Privacy Policy
Updated on 12.06.2024
General Provisions
1.1 These Rules of storage and processing of confidential data about Users of Galt VPN service (hereinafter referred to as "Rules") are developed and placed by Galt Technologies LLC (hereinafter referred to as "Company"), and determine the order of processing and protection of information of the persons using Galt VPN service (hereinafter referred to as "Service").
1.2 The terms used but not defined in these Rules have the meaning provided in the Rules of Service usage.
1.3 The purpose of these Rules is to ensure proper protection of information about the Users of the Service, including their personal data, from unauthorised access and disclosure.
1.4 The relations related to the processing, including collection, storage, use, as well as protection of the information about the Users are regulated by these Rules and the current legislation of the Republic of Armenia.
1.5 By using the Service, the User agrees to the terms of these Rules. These Rules can be changed and/or amended by the Company unilaterally without any special notification. These Rules are an open and publicly available document. The current version of these Rules is available at galtvpn.com/en-privacy The User is obliged to check the current version of these Rules from time to time for changes and/or additions. Continued use of the Service by the User after the relevant changes and/or additions are made means the User's acceptance and agreement with such changes and/or additions. The User has the right to refuse to accept changes and additions to these Rules, which means the User's refusal to use all the rights previously granted to him/her. If the User does not agree with the terms of these Rules, the use of the Service shall be immediately terminated.
Purpose of processing information about the User
2.1 In order to fulfil the Company's obligations to the User and provide the User with the rights provided for in the Galt VPN Service Terms of Use, including the improvement, development and implementation of new functionalities of the Service, the Company, in accordance with applicable law, collects, stores, uses, transmits, blocks, deletes and destroys the information obtained with respect to the User when using the Service (hereinafter - processing).
2.2 By providing the opportunity to use the Service, the Company, acting reasonably and in good faith, assumes that the User:
2.2.1 has all the necessary rights to use the Service;
2.2.2 provides accurate information about himself/herself in the amounts necessary for the use of the Service;
2.3. the Company does not verify the reliability of the received (collected) information about Users, except when such verification is necessary for the purposes of fulfilment of the Company's obligations to the User. Nevertheless, the Company assumes that the User provides accurate and sufficient information about himself/herself, as well as updates it in a timely manner.
Composition of information about Users
3.1 The composition of information about Users includes:
3.1.1 Information provided by the User for the implementation and use of the functionalities of the Service by the User, including the User's personal page ID in Telegram messenger, email address, Google or Apple ID account data.
3.1.2 Personal Data: User's personal page ID in Telegram messenger, email address, Google or Apple ID account data;
3.1.3 Statistical and other data on how the User interacts with the Service (for example, the number of devices connected for each User, the amount of traffic consumption of the Service).
3.3 In order to fulfil the Service Rules, the Company develops the Service, develops and implements new functionalities, improves them and optimises their quality.To ensure the implementation of these goals, the Company may send the User service mailings using the functionality of the Service (e.g., authorisation messages to the e-mail address; messages to Telegram on behalf of the Service to notify about subscription debits, to receive feedback (e.g., surveys), to inform about the subscription fee, to send the User a message to the Service, to send the User a message about the subscription fee, and to notify the User about the subscription fee.
Principles of Personal Data Processing
4.1 Personal data processing is carried out on the basis of the principles of:
4.1.1 lawfulness of the purposes and methods of personal data processing;
4.1.2. good faith;
4.1.3. compliance of the purposes of personal data processing with the purposes determined in advance and declared at the time of personal data collection, as well as with the Company's authorisation;
4.1.4. compliance of the scope and nature of personal data processed, methods of personal data processing with the purposes of personal data processing;
4.1.5. inadmissibility of combining databases containing personal data created for incompatible purposes.
4.2 Collection of information about the User
4.2.1 The information stipulated in cl. 3.1.1 of these Rules is collected when the User specifies it in the Service. Collection of the User's data provided for in clause. 3.1.2 of these Rules starts to be collected after the User accepts the Rules of using the Service and the Rules of protection of information about the Users of the Service. Collection of other data provided by cl. 3.1.3 of the Rules is collected by the Company in the process of using the Service by the User. In some cases, the collection of other data of the User starts from the moment the User gets access to the Service (for example, at the first launch of the Service).
4.3 Storage of Personal Data
4.3.1 Personal data of Users are stored on the territory of the Russian Federation, with storage being carried out exclusively on electronic media, data are processed using automated systems, except for cases when non-automated processing of personal data is necessary in connection with the fulfilment of legal requirements. Personal data are stored during the validity period of the User Agreement between the User and the Company (until the purposes of their processing are achieved), and after the termination of the Agreement - during the period required and established by the current legislation.
4.4 Transfer of Personal Data
4.4.1 The personal data of Users are not transferred to any third parties, except for the cases expressly provided for by these Rules, the User Agreement of the Service, or with the express consent of the User. Provision of Users' personal data at the request of state authorities (local authorities) is carried out in the manner prescribed by law.
4.5 Termination of personal data processing
4.5.1 When the purpose of personal data processing is achieved (User's cancellation of the agreement), the Company stops processing the User's personal data in one of the ways provided for by law. Achievement of the purpose of personal data processing shall be deemed termination of the contract (User Agreement) between the User and the Company, in particular:
independent deletion of the User's account in the application;
application of the User to the postal address of the Company in accordance with the procedure stipulated in Section 8 of these Rules with a statement of cancellation of the agreement between the User and the Company.
Rights and obligations of Users
5.1 Users have the right:
5.1.1. exercise free free access to information about themselves by viewing data in the Service;
5.1.2 demand from the Company to clarify their personal data, block or destroy them if such data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing and if the Service does not allow the User to delete such information independently;
5.1.3 on the basis of a request to receive information from the Company regarding the processing of his/her personal data.
Measures to protect information about Users
6.1 The Company takes technical and organisational-legal measures in order to ensure protection of the User's personal data from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions.
6.2 Technical security measures are implemented by the Company taking into account the requirements of the legislation of the Republic of Armenia, the current state of the art, the nature of the processed information and the risks associated with its processing.
6.3 Information is processed mainly automatically without access to it by the Company's employees. If such access is granted to the Company's employees, it shall be granted only to the extent necessary for the performance by such persons of their official duties or duties under a contract with the Company, and such persons shall be obliged to comply with security requirements when accessing the information. To protect and ensure the confidentiality of data, all employees/contractors comply with internal policies and procedures regarding the processing of information. These persons shall also comply with all technical and organisational security measures required by applicable law and necessary for the protection of User information.
Limitation of the Rules
7.1 The Company shall not be liable for the actions of third parties who, as a result of using the Application, gained access to information about the User, for the consequences of using information that, due to the nature of the Service, may be available to any User of the Service.
Appeals of Users
8.1 Users have the right to send to the Company their requests, including requests regarding the use of their personal data in writing to the e-mail address support@galtvpn.com.
8.2 A request sent by a User must contain the following information:
8.2.1 number of the main identity document of the User or his/her representative;
8.2.2 information about the date of issuance of the document and the issuing authority;
8.2.3 information confirming the User's participation in relations with the Operator (in particular, the User's personal Telegram page ID, e-mail address, Google or Apple ID account data);
8.2.4 the signature of the User or his/her representative.
8.3 The Company undertakes to consider and respond to the User's request within 30 days from the moment of receipt of the request, unless another term is stipulated by the current legislation of the Republic of Armenia.
8.4 All enquiries received by the Company from Users are classified as restricted information and shall not be disclosed without the written consent of the User. Personal data and other information about the User who sent the enquiry may not be used without the User's special consent except for answering the subject of the enquiry received or in cases stipulated by the legislation.
