based on a genuine and legitimate reason to do so on the basis of one of the legal grounds established in the GDPR.

PERSONAL DATA YOU GIVE US

You may give us your personal by:

• Filing the contact Us forms

In the following, We report the detailed set of data We ask you, mandatorily or optionally for each process you may be involved in.

PERSONAL DATA WE COLLECT FROM YOUR DEVICE

We use Usage Data and Cookies to manage Our website and to make sure that content from Our website is presented in the most effective way for you and your device.  For more information about cookies, please see our Cookie Policy.

LAWFUL BASIS FOR PERSONAL PROCESSING

PROCESSING ON THE BASIS OF OUR LEGITIMATE INTERESTS

A legitimate interest exists when We have a business or commercial reason upon which personal data will be processed. In such a case We undertake to protect any and all of Your personal data and the manner in which such data is processed and to ensure that such processing would not be unfair to You or Your interest.

PROCESSING ON THE BASIS OF YOUR CONSENT

Consent is not the only ground we may be permitted or obliged to rely on to process Your personal data. We will only process personal data on the basis of Your consent where we cannot or otherwise choose not to rely on any ulterior legal ground (such as compliance with a legal obligation or legitimate interest). Where we process Your personal data on the basis of Your consent, you shall have the right to withdraw your consent at any time and in the same manner as it had been previously provided by Yourself. In the case that You exercise Your right to withdraw consent, we would then determine whether we are able (or obliged) to process Your personal data on the basis of any other legal ground other than consent. If this is the case We will notify You accordingly. Any such withdrawal of Your consent will not invalidate any processing operations carried out prior to You have withdrawn Your consent.

For the avoidance of all doubt, We would like to point out that in those limited cases where We cannot or choose not to rely on another legal ground (for example, Our legitimate interests), We will process Your Personal Data on the basis of Your consent. 

In those cases where We process on the basis of Your consent (which We will never presume but which We shall have obtained in a clear and manifest manner from You), YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME and this, in the same manner as You shall have provided it to Us. 

Should You exercise Your right to withdraw Your consent at any time (by writing to Us at the physical or email address below), We will determine whether at that stage an alternative legal basis exists for processing Your Personal Data (for example, on the basis of a legal obligation to which We are subject) where We would be legally authorised (or even obliged) to process Your Personal Data without needing Your consent and if so, notify You accordingly. 

When We ask for such Personal Data, You may always decline, however, should You decline to provide Us with the necessary data that We require to provide requested services, We may not necessarily be able to provide You with such services (especially if consent is the only legal ground that is available to Us). 

Just to clarify, consent is not the only ground that permits Us to process Your Personal Data. In the last preceding section, We pointed out the various grounds that We rely on when processing Your Personal Data for specific purposes. 

OTHER PURPOSES

We may be required to use and retain personal information for; loss prevention; and to protect Our rights, privacy, safety, or property, or those of other persons in accordance with Our legitimate interests.

DATA RETENTION

We are required to keep your documents according to Our Data Retention Policy.  After this period, your personal data will be irreversibly destroyed.  Any personal data held by Us for service notifications will be kept by Us until such time that you notify Us that you no longer wish to receive this data. Should you need further information about the retention periods please contact us at [email protected]

We retain data for limited periods when it needs to be kept for legitimate business or legal purposes. We try to ensure that our services protect information from accidental or malicious deletion. Because of this, there may be delays between when you delete something and when copies are deleted from our active and backup systems.

DO WE SHARE YOUR PERSONAL DATA?

We share your personal data with third party suppliers to provide you with the best service.

Moreover, the Company may share your personal data with:

• Other third parties to the extent necessary to: (i) comply with a government request, a court order or applicable law; (ii) prevent illegal uses of Our website, violations of Our website, its terms of use and Our policies; (iii) defend Ourselves against third party claims; and (iv) assist in fraud prevention or investigation.
• To any other third party for which you have provided Us with your consent

AUTHORISED DISCLOSURES OF PERSONAL DATA TO THIRD PARTIES

Without prejudice to anything else contained in this Privacy Policy, personal data relating to You may be shared with authorised third parties located in or outside of the EU/EEA where such disclosures are permitted or required pursuant to Data Protection Laws and/or any other applicable legislation. These authorised third parties may include but are not limited to entities within Adventrum , other third parties and organisations such as law enforcement agencies, collaborating accounting and auditing firms, regulators, relevant authorities and digital marketing providers. We may also share such personal data with organisations who have introduced You to Us, third parties which You have asked Us or permitted Us to share Your data with or any other third party which We must necessarily share Your personal data with so as to be able to provide the products and/or services which You have requested. The personal data shared will depend on the product/s and or service/s You choose to use.

When any such personal data has to be transferred outside of the EEA – European Economic Area, We ensure that all the necessary and appropriate safeguards are in place. We may also disclose personal information to other companies within associated or subsidiary companies and to business partners, or successors in title to Our business. The manner in which data transfer outside the EEA is handled is detailed below. Your Personal Data will never be shared with third parties for their marketing purposes (unless You give Your consent thereto).

SHARING OF PERSONAL DATA WITH OTHER CATEGORIES OF RECIPIENTS

Relevant data will also be disclosed or shared as appropriate (and in all cases in line with the Data Protection Laws) to/with members and staff of Adventrum, to/with other entities within Adventrum  (for example in compliance with legal obligations) and/or to/with affiliated entities and/or subcontractors established within the European Union if pertinent to any of the purposes listed in this Privacy Policy (including to/with Our services providers who facilitate the functionality of the Site and/or any service You may require). Personal information will only be shared by Us to provide the services You request from Us or for any other lawful reason (including authorised disclosures not requiring Your consent).

Any such authorised disclosures will be done in accordance with the Data Protection laws (for example, all Our processors are contractually bound by the requirements in the said Data Protection Laws, including a strict obligation to keep any information they receive confidential and to ensure that their employees/personnel are also bound by similar obligations). The said service providers (Our processors) are also bound by a number of other obligations (in particular, those established in Article 28 of the GDPR).

Your Personal Data will never be shared with third parties for their marketing purposes (unless You give Your consent thereto).

INTERNET COMMUNICATIONS

You will be aware that data sent via the Internet may be transmitted across international borders even where sender and receiver of information are located in the same country. We cannot be held responsible for anything done or omitted to be done by You or any third party in connection with any Personal Data prior to Our receiving it including but not limited to any transfers of Personal Data from You to Us via a country having a lower level of data protection than that in place in the European Union, and this, by any technological means whatsoever (for example, WhatsApp, Skype, Dropbox etc.).

Moreover, We shall accept no responsibility or liability whatsoever for the security of Your data while in transit through the internet unless Our responsibility results explicitly from a law having effect in Sweden.

ACCURACY OF PERSONAL DATA

All reasonable efforts are made to keep any Personal Data We may hold about You up-to-date and as accurate as possible. You can check the information that We hold about You at any time by contacting Us in the manner explained below. If You find any inaccuracies, We will correct them and where required, delete them as necessary. Please see below for a detailed list of Your legal rights in terms of any applicable data protection law.

LINKS TO THIRD-PARTY SITES

Links that We provide to third-party websites are clearly marked and We are not in any way whatsoever responsible for (nor can We be deemed to endorse in any way) the content of such websites (including any applicable privacy policies or data processing operations of any kind). We suggest that You should read the privacy policies of any such third-party websites.

TRANSFER OF DATA OUTSIDE OF THE EEA

Your personal data will only be transferred outside of the EEA or any other non-EEA country which has been deemed by the European Commission to offer an adequate level of protection (also referred to as “white-listed countries” – listed here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en) in the following circumstances: When You have expressly consented Us to do so; when it is necessary to constitute or execute a contract entered between You and Adventrum; or to be compliant and in line with any and all legal obligations or duties.

In the event that personal data is transferred outside of the EEA, within Adventrum  or to any of Adventrum ’s business partners, We ensure to implement all appropriate safeguards to ensure that the same protection is afforded and the same standards are applied as would be within the EEA. You are entitled to receive a copy of such safeguards by contacting Us at the address below.

Contracts containing the EU Standard Contractual Clauses (EU Model Clauses) will be used which require the entity receiving the personal data to use the same standards as they would be subject to within the EEA. Should any data be transferred to the USA and the entity receiving the data is registered with Privacy Shield (a framework that ensures personal data protection) it will be taken with the same level of protection as approved by the European Commission.

DATA SUBJECT RIGHTS

Adventrum  undertakes to assist You in the best way possible should You choose to exercise any of Your rights with respect to Your personal data. In certain cases, We might need to verify Your identity prior to acceding to Your request to exercise any relevant right.

• Access to your personal data
• An electronic copy of your personal data (portability)
• Correction of your personal data if it is incomplete or inaccurate
• Deletion or restriction of your personal data in certain circumstances by applicable law.

COMPANY INFORMATION

If You have any questions/ comments about privacy or should You wish to exercise any of Your individual rights, please contact our DPO at: [email protected] or by writing to the address above.

CHANGES TO THIS PRIVACY POLICY

Adventrum  reserves the right to make changes to the privacy policy at any time.  It is recommended to check this page often, referring to the date of the last update. Should the changes affect activities performed on the basis of the User’s consent, Adventrum shall collect new consent from the User, where required.

Last update: 2022-11-15