Privacy Policy
Effective Date:
April 30, 2025
This
Privacy Policy explains how VPN Master (“Snap Master VPN”, “we,” “us”)
collects, uses, shares, and protects your information when you access our
websites, VPN Master or Snap Master VPN applications（the “Apps”）, and all related services (collectively,
the “Services”).
The Services are operated by SECUREGUARD
GROUP PTE. LTD. (the “Company”, “VPN Master”, “Snap Master VPN”, “we”,
“our”, “us”), domiciled
at 36 ROBINSON ROAD #21-01 CITY HOUSE SINGAPORE (068877). It is
therefore governed by and construed in
accordance with the laws of the Republic of Singapore, excluding its conflicts
of law principles.
This policy, together with our Terms of
Service, forms a binding legal agreement between you and us. By using our
Services, you acknowledge and agree to this Privacy Policy.
Commitment to User Privacy and No-Log Policy
We operate under a strict no-log policy. VPN
Master never collects, stores, or logs browsing activity, VPN traffic content,
destination websites, DNS queries, or connection metadata. We only collect the
minimal data necessary to operate and improve the Services, perform essential
account management, process Subscriptions, handle customer support, and ensure
system security. All such data is strictly segregated and cannot be linked to
VPN usage. Our privacy management controls and system architecture are subject
to regular internal review, reflecting our core values of user trust and
security.
Information Collected
We limit the data collection to what is maintain
the quality and functionality of our Services.
Anonymous Usage
Data: We may collect anonymized technical
data such as connection success/failure,
country, device type, operating system version, and general error logs solely
for the improvement of network reliability and troubleshooting. Such data is
never identifiable to any user, cannot be cross-referenced, and is irreversibly
anonymized at collection.
Account Registration Data: To
create an account, an email address and password are required. This helps you
manage access, Subscriptions, password recovery, and support requests.
Subscription and Payment Data: For Premium
services, we keep records of your Subscription plan, status, email, transaction
ID, auto-renewal status, and payment channel. We do not store any credit card
or sensitive payment information. Payment processing is handled by
PCI-compliant third-party providers.
Customer
Support Data: We may store
data you provide when contacting customer support, such as your correspondence,
contact details, and any voluntarily submitted information, exclusively to
respond to your inquiries.
Purposes of Data Processing
We process your data to:
•
Provide,
operate, and maintain our Services;
•
Manage
Subscriptions, process transactions, and authenticate your account;
•
Respond to
inquiries, resolve issues, and offer customer support;
•
Perform
diagnostics, monitor service quality and security, and improve our Services;
•
Comply with
applicable laws, prevent fraud, and resolve potential disputes;
•
Send essential
service notifications or, with your consent, marketing communications.
We never use your information for behavioral
profiling and do not sell or share personal data with third parties for
independent marketing.
Third-Party Providers
To ensure optimal functionality, diagnostics,
customer support, security, analytics, advertising (for free basic services),
and global payment options, VPN Master integrates with select third-party
service providers. Some of the key partners include:
•
Firebase by Google: For
crash reporting and diagnostics to improve app reliability and performance.
•
Adjust: To
measure advertising performance and optimize user acquisition strategies.
•
Admob by Google, Liftoff, InMobi, Unity: For
advertising and attribution in the provision of free service offerings,
supporting our no-charge user options.
•
Stripe, Payssion, Paddle: For the secure processing of payments in
Premium services.
These partners may collect or process limited
technical or transactional data as necessary to perform their designated
functions, using cookies, tags, or similar technologies. All third-party
processing is governed by strict data protection agreements that prohibit the
identification, profiling, or tracking of users’ VPN activity or personal usage
data. Additionally, all data sharing is conducted in accordance with this
Privacy Policy and applicable laws; usage and analytics data are never combined
with VPN logs, traffic, or user account details.
We encourage you to review the privacy policies
of these third-party providers for details about their data handling and
retention practices. Our partnerships are regularly reviewed to ensure strict
compliance with our privacy standards and commitment to user confidentiality.
Data Sharing and Transfer Practices
We only
share information in the following situations:
•
With Service
Providers: We work with trusted third-party
providers for analytics, payment, advertising (for free basic services),
security, diagnostics, and customer support. All third-party processing is
limited to what is necessary and contractually restricted from correlating
information to your VPN activity or account.
•
Business
Transfers: If VPN Master undergoes a merger,
acquisition, or asset transfer, your information will remain protected
according to this Policy.
•
Cross-Border
Transfers: Your information may be processed or
stored in jurisdictions other than your country of residence. Such transfers
are protected by appropriate safeguards or standard contractual clauses as
required by law.
•
Legal
Obligations: Data may be disclosed where required
by law or to address lawful government or regulatory requests. We will always
seek to limit disclosure to what is lawfully demanded.
•
With Your
Consent: No information is shared outside these
contexts unless you have provided explicit, informed consent.
Data Protection Measures
We use a comprehensive set of technical,
administrative, and organizational safeguards to protect your personal
information from unauthorized access, loss, or misuse:
•
Access
controls restrict personal data to authorized personnel only, with monitoring
and audit trails.
•
Data
segregation mechanisms ensure that account, diagnostic, analytics, payment, and
VPN data remain logically and physically separated, preventing any
cross-linking.
•
Encryption
protocols protect data in transit and, where appropriate, at rest.
•
We conduct
regular internal reviews to test and improve system defenses.
•
Our incident
response plan ensures prompt investigation of security events and regulatory
notification if required.
VPN Master’s approach to data protection is
based on transparency, user empowerment, and strong foundational security, in
line with leading international privacy standards.
Your Choices and Rights
VPN Master supports your ability to control
your personal information in accordance with applicable law:
•
Access: You can request details about any personal
data we hold related to you.
•
Correction: You have the right to request correction of
any incorrect or incomplete information.
•
Deletion: Subject to statutory or contractual
obligations, you may request deletion of your account and all related data.
Once deleted, this data cannot be restored.
•
Restriction
and Objection: You may
restrict or object to certain processing of your data, for example, opting out
of optional communications or objecting to uses based on legitimate interests.
•
Consent
Withdrawal: For any activities based on your
consent (such as marketing), you may withdraw at any time without affecting
prior processing.
•
Complaints: You are entitled to raise privacy-related
concerns or complaints with us at any time, or with your local data protection
authority.
Data Retention and Deletion
We retain personal data only as long as
necessary for the purposes it was collected—such as providing Services,
complying with legal obligations, ensuring security, or resolving disputes.
Once data is no longer needed, it is securely
deleted, irreversibly anonymized, or, if immediate deletion is technically
impossible (such as with backup systems), it is isolated and deleted as soon as
possible.
Data in backups is not processed for
operational purposes and is subject to regular deletion cycles.
When you request deletion of your account and
associated data, we will remove all such information to the extent permitted by
law. If legal obligations require us to retain certain data (for example, for
anti-fraud, financial, or audit requirements), we will inform you of the
retention period and the nature of the information held.
Our retention policies are designed with data
minimization in mind, and we regularly review all practices to ensure data is
not held any longer than necessary.
Region-Specific Privacy Notices
For European Economic Area (EEA) and
United Kingdom Users:
In compliance with the EU and UK General Data
Protection Regulation (GDPR), we are required to provide certain details
regarding how we process the personal information of users in the EEA and UK.
If you are a resident of the EEA or UK, you are responsible for ensuring that
any information you submit to us is accurate, up to date, and pertains solely
to you. Should you need to correct or update your information, you may contact
us at any time using this specified communication channel.
You represent and warrant that all information
submitted is truthful and correct, and only relates to yourself as the data
subject.
You have the right to request access to your
data, as well as to request correction (rectification) or deletion (erasure) of
your personal information. Should you wish to exercise these rights, please
contact us via the methods outlined in this policy.
Please note that our data partners or other
third parties may act as independent controllers of your data. If you wish to
receive additional details or opt out of the sharing of your personal
information to these third parties for any purpose, please contact us directly.
If you have previously given consent to receive
direct marketing communications or have subscribed to our newsletters, you may
revoke your consent and unsubscribe at any time using the opt-out link included
in each communication.
Certain information and processing activities
are mandatory for us to deliver the Services. Any request to alter, restrict,
or delete essential data may result in our inability to provide some or all of
the Services to you. Specifically:
•
If you request
to modify mandatory information, this may affect your access to or our
provision of the Services.
•
If you request
a restriction or object to processing required for the operation of the
Services, we may be unable to continue service.
•
If you
withdraw consent or request deletion, we will cease to use or process your
information but may retain it as necessary to comply with regulatory or law
enforcement requirements. We also reserve the right to archive such information
for a commercially reasonable period to ensure data integrity, and to maintain
an anonymized version where appropriate.
•
If you are a
parent or guardian of a child under 13 (or another age as specified by
applicable law) and believe your child has provided us with personal
information, please contact us and we will promptly remove such information
from our systems.
To protect your privacy and security, we may
require verification of your identity before responding to any rights request.
For this purpose, you may be asked to provide a copy of an official
identification document, which will be securely destroyed within two months
after your request is resolved.
Clearly specify the nature of your request when
contacting us. Our team will respond within one month, unless additional time
is needed to investigate or process your request, in which case you will be
informed accordingly.
For California Residents (CCPA):
Under the California Consumer Privacy Act
(CCPA), California residents have the right to request information about the
categories of personal information we have collected and disclosed to third
parties for business or commercial purposes during the preceding calendar year.
You also have the right to opt out of the sale or sharing of your personal
information at any time.
Please note that VPN Master does not sell your
personal information as outlined in this Privacy Policy. Our partners and
service providers may access your information solely to provide Services in
accordance with our agreements; they are prohibited from using your personal
information for any unrelated purposes. All contractual agreements are
carefully structured to ensure the protection of your information and privacy
rights.
Children’s Policy
VPN Master treats the privacy of children with
the utmost importance and is committed to compliance with all applicable child
protection and privacy regulations.
We consider a user to be a child if they are
under the age of 13, unless a different minimum age is specified by applicable
laws and regulations in their country of residence.
Our Services are not directed at children, and
we do not knowingly collect, use, or disclose personal information from
children without the valid consent of a parent or legal guardian. If we become
aware that personal information from a child has been collected without the
appropriate consent, we will take reasonable steps to delete it as soon as
possible.
We proactively implement the following
protective measures for users identified as children:
•
Children are
not permitted to create accounts, access chat, leaderboards, forums, social
networking services, or subscribe to newsletters on our platforms.
•
We prohibit
the collection and usage of precise geolocation data for children and only
deliver contextual (non-behavioral) advertising.
•
Any feature
where a child’s real name or personal information could appear is inaccessible
to users identified as children.
•
Children may
participate in service testing only with explicit parental or guardian consent
and supervision, in accordance with the regulations applicable in their
jurisdiction.
If you are a parent or guardian, you may
exercise rights on behalf of your child as described in this Privacy Policy.
Should you believe that a child has provided us with personal information
without your consent or that of the legal guardian, please contact us
immediately. Upon sufficient verification, we will promptly delete such
information from our records.
VPN Master strongly encourages parents and
guardians to educate children about safe and responsible use of personal
information online.
Changes to Policy
We may periodically update this Privacy Policy
to reflect changes in law, industry standards, or our Services. Updates will be
published on our website with a revised effective date. For significant
changes, we will notify you via the Services or by email if available. Please
review this Policy regularly.
Contact
If you have any questions, concerns, or
complaints about our Privacy Policy, our compliance with applicable laws, how
we handle your information, or if you wish to exercise your privacy rights,
contact:
•
Email: developer@secureguardpro.com
Also, for all privacy-related questions,
requests, or concerns, contact:
•
Data Protection
Officer: Cecilia Fung
•
Email: dpo@secureguardpro.com
We handle all privacy requests in strict
accordance with applicable law and are committed to a timely and transparent
response.