Privacy Policy

Last updated: 2024.09.19

We, Blueberry Web Solutions Pvt. Ltd. and its affiliates, are dedicated to safeguarding your privacy. We only collect the minimum amount of data necessary to provide and maintain our services.

This Privacy Policy explains how we collect, use, and protect your information when you use our mobile application, Kivo VPN, available on the Google Play Store and the iOS App Store. Please note that this policy does not cover any data transmitted to or from third-party websites or applications via Kivo VPN.

1. Collection of Data

1.1 Data Not Collected

We do not collect the following data:

  • Personal Identifiers: We do not collect names (including subscriber names, user names, or screen names).
  • Addresses: We do not collect residential or business addresses.
  • Phone Numbers: We do not collect telephone numbers.
  • Payment Information:
    • a. We do not collect or store your payment details, such as credit card numbers, bank account numbers, or billing records.
    • b. Payment processing is handled by third-party processors. If you make a payment to Kivo VPN, you will be redirected to a third-party payment service. Please refer to the respective processor’s terms and privacy policy to understand what data they collect.

Additionally, we do not collect any sensitive data, as our systems are engineered to avoid storing such information. We also do not track your online activities. Specifically, we do not collect:

  • Browsing history
  • Traffic destination
  • Data content
  • DNS queries

Furthermore, we do not collect connection logs, including:

  • Your IP address
  • Your outgoing VPN IP address
  • Connection timestamps
  • Session duration

As we do not collect activity or connection logs, we do not have access to:

  • The websites you visit
  • The time you connected to Kivo VPN
  • Your original or temporarily assigned IP addresses

Data We Collect

We limit data collection strictly to what is necessary to maintain and improve the services provided by Kivo VPN.

1. Data You Provide

We collect only the data you voluntarily provide during your interactions with Kivo VPN. For example, when you register for an account, we may ask for your email address. The amount of data collected depends on your privacy settings.

We use your email to:

  • Communicate with you.
  • Send updates and important announcements.
  • Share marketing information such as offers, surveys, and invitations (you may opt out of these communications at any time).

If you contact us directly, we may receive additional data such as your name, email address, phone number, message content, and any other information you choose to provide.

You can withdraw your consent to our use of your email for the purposes mentioned above.

2. Data Necessary for Service Maintenance

To ensure the quality and functionality of Kivo VPN, we collect certain non-identifiable data, including:

  • App Version Data: We collect information about your version of Kivo VPN to quickly identify and fix any technical issues.
  • VPN Connection Data: We collect abstracted data about your VPN usage, including the success of connections, VPN location, your country, and your internet service provider (ISP). This data does not identify you personally.
  • Data Usage: We track the total amount of data transferred through Kivo VPN to prevent excessive usage that could impact the experience of other users.
  • Anonymous Diagnostic Data: We collect anonymized data for network diagnostics and analysis, such as VPN connection failures, speed test results, and crash reports.

3. Data Usage and Processing

We collect, combine, and process your data for the following purposes:

3.1 Security

To authenticate your use of Kivo VPN, we assign a unique identifier when you register using your email address. This identifier, linked only to your device identification code, helps us verify the level of service you’ve subscribed to before establishing your Kivo VPN connection. We do not use any other data for identity verification.

3.2 System Diagnostics

We use information related to your Kivo VPN activity for internal operations, ensuring the service runs smoothly. This includes tasks such as troubleshooting, data analysis, and monitoring usage trends to enhance the app's performance.

3.3 Customer Support

We use your data to assist with customer support, addressing inquiries and resolving issues. This allows us to monitor and improve our customer service, respond to your feedback, and offer solutions to common problems. We may also communicate with you regarding Kivo VPN updates and for marketing or promotional purposes.

3.4 Research and Development

Your usage data helps us understand how Kivo VPN is used, enabling us to develop new products, services, features, and functionalities to better serve you.

3.5 Service Providers

We work with service providers and third-party vendors who may use data to assist in delivering and promoting Kivo VPN.

4. Sharing and Transfer of Data

We may share and transfer your data in various ways, including the following:

4.1 Aggregated and Anonymous Data

We may share your data with partners in a way that is aggregated or anonymized, ensuring that it cannot be used to identify you personally.

4.2 Referral Program

If you sign up for Kivo VPN through a friend’s referral, we may inform your friend that you have joined Kivo VPN via their referral link.

4.3 Analytics

We share anonymized statistics and analytical data with partners for network diagnostics and performance monitoring purposes.

4.4 Business Transactions

In the event of a potential merger, acquisition, debt financing, sale of assets, or similar transaction, or in the case of insolvency, bankruptcy, or receivership, your data may be disclosed and transferred to the relevant parties involved.

For users who purchase subscriptions, payments are processed by third-party platforms like Google Play or the Apple App Store. We do not collect or store your payment information.

4.5 With Your Consent

We may share your data when you provide explicit consent or specific instructions to do so.

4.6 International Data Transfers

Your data may be processed in countries where our service providers operate. By using our services, you acknowledge and agree to the transfer of your data outside your country of residence, with safeguards in place to protect it during the transfer.

4. Security Measures

We employ strong security protocols to safeguard your data from unauthorized access, collection, use, disclosure, alteration, copying, or disposal. Our computer networks are protected with rigorous control measures, ensuring secure operations. Access to your data by our staff is strictly limited to essential personnel on a need-to-know basis. Additionally, we do not collect or store any traffic or personal data within our data centers.

5. Data Retention

We retain your data only as long as we have a valid business reason to do so, such as fulfilling the service you requested or meeting legal, tax, or accounting obligations. When we no longer have a legitimate need to process your data, we will either delete it or anonymize it. In cases where deletion or anonymization is not possible (for example, if the data is stored in backup archives), we will securely store it and ensure it is isolated from further processing until deletion is possible.

6. Right to be Forgotten

We will delete your data when:

  • It is no longer needed for the purpose for which it was originally collected or processed.
  • You withdraw your consent, and our basis for holding your data is your consent.
  • You object to the processing of your data, and we have no legitimate reason to continue.
  • You object to the use of your data for direct marketing, and we are processing it for that purpose.

7. Third-Party Services

While using Kivo VPN, you may interact with third-party services, such as by clicking on external links within the app. We are not responsible for the privacy policies or practices of these third-party services. We encourage you to review their privacy policies carefully before engaging with them.

8. Advertising

(1) Paid Kivo VPN

For our paid version of Kivo VPN, we do not collaborate with third-party advertising partners. Your data is solely used to provide and enhance our service.

(2) Free Kivo VPN

For our free version of Kivo VPN, we work with third-party advertising partners to help cover the costs of offering our service. However, we do not target ads based on your data, nor do we share or use your personal information for advertising purposes without your explicit consent. Third-party advertisers may use cookies, pixel tags, and similar technologies on our platform, which allows them to collect or access data. They may gather information about you over time and across various online services.

9. Children's Privacy

We encourage parents and guardians to educate their children about online privacy and the importance of not sharing personal information such as names, addresses, or phone numbers without their prior consent.

We define a child as anyone under the age of 13, or under the stricter age limit mandated by their state or country of residence. If we determine that our services are being accessed by a child below the legal age, we reserve the right to block access to our services or restrict the collection of their data, as outlined below.

Users below the legal age in their state or country are subject to the following restrictions:

  • They cannot display their real name or any personal information on Kivo VPN.
  • They cannot access features like chat, leaderboards, forums, or social networks (e.g., Facebook, Game Center).
  • They cannot subscribe to newsletters.
  • They cannot use any feature that reveals their real identity.

For these users, we do not collect or use precise geolocation data, and they will only be shown contextual advertisements, excluding any form of behavioral advertising.

Children may participate in testing our apps or websites with parental consent and/or in the physical presence of their parent or guardian, depending on the local regulations. Parents retain the right to exercise their children’s privacy rights as described in this policy.

10. Orders Compelling the Disclosure of Your Data

We limit our data collection to what is necessary for service delivery. This includes your device identification code and any additional information you voluntarily provide through emails, phone calls, or interactions with Kivo VPN on Google Play or the App Store. We do not collect IP addresses, traffic data, or DNS queries that could be used to identify you.

While we are dedicated to protecting your privacy, we may be required to disclose your data if served with a valid court order enforceable in India, or in response to legal requests from law enforcement agencies. In such cases, we will take steps to ensure that the recipient of your data upholds data protection standards in line with India’s Personal Data Protection Act (PDPA).

11. Access

As a Kivo VPN user, you have the right to request access to your personal data by contacting us at info@kivovpn.com. To safeguard your privacy and security, we may take reasonable measures to verify your identity before processing your request. Upon approval, we will provide you with access to the personal data we hold about you or that is under our control. Additionally, where applicable, we will inform you of how your data has been used or disclosed within the year preceding your request. Please note that we may charge a fee for processing access requests.

12. Correction

If you believe that your personal data held by us contains errors or omissions, you can request a correction by emailing info@kivovpn.com. We will review your request and, if a correction is warranted, make the necessary changes as promptly as possible. We will also forward the corrected data to any organization to which we disclosed your data within the year prior to your request, unless that organization no longer requires the corrected information for legal or business purposes.

To ensure your privacy and security, we may take steps to verify your identity before making any corrections. Please note that your data may be periodically archived or stored as part of our routine backup procedures for disaster recovery purposes.

13. GDPR Compliance

If you are a resident of the European Economic Area (EEA), we encourage you to keep your information updated. You can correct any information you’ve provided by reaching out to us using this form.

You affirm that all information you provide is accurate and pertains solely to you, not any other individual. You have the right to request access to, rectify, or erase your information at any time. Please be aware that third parties, including our data partners, may also control your information. For more details or to opt out of sharing your personal information with third parties, please contact us at info@kivovpn.com.

If you have previously consented to receive direct marketing communications or subscribed to our newsletters, you can unsubscribe using the link provided in each communication.

Keep in mind that the functionality and features of the Kivo VPN services may be affected by your actions. Some information is necessary for us to provide our services. Your actions may lead us to discontinue service provision if the following conditions are met:

  • Modifying mandatory information may hinder our ability to continue offering Kivo VPN services.
  • Requesting limitations on mandatory processing may prevent us from providing Kivo VPN or other services.
  • Withdrawing your consent or requesting deletion of your information will result in us no longer processing your information. However, we will retain it to comply with regulatory or legal obligations, and we may keep an anonymous version of the data for our records.

For specific requests, please email us at info@kivovpn.com.

If you are a parent of a child under 13 years old (or under another applicable age limit) and believe that your child has provided us with incorrect information, please contact us at info@kivovpn.com to request deletion of that information.

To protect your confidentiality, we need to verify your identity. Please provide a copy of an official document for this purpose. This document will be securely destroyed within two months of your request being fulfilled.

Our team will review your request and respond within one month. If further investigation is needed, we will inform you accordingly.

14. CCPA Compliance

Under the California Consumer Privacy Act of 2018 (CCPA), California residents have the right to request information about the personal data we have collected, shared, or sold to third parties in the previous calendar year.

As a California resident, you also have the right to opt out of the sale of your personal information at any time. Please note that we do not sell your personal information in order to provide Kivo VPN or our services outlined in this Privacy Policy. Our partners and service providers may access your personal information solely to deliver services, but they cannot use it for other purposes. Our agreements with these entities are designed to protect your privacy rights.

15. Breach Notification

In the event of a serious data security breach, we will promptly notify the relevant supervisory authority to ensure the effective protection of your personal data.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will notify you by revising the "Effective Date" at the top of this policy. We encourage you to review this policy periodically for any updates.

17. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Republic of India.

18. Contact Us

If you have any questions or concerns regarding this Privacy Policy or our data practices, please contact us at: info@kivovpn.com.