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Last Updated: April 5th, 2020

1. Introduction
This Privacy Policy (“Privacy Policy”) is designed to explain about the data collection practices used by k2vpn, (“Company,” “us,” “our,” and/or “we”) when operating and executing the operation of the k2vpn (the “Product”) and also apply to the website (the “Site”). This Privacy Policy is part of our Terms of Services available at http://www.k2vpn.io/terms : (the “Eula”), which incorporate this Privacy Policy by reference, and it applies to end users who install the Product and use the K2VPN Mac VPN free services (the “Services”) . If you are not the end user of the Product or Services (as defined under the Eula), you must reflect this Privacy Policy to your end users and ensure their consent to the terms.

2. Our disclosure
and your consent Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. BY INSTALLING OR USING THIS PROCUT, YOU AGREE TO THIS PRIVACY POLICY. If you do not agree with our policies and practices, your choice is not to install and NOT TO use the Product. We evaluate our privacy policies and procedures to implement improvements and refinements from time to time.

3. Minors
This Product is not intended for children under 13 years of age. No one under age 13 may provide any personal information by using the Product. We do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the email address in the last paragraph below.

4. Learn about your Data
Type of Information, Collection and Uses.
In order to enable you to use various services of the Product and constantly improve and upgrade it, we may use certain end user’s information (including cookies and local storage). The following is an explanation on end user’s information, and what type of information we use.
About Non-Personal Information:
Non-Personal Information means, information that alone cannot identify you, including data we receive and/or extract from your device upon installation and operation of the Product. At all time, we make sure to extract and store the data in an anonymous and aggregative manner. When operating the Product and executing the Services, we collect non personal information of end users that includes the following: operating system type and version, installed browsers type and versions, language, timestamp of installations and, traffic data, location data, logs and other communication data and the resources that you access and use on the Product. We may also retain information pertaining to the operation of the Product and delivery of Services (including the installation process) such as: success and failure, duration of installation, malfunctions, errors, and bugs. The installation information is used to provide, maintain and improve the operation of the Product and Services.
About Personal Information:
means information about you that specifically identifies you or, when combined with other information, can be used to identify you. We do not collect any other personal information that can identify you, unless you voluntary provide to us in order to contact you. We also collect the device IP address that is allocated by the Internet service provider to identify the country and language; In some jurisdictions and given specific circumstances, IP address may be considered to be personal information when used with other information in an attempt to individually identify users. However, we make no such use in the data we collect, and we make no attempt or effort to personally identify any user.
How do we use your data? do we disclose your information?
Any information that we collect or receive about you may be used by us for the following purposes:
• To monetize our Product; to provide you with customer support and respond to inquiries; to perform market research or measure Product usage; to analyze traffic counts, your interests and Site performance; to contact you in case you directly contacted us;
• To protect our rights and the rights of our users; to protect or defend our legal rights or property or the legal rights or property of any of our vendors, partners or affiliates, or any of their employees, agents and contractors (including enforcement of agreements); to protect the safety and security of individuals; to protect against fraud or for risk management purposes; or comply with the law, subpoena or other legal process or requirement.
• We may also use and share aggregated, anonymous data about the use of our Site and related activity, and such data is not subject to this Privacy Policy. We only disclose or share your non-public personal information with third parties when we believe doing so is permitted by you and/or authorized by this Privacy Policy.
• To provide relevant content , advertising and offers when using our Website
About Cookies and tracking methodsWe do not use cookies and similar tracking technologies to access user personal data. However, we may work with third party including advertising networks and advertisers (“Third Party”), who help deliver ads to you. As noted above, these third party and advertisers may also use cookies and other technologies to collect and track user data such as demographic information, location, interests, affiliations, website usage, e-commerce, and other online activity to assist them in delivering advertising and content that is more relevant to your interests. They may also supplement data from other sources to help deliver more relevant ads.
WE ENCOURAGE YOU NOT TO PROVIDE ANY PERSONAL INFORMATION OR ACCESS ANY THIRD PARTY CONTENT UNLESS YOU KNOW AND ARE COMFORTABLE WITH ITS PROVIDER.
opt out of cookies:
If you would like more information about this practice and to know your choices about not having this information used by these companies, click here (http://www.networkadvertising.org/managing/opt_out.asp)
Nothing herein shall deem to imply an affiliation between us and any third parties. You may choose to set Your browser to refuse cookies, or to alert you when cookies are being sent.

5. Third Party content (“Third Party Content”)
Please be notified that in this Privacy Notice, the definition of Product and Services does not include any Third Party’s content that is displayed to you on our site, including but not limited to, search results, any content advertisements, links to third party websites that are controlled and maintained by others, promotions, offers, other materials (the “Content”); these are governed respectively by the Site’s such Third Party’s Privacy Policy and End user License Agreement.
You are knowingly and voluntarily assuming all risks of accepting and/or using Third Party Content and you agree that we shall have no liability whatsoever with respect to such Third Party Content or service and/or your usage of them.

6. Changes to This Privacy Policy
The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Site and this privacy policy to check for any changes. Your continued use of this Site, the Product and the Services after we make changes, is deemed to be acceptance of those changes, so please check the policy periodically for updates.

7. How to Contact Us
If you have any questions or comments concerning this Privacy Policy, you are welcome to send us an e-mail at: contact@k2vpn.io and we will make an effort to reply within a reasonable timeframe. You may also send us mail to Raynolds Ave #116, 1051 1340, Irvine, California. Zip code 92614.

Last Updated: June 24th, 2020

1. Introduction
This Privacy Policy (“Privacy Policy”) is designed to explain about the data collection practices used while k2vpn, (“Company,” “us,” “our,” and/or “we”) execute the operation of the K2VPN for IOS environment (the “Product”). This Privacy Policy is part of our Terms of Services available at http://www.k2vpn.io/terms : (the “Eula”), which incorporate this Privacy Policy by reference, and it applies to end users who purchase and install the Product via the App Store and use the K2VPN IOS VPN services (the “Services”). If you are not the end user of the Product or Services (as defined under the Eula), you must reflect this Privacy Policy to your end users and ensure their consent to the terms.

2. Our disclosure and your consent
By this Privacy Policy, you will be able to considerably comprehend what is a user information, whether and how your information is access and treated while using our Product , by us and by 3rd party service providers. Please read this policy carefully.
BY INSTALLING OR USING THIS PROCUT, YOU AGREE TO THIS PRIVACY POLICY. If you do not agree with our policies and practices, your choice is not to install and NOT TO use the Product.
We evaluate our privacy policies and procedures to implement improvements and refinements from time to time.

3. Minors
We comply with Children’s Online Privacy Act (COPPA) thus accordingly, this Product is not intended for children under 13 years of age, unless an expressed parental consent has been given. No one under age 13 may provide any personal information by using the Product. We do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the email address in the last paragraph below.

4. Third Party Services
The Product uses and embed 3rd party’s technologies, features and services which are required to enhance advanced feature , strength our application development capabilities, improve the Product and our services (the “3rd service providers”). Such 3rd Parties’ respective terms of service, Privacy and other policies (referred to you hereinunder) govern your use of the Product and our Services.
Third Party’s services relevant to our product: App Store, Appsflyer and firebase as detailed below.
App Store Policies
Our product is being offered to you via the App store. Please carefully read the App Store Policies, as your choice to Purchase the product, download and Install the Product is also subject to App Store Policies.
App Store Policies and links:
Privacy Policy: https://www.apple.com/legal/privacy/
Terms of use: https://www.apple.com/legal/internet-services/terms/site.html (also refer you to additional policies)
Sales and Refunds Policy: https://www.apple.com/shop/browse/open/salespolicies
Other Third-Party services integrated within the Product:
Appsflyer
is a SaaS mobile analytics and attribution platform provide us with enhanced capabilities for better analytics, reports, transactions tracking, fraud detections and other useful services. Appsflyer privacy practices are available at: https://www.appsflyer.com/services-privacy-policy/, https://www.appsflyer.com/product/gdpr-ccpa, https://www.appsflyer.com/cookie-policy
Firebase
is a Google development tool for mobile platform, used by our Product’s developers as a complementary development tool and platform. Firebase’s privacy practices available at https://firebase.google.com/support/privacy.

5. Learn about your Data
Type of Information, Collection and Uses.
In order to enable you to use various services of the Product and constantly improve and upgrade it, we and 3rd service providers, may access certain end user’s information (including cookies and local storage). The following is an explanation on end user’s information, and what type of information is accessed if any.
About Non-Personal Information:
Non-Personal Information means, information that alone cannot identify you, including data received and/or extracted from your device upon installation and operation of the Product.
Non-personal information with respect to your use of the Product includes: operating system type and version, installed browsers type and versions, language, timestamp of installations, aggregated data, analytics and statistics information, traffic data, location data, logs and other communication data, information pertaining to the operation of the Product and delivery of services (including the installation process) such as: success and failure, duration of installation, malfunctions, errors, and bugs. The installation information is used to provide, maintain and improve the operation of the Product and our services. At all time, we make sure to extract and store the data in an anonymous and aggregative manner.
About Personal Information:
means information about you that specifically identifies you or, when combined with other information, can be used to identify you. We do not collect any other personal information that can identify you, unless you voluntary provide to us in order to contact you. Nevertheless, 3rd service providers may access some personal information data used solely to provide their services as detailed under their respective policies linked to your review above. We make no attempt or effort to personally identify any user.
About Cookies and tracking methods
We do not use cookies and similar tracking technologies to access user personal data. However, 3rd service providers as noted above, may also use cookies and other technologies to collect and track user data required to assist them provide their services.
we encourage you not to provide any personal information or access any third party content unless you know and are comfortable with its provider.
opt out of cookies:
If you would like more information about this practice and to know your choices about not having this information used by these companies, click here (http://www.networkadvertising.org/managing/opt_out.asp)
Nothing herein shall deem to imply an affiliation between us and any third parties.
You may choose to set Your browser to refuse cookies, or to alert you when cookies are being sent.

6. Changes to This Privacy Policy
The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Site and this privacy policy to check for any changes. Your continued use of this Site, the Product and the Services after we make changes, is deemed to be acceptance of those changes, so please check the policy periodically for updates.

7. How to Contact Us
If you have any questions or comments concerning this Privacy Policy, you are welcome to send us an e-mail at: contact@k2vpn.io and we will make an effort to reply within a reasonable timeframe. You may also send us mail to Raynolds Ave #116, 1051 1340, Irvine, California. Zip code 92614.

Last Updated: July 5th, 2020

1. Introduction
This Privacy Policy (this “Policy”) is designed to explain to our users about the data practices used by k2vpn, (“Company”, “we”, “us” or “our”) with respect to its software, application, browser extension and hosting websites (respectively, the “Product” and “Site”). This Policy, together with the Product’s Terms of Service and license agreement (available at http://www.k2vpn.io/terms), is considered a binding agreement between you, a consumer of our Product or a visitor of the Site (“you” or “User”) and us.

Please be aware, we may adjust or change this Policy when we introduce a new feature, functionality, product, or when the market in which we operate introduces new regulation. When the changes are materials, we will make sure to post a notice on the Product’s hosting website and/or the Site, otherwise, the change will be reflected in the “last updated” statement and will be effective as of that date.

We know that long legal documents can be tiring sometimes, so we made an effort to write this Policy in a straightforward language, and to provide you with the following summary. The summary is designed to help you understand our data practices, however, cannot replace or prevail the full version of this Policy.

• We use and collect only data we need for the Product’s functionality and Product’s monetization. All of which functionalities are transparently provided to you via the Site or installation flow.
• We do not collect personally identifiable information, however, certain countries (jurisdictions) define certain types of data as “personal”. This could include your IP address and certain online technologies like cookies. When we use such data, we use it in a manner that keeps your anonymity and we make no effort to personally identify you.
• The nature of the Product requires certain accessing permissions that include transmission of your web traffic via our proxy servers. We are aware of the sensitivity and do not take it lightly. We make sure to secure any connection you make via your browser with our servers.
• We do not share your data with third parties unless it is required to provide the Product, the monetization (such as search vendors for example), related services and to dully process or store the data for these purposes.
• If you become aware of any data or privacy concerns, please reach out to our data protection officer at privacy@k2vpn.com

2. Our disclosure and your consent
By installing the Product, visiting the Site, or otherwise using the Services, We take it as if you agree to this Policy and the practices described in it. When the data involved in an action you make is likely to become sensitive, or trigger sensitivity, we will make sure to make a due disclosure in addition to this Policy. However, all the practices are described below and do not involve any special sensitivity.
Please read this policy carefully to understand our policies and practices regarding your information and how we treat them.
If you do not agree with our policies and practices, your choice is to not install and to not use the Product, or, in some cases, you can adjust your browser’s settings to refuse certain types of data collection, as described in this Policy.

3. Minors
The Site and Product are not intended for children under 16 years of age. If you are a minor in your country of residence, please do not access the Site and do not install the Product or otherwise use it.
We do not knowingly collect personal information about minors. If we learn that we have collected or received personal information about a minor without verification of parental consent, we will delete such information. If you believe we might have any information from or about a minor, please contact us at privacy@k2vpn.com.

4. Data we collect and why
When we operate the Site or provide the Product’s functionalities, we access and use certain data that is being sent automatically from your browser to our servers and allow us to enable the functionalities and services, so as to monetize the free Product. Although some jurisdictions define a browser’s data as personal data, we make no use of your data to personally identify you.

4.2 Type of information we collect and use
In order to operate the Product’s functionality, to provide the Services, to perform the Testing and Improvements, to enable the Monetization and for Performance Tracking (all as defined and described below), we collect, process and use the following data categories:

Data you submit with us
The Product and Services do not require you to submit any data with us, and such data may find their way to us only when you actively contact us via email or any other channel we may make available from time to time. In this case, we will use the data you have submitted only for the purposes of addressing your inquiry or reason of contacting, including when you reach out to exercise your User’s rights.

Data we collect automatically from your local storage or when the Services are enabled:

Category Data Items Purpose How Long
Identifiers An online identifier that the system randomly generates for you; your Internet Protocol (IP) address, 1. Knowing how many users the Product has
2. The IP address is used for two main purposes:
3.1 When the VPN is activated, we mask your current IP address with a new one we generate for you (VPN’s core functionality).
3.2 We extract the country from which you use the VPN for purposes of the monetization, i.e. display of search results to your queries based on the country from which you browse (whether real country or the country you chose to browse from when you activated the VPN functionality).
3.3 Upon your consent when you first browse the Site, we may display to you your current IP and country on the homepage.
Online identifier - so long as you have the Product installed on your browser.
IP address - we do not retain it in our servers, but only access to your local storage upon need, and we do extract the country for purposes of providing the VPN functionality (even if the country is the one you have chosen); we retain the country for the length of the session.
Local Storage and Online Activity Search queries you submit via your address bar; your interaction with elements on the Site or Product (such as buttons clicks) 1. When you submit a search query or a URL in your browser’s address bar we check if you hit “k2+tab” to activate your VPN functionality
2. User’s interaction: to respond with the relevant request, to understand engagement, and to extract statistics of visiting our Site or Installing the Product.
3. Search queries are provided to our search vendors that, in response, provide you with search results in their own proprietary search result page.
User’s interaction and activities in the Site or Product - as described in our Cookie Policy, as per each cookie and tag’s type (range between 24 hours to one year);
Search Query - range between the single search session you trigger to 45 days for measurement and calculation purposes with our search partners.
Marketing and Product’s Advertising Referrer URL, cookie IDs When we advertise the Product or Site, we do so with Google and Bing search. In which case we check which source “sent” you to our Site for measurement and calculation. As per each cookie and tag’s type (range between 24 hours to one year);
Geolocation - not verified Country (extracted from IP address) We do not compare or verify this data and we use it for the following purposes:
1. Understand the countries from which our users access the Product and Site.
2. Ability to adjust content to country/language, for example, when we provide search results to your search queries.
3. Over time we might use it to block access to IP addresses that are associated with fraud or non-human access.
We do not retain in our servers, however, access to your local storage upon need and necessity.

Third party sources:
We do not get personal data about you for third party sources, however, we might access certain browser’s functionality via the browser’s permission and we might use a third party API to extract your country from your IP address.

That’s how we use your data
We have four main necessities and purposes for the data we collect:
• Providing the Product’s functionalities, installation process, facilitating the Product’s activation and deactivation functionalities, and to ensure it delivers the promised functionalities (each, or collectively, the “Services”).
• Testing and improving features and functionalities. Meaning, we would like to introduce updates, upgrades and improvements, whether performance and compatibility or new features and functionalities (“Testing and Improvements”). This, at times, requires the use of certain usage data.
• Monetization of the Product. Meaning, we would like to keep providing our products (and the Product), free of charge for our users, so we charge third party advertisers in order to monetize the product (“Monetization”). That is, simply because we know that is how the internet works, and it helps us with financing the operation of producing new and free products for you.
• Statistics and performance analytics. We track certain web data to better extract statistics and analytics of the engagement with Product and the Site, including visits, installations, connecting and disconnecting, engagement with monetization and so forth. This is highly standard across the web, and we are just stating the obvious here (“Performance”). This category may also include the processing of data over time to extract statistics and aggregations of data.
4.3. Cookies and web tracking technologies
When you use the Site, or any other site that hosts the Product and is operated by us, we may store cookies on your computer in order to facilitate and customize your use of our Site. A cookie is a small data text file, which a website stores on your computer's hard drive, that, if your browser is set to accept cookies.
Be aware, that accepting cookies is subject to your own choice, meaning, you can reset your browser to refuse cookies, or periodically delete the cookies that are stored in your browser. Doing so, however, might dilute your online experience, as it might cause certain features in the Site to not function properly.

5. Lawful basis and consent
This section 5, is applicable to you if you are a resident of the European Union (EU), European Economic Area (EEA) or United Kingdom (UK), and intended to demonstrate a lawful basis for our data collection and processing practices:
• The lawful basis for processing any data that is essential for the functionality of the Product, Site or Services is legitimate interest, and your consent via this Policy, on top of that, when such data is classified as personal. This includes all the data categories under Services, Testing and Improvements and Performance.
• When the data is being processed for Monetization purposes, the lawful basis is consent, and we make sure to accept this consent in the installation flow, first when you choose to install the Product, and second, in the Web-store listing page.
• Additionally, you have the choice to disable the Product and cease any data processing, to refuse web-technologies and to withdraw your consent to any personal data processing activities.

6. Data sharing
We do not share your data, sale it or trade it, and any exchange of data with third parties, that some jurisdiction might qualify as a data sharing, are made as follows:
• Service Providers: With third party service providers that help us with providing certain features, tools, storage security and any other feature or service required for the Services, and is out-sourced to third parties. In that case, they receive access to the data needed for their services, and for the limited time required, to provide such service. For example, we use Amazon Web Services (AWS) for storage, processing and securing data.
• Web Performance Tools: Third party tags and online trackers that help us understand the way visitors of the Site and users of the Product engage with it. In this category we include Google Analytics and similar tools that collect online data that is required for Performance understanding.
• Legal Obligation: Based on a legal requirement, or exercising your rights, if and where applicable. Similarly, if we are forced to share, in light of a court order or legislative requirement.
• Product’s Advertising: When we want to advertise the Product and Services to potential customers and users, we engage with digital media companies such as Google, Bing and Facebook, that send users to our Site. In this case, the only exchange of information would be your online identifier in their systems for measurement and calculation purposes.
• Monetization: we partner with search partners who provide search results to your search query. so when you enter a search query in your address bar, you will receive their search result page, which is operated by them and subject to their own privacy policies and data collection practices. In that case and for the time being our search partner is Bing.com, and the only data sharing we engage is transmission of that search query and the country from which it is being sent (whether your true country or the masked one when you search via the VPN functionalities).

7. Users Rights and Choices
Subject to your residency, and our will to provide the Services and Product in such jurisdiction, you may be eligible for the following rights:
• If you are a resident of the EU, EEA or UK, the following rights may apply specifically apply to processing of your personal information (subject to certain exemptions): (1) Right to access your data, if existed in our systems; (2) right to receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format; (3) Request rectification of your personal information that is in our control; (4) Request erasure of your personal information; (5) Object to the processing of personal information by us; (6) Request to restrict processing of your personal information by us; (7) Lodge a complaint with a supervisory authority in case relevant and applicable.
• If you are a resident of California, in certain cases, some or all of the following rights may apply to you: (1) Right to know the categories of personal data we collect about you, and categories of sources, as described in this Policy; (2) Right to access a personal data collected about you; (3) Right to request deletion of the personal data stored about you.
• Please note that due to the fact that we do not collect or retain personally identifiable information, our only way to validate and address your requests concerning privacy rights are if you provide us with a web identifier, such as cookie ID or IP address that is associated with one of your uses (which again, depending on your usage, is being masked by the product as part of its core features).
• Please note that these rights are not absolute, and may be subject to exemptions as described in the applicable legislation, and to our ability to verify your request.
• At the time being, in order to exercise any of your rights, please contact us at: privacy@k2vpn.com and indicate in the subject matter whether your request is based on the EU GDPR (the EU General Data Protection Regulation) or CCPA (the California Consumer Privacy Act). When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or addressing your request.

8. International Transfer of Data
• We may transfer your Information (including Personal Information) outside the country in which it is collected or in which you reside, including to a country that may not offer the same level of protection for Personal Information as of the country in which you reside. However, in which case we make sure to place all contractual safeguards to ensure your Information is processed in a way that offers an adequate level of protection when it is shared between or among our third-party vendors. If applicable to your type of consuming the Services, by providing Personal Information and using the Services, you expressly consent to the use of such information in accordance with this Privacy Policy and to the transfer of your information to another country.
• Our data storage services and servers are in the United State and provided by AWS. When the data is transmitted, we make sure it is encrypted and safeguarded in transmission.

9. Data Security
When designing the Product, we were mindful of principles and standards of data security and data protection. We make our best efforts to secure your data, the Product and the transmission of traffic. We also use 3rd party data hosting services like AWS that assist with encrypting, anonymize and secure personal data, and do our best to apply physical, logical and technical data security measures. Of course, incidents happen, and nothing could be 100% secure on the web at all times.
Please be responsible and use the Product in a manner that does not allow your privacy to be evaded, or your data to be secured.

10. Changes to This Privacy Policy
We may change or adjust this Policy from time to time at our sole need, discretion and when we introduce a new feature, product or to address new legislation. The “last updated'' label will always reflect the last version, and we highly encourage you to regularly advise this Policy to better learn about our data practices.
When a change we make is classified as “material” we will post an update in the Site, and such changes will become effective within 7 days following such first post. Otherwise, any change will become immediately effective and your continued use of the Product and Site will constitute your consent to such changes.

12. Contacting Us
If you have any questions or comments concerning this Privacy Policy, you are welcome to send us an e-mail at: contact@k2vpn.io and we will make an effort to reply within a reasonable timeframe. You may also send us mail to Raynolds Ave #116, 1051 1340, Irvine, California. Zip code 92614.