Privacy
Policy
Last updated on
September 11, 2024
Autumn
Breeze is committed to protecting your privacy. Our guiding principle toward data collection is to collect
only the minimal data required to operate a world-class VPN service at
scale. We want you to understand what information we collect, what we
don't collect, and how we collect, use, and store information. We do not collect logs of your activity,
including no logging of browsing history, traffic destination, data content, or
DNS queries. We also never store connection logs, i.e., no logs of your IP
address, your outgoing VPN IP address, connection timestamp, or session
duration. We designed our systems not to have
sensitive data about you; even when compelled, we cannot provide data that we
do not possess.
This Privacy Policy
describes how AUTUMN BREEZE PTE. LIMITED and its affiliates ("Autumn
Breeze," "we," "our" or "us") collect,
use, and share information in connection with your use of our services, and
applications (collectively, the "Services"). This Privacy Policy (the
"Privacy Policy") does not apply to information you may process when
using our Services.
1.
(USER-CONTROLLED OPTION): PERSONAL INFORMATION
Our VPN APP is a non-obligatory log network. Autumn Breeze
are not available for the information related to the personal information of
users, including but not limited to names (subscriber names, user names and
screen names), addresses (including mailing addresses, residential address,
business addresses) and telephones, unless the data you provide depending on
the context of your interactions with us and the choices you make, including
your privacy settings, and the products and features you use for the purpose of
administering your subscription and for the purpose to enjoy our VPN services. Except
for the limited exceptions, we don't automatically collect any Personal
Information from you.
When you open the APP seeking for our VPN
services, the APP assigns a unique identifier to you for the service (such
unique identifier just binds up with your device identification code, but does
not tie to any other personal information of users). When you use the VPN
services, we will check your account information through this unique identifier
to determine the level of service you have signed up for before establishing
your VPN connection.
With some forms of payment, certain Mac version of our VPN
services may redirect you to the website of a third-party payment processor
(namely PayPal) to complete the transaction. To understand what personal
information the processor collects and stores, please refer to the respective
processor's terms and privacy policy. Therefore, except for the limited
exception above, we do not know any means or source of user's detailed payment
for VPN services (including any credit card or bank account number) or any billing
records either.
If you contact us directly, we may receive additional information
about you such as your name, email address, phone number, the contents of the
message and/or attachments you may send us, and any other information you may
choose to provide. We may also receive a confirmation when you open an email
from us.
Autumn Breeze uses your email address (if any depending on your
choice) for the following reasons:
Autumn Breeze uses your personal information only for the purposes
listed in this Privacy Policy, and we don't sell your personal
information to third parties without your prior consent.
2.
SERVICE INFORMATION RELATED TO YOUR VPN USAGE
Subject to applicable laws and for the avoidance to infringe any
internet service provider, any browsing information, traffic destination, data
content, IP addresses, DNS queries or other similar information relating to
your online activities transmitted by you to our servers is encrypted and
cleared after the VPN "session" is closed. That said, we
don't collect any information regarding the websites you
visit or any data stored on or transmitted from your device, including
any data that applications on your device may transmit through the VPN network. More specifically,
Autumn Breeze has NO
documents/information below under the situations of the limited connecting with
your personal information and the non-collection of the
websites you visit or any data stored on or transmitted from your device:
If anyone would like to access to or try to compel Autumn Breeze
to release user information based on any of the above, we cannot
supply this information because the data don't exist.
For the purpose to fulfill
our contractual obligations in good faith and to make you enjoy excellent VPN
services, we collect the following information related to your VPN usage:
We collect information
related to which Apps and Apps version(s) you have activated. It makes our Support
Team efficiently find out and eliminate technical issues for you.
We collect information about
whether a VPN connection is successful on a particular day (but not a specific
time of the day), to which VPN location (but not your assigned outgoing IP
address), and from which country/ISP (but not your source IP address). The
minimal information allows us to provide efficient technical support to you,
such as identifying connection problems, providing country-specific advice
about how to use our VPN services, and to enable our engineers to identify and
fix network issues.
We collect information
regarding the total sum of data transferred by a given user. It is one of our
service principles to provide unlimited data transfer, however if we notice
that a user occupies more traffic than thousands of others combined, what influence
other users to enjoy high-quality service, we may seek for the reason with the
user.
When you become one of our
users for the VPN services, with your permission, we collect minimal usage
statistics and anonymized analytics data used for network diagnostics in our
network operations tools, for the purpose to optimize network speeds and to let
us identify problems related to specific apps, VPN servers, or ISPs. Learning
and analyzing the statistics allows us to improve the quality of the services
and the products. We ensure the information we receive is fully
anonymized and cannot be tied back to individual users (i.e., we do not
store which user sent which data, and we do not store IP addresses).
We will collect the
following information:
We collect minimal usage
statistics to maintain our quality of service. Although we provide service to
users improving the network speed, we can't uniquely identify any specific
behavior of any user, because thousands of users share one same location simultaneously
to enjoy surfing the internet and the usage pattern overlaps with thousands of
other customers who also connected to the same location on the same day.
Regarding to the sensitive
data, we've engineered our systems to categorically eliminate the storage of
sensitive data. We never know HOW they have utilized our Service.
We stand by our firm
commitment to our customers' privacy by not possessing any data related to a
user's online activities.
3.
THE USE AND SHARING OF INFORMATION
How we use information
We
use the information we collect in various ways, including to:
How we share information
We
may share the information we collect in various ways, including the following:
4.
ADVERTISING
We
do not server any ads for the Premium subscription of our services. As well, we
are proud to offer free, advertising-supported VPN services to the customers.
We work with third-party advertising partners to show ads to the customers who
choose free VPN services.
We
ensure that we do not target any personal information based on these ads.
Although you opt in to use the free, advertising-supported VPN services, we
won't share the advertisers any your personal information or any usage
information without your prior consent.
Notwithstanding
the foregoing, these advertising partners may set and access their own cookies,
pixel tags, and similar technologies on our services, and they may otherwise
collect or have access to information about you which they may collect over
time and across different online services.
To
learn more about these programs, please visit (including but not limited to):
5.
JURISDICTION AND APPLICABLE LAW
Keeping
your information private is our core mission. In service of this mission,
Autumn Breeze's registered place of business is in Singapore, where has
integrated data protection legislation.
There
are no special data retention laws and no guidance pertaining to e-discovery or
disclosure to foreign law enforcement agencies in Singapore. The disclosure of
personal data may follow this Privacy Policy.
Required
by any foreign law enforcement agencies, Autumn Breeze turns over protected
user information only upon receipt of a valid subpoena, court order, or search
warrant, which shall be served effectively under the Rules of Court of
Singapore. More specifically, we think the subpoena, court order or search
warrant may lose its coercive effect when it crosses its boundary. It only
regains coercive effect on the other side of the line either through a
domestication action (in the other state's courts) or under the authority
of a statute. Additionally, we will notify affected users about any requests
for their account information, unless prohibited from doing so by law or court
order. Should we receive a valid served legal order, it is important to
note that Autumn Breeze does not collect any IP addresses, browsing
history, traffic data, or DNS queries that could be used to identify any
specific user.
6.
DATA RETENTION
We
retain personal information we collect from you where we have an ongoing
legitimate business need to do so (for example, to provide you with a service
you have requested or to comply with applicable legal, tax, or accounting
requirements).
When
we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize it or, if this is not possible
(for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it
from any further processing until deletion is possible.
We
keep records of any correspondence, questions, complaints, or compliments you
submit to us, along with our response. Depending on how you contact us, we may
collect your email address and any additional information you provide to us.
Having full correspondence records enables us to provide the best possible
customer support experience.
We
use emails for support correspondence: snapvpn@autumnbreeze.co
When
you correspond with us using these emails, your correspondence records,
including your name and email address, are stored in their systems.
7.
SECURITY MEASURES
Autumn Breeze is committed to protecting your information. We use
best-in-class physical, procedural, and technical security with respect to our
offices and information storage facilities so as to prevent any loss, misuse,
unauthorized access, disclosure, or modification of information. Access to user
information is restricted to staff who require such access to perform their job
functions.
While we believe these systems are robust, it is important to
understand that no data security measures in the world can offer 100%
protection.
Servers are housed in data centers with strong security practices.
None of these data centers require us to collect or store any traffic data or
personal information related to your use of VPN services. If any data center
were to ask us to log such data, we would immediately cease operations with
said data center and find alternative options.
Even if a government were to physically seize one of our VPN
servers and manage to break its disk encryption, there would be no logs or
information that would tie any individual user to a particular event, website,
or behavior.
8.
THIRD-PARTY SERVICES
You may access other third-party services while using the VPN
services, for example by clicking on links to those third-party services from
within the Services. We are not responsible for the privacy policies and/or
practices of these third-party services, and we encourage you to carefully
review their privacy policies.
9
CHILDREN'S PRIVACY
We feel under a particular
obligation to protect information obtained from young children. We would
strongly urge parents to instruct their children never to disclose their real
name, their address or their telephone number while they are on-line without
prior permission. Autumn Breeze does not knowingly collect information from
children under the age of 16, and children under 16 years old are prohibited
from using our services. If you learn that a child has provided us with
personal information in violation of this Privacy Policy, you can alert us
at snapvpn@autumnbreeze.co.
When you become one of our users for the VPN services, you may
access certain information associated with you by emailing snapvpn@autumnbreeze.co.
If you decide not to use our VPN services any more, any public activity on your
Account prior to deletion may remain stored on our servers and may remain
accessible to the public.
To protect your privacy and security, we may also take reasonable
steps to verify your identity before updating or removing your information. The
information you provide us may be archived or stored periodically by us
according to backup processes conducted in the ordinary course of business for
disaster recovery purposes. Your ability to access and correct your information
may be temporarily limited where access and correction could: inhibit our
ability to comply with a legal obligation; inhibit our ability to investigate,
make or defend legal claims; result in disclosure of personal information about
a third party; or result in breach of a contract or disclosure of trade secrets
or other proprietary business information belonging to us or a third party.
11.
GDPR
Autumn Breeze is committed
to user privacy globally, and personal information under users' control and
minimal collection of data are our existing practices. According to the
requirements of the General Data Protection Regulation (GDPR) of the European Union
(EU), we collect and process the data in a specific manner of users in EU
outlined in this Privacy Policy on one of the following bases, depending on the
circumstances:
i) For the
purposes of fulfilling our contractual obligations to users, including:
-
Providing users with the VPN services and Apps they have requested.
-
Managing user subscriptions and processing payments.
-
Providing customer support.
ii) For a
legitimate interest associated with the operation of our business, including:
-
Enhancing the quality, reliability, and effectiveness of our VPN Services, and
Apps.
-
Communicating with customers to provide information and seek feedback related
to our VPN services and Apps.
You can withdraw your
consent at any time. Withdrawing your consent will not affect the
lawfulness of any processing we conducted prior to your withdrawal, nor will it
affect the processing of your personal information conducted in reliance on lawful
processing grounds other than consent.
As well, you have the right
to opt-out of marketing communications we send you at any time. You
can exercise this right by clicking on the "unsubscribe" or
"opt-out" link in the marketing emails we send you.
You can exercise your rights
under the GDPR to access, transfer, correct, delete, or object to the
processing of your personal information by contacting us at snapvpn@autumnbreeze.co.
12.
INTERNATIONAL DATA TRANSFERS
Autumn
Breeze is a global business. We may transfer personal information to countries
other than the country in which the data was originally collected. These
countries may not have the same data protection laws as the country in which
you initially provided the information. When we transfer your personal
information to other countries, we will protect that information as described
in this Privacy Policy.
For
the purpose to consist with applicable privacy laws and principles, this
Privacy Policy may be modified from time to time without prior notice to you,
so please review it frequently. Your continued use of our VPN services
constitutes your acceptance of our Privacy Policy. Changes to this Privacy Policy will be posted
inside our APP. If we materially change the ways in which we use or share
personal information previously collected from you through our VPN services, we
will notify you through our APP, by email, or other communication.
14.
Contacts
If
you have any questions or concerns about this Privacy Policy, please feel free
to contact us at snapvpn@autumnbreeze.co.
Echo
Kwan is the Data Protection Officer ("DPO") for Autumn Breeze, having
been appointed in 2018. If you are not in a position to engage with us by the
above mentioned means, please contact DPO at datasecurityofficer@autumnbreeze.co.