Privacy Policy

Updated: Jan 1, 2025

 

This Privacy Policy describes how your data is collected, used, and shared in connection with your use of VPN Master (or Snap Master VPN, depending on your region) applications, websites and relevant services (collectively, "the Services"). The Services are operated by Lemon Clove PTE. LIMITED (the “Company”, “we”, “our”, “us”). It is therefore governed by and construed in accordance with the laws of the Republic of Singapore, excluding its conflicts of law principles. We, Lemon Clove PTE. LIMITED and its affiliates, are committed to protecting your privacy by strictly minimizing the scope of data collection. Only data necessary to maintain our services is collected. Based on this principle, we do not sell, use or disclose any data to third parties for any unrelated purposes.

By accessing or using our websites, applications, and/or services, you acknowledge that you have read, understood, and agreed to be bound by this Privacy Policy. The Privacy Policy does not apply to data that you send and/or receive from third-party websites that you may process through our Services.

Please note that the Privacy Policy and the Terms of Service constitute a binding legal agreement between you and us, so please read them carefully before starting.

 

1.Data Collection

We are committed to minimizing data collection and maintaining user privacy. All data we process is limited to what is strictly necessary for the operation, maintenance, and improvement of the Services.

Anonymous Usage Data

We may collect aggregated and anonymized data solely for the purpose of ensuring the reliability, performance, and security of the Services. Such data may include, but is not limited to:

·      Connection metadata such as timestamps of connection attempts, connection status (success or failure), the VPN server location selected, country-level location and internet service provider (ISP);

·      Device and application diagnostics, including device type, operating system version, VPN protocol used, connection errors, crash reports, and aggregated bandwidth usage;

·      In-app performance metrics such as speed test results or service quality metrics.

This information does not include any data that could identify users individually, and we employ technical and organizational measures to ensure that it remains de-identified and unlinkable to specific user accounts or activity.

Subscription and Payment Data

When you subscribe to our Premium Services, we may collect the following information for the purpose of subscription management, customer support, and compliance with applicable laws:

·      Subscription-related information, including the plan selected, subscription term, amount paid, currency, payment status, auto-renewal status, and anonymized transaction ID;

·      Your email address or other contact information, if voluntarily provided as part of the purchase process;

·      Information provided by the app store, subject to their respective privacy policies.

We do not collect or store any credit card numbers, bank account details, or other sensitive financial data. All payment processing is handled by the respective platform providers through secure and compliant channels.

User Support and Communication Data

If you choose to contact us through customer support or other communication channels (e.g., email, in-app support forms), we may collect:

·      Your name, email address, or other contact information (if provided);

·      The content of your message and any attachments you include;

·      Metadata such as the date and time of your inquiry.

We will use this information solely to respond to your inquiries, provide technical support, and improve the quality of customer service. You may withdraw your consent to our use of this data at any time by contacting us.

We do not collect or log your browsing activity, DNS queries, or the content of any communications transmitted through the VPN. Although we do not collect personally identifiable information (PII) such as names, email addresses, or account credentials, certain third-party SDKs integrated into our app may process information such as your device identifiers (e.g., Android ID) or IP address. While this data may technically be considered indirect identifiers in some jurisdictions, we do not use it to identify you as an individual and do not combine it with other data to attempt re-identification.

 

2.Use of Data

We use and process your data solely for the purposes necessary to operate, maintain, and improve the Services. Specifically:

Service Access and Authentication
We assign a unique identifier linked to your device (without reference to personal data) to determine your service level and enable your connection to the Services. This allows us to authenticate your access and manage your service plan. We do not use any other form of data to verify your identity.

Diagnostics and Performance Monitoring
We process technical and usage data to identify and resolve operational issues, conduct troubleshooting, analyze service performance, and identify usage trends for optimization.

Customer Support
Your data may be used to respond to customer inquiries, investigate concerns, improve support responses, and provide service-related communications. We may also contact you with updates about the Services, subject to your communication preferences.

Research and Service Development
We may use aggregated or anonymized usage data to analyze user interaction and improve or develop new features, services, and performance enhancements.

Third-Party Service Providers
We use third-party service providers for diagnostics, analytics, marketing, and infrastructure support. These providers process limited data as necessary to perform their services on our behalf and in accordance with this Privacy Policy.

 

3.Sharing and Transfer of Data

We do not sell your personal data. We only share or transfer data under the following limited circumstances:

Aggregated and Anonymous Data
We may share non-identifiable, aggregated, or anonymized data with trusted partners for analytics, reporting, or service improvement purposes.

Analytics and Diagnostics
Anonymized diagnostic and usage statistics may be shared with analytics providers for performance monitoring and improvement.

Business Transfers
In the event of a merger, acquisition, reorganization, or similar corporate transaction, your data may be transferred to the relevant successor entity, subject to appropriate data protection safeguards.

International Data Transfers
We may transfer your data to countries where our service providers operate. Where required by law, we implement appropriate safeguards to ensure an adequate level of protection.

With Your Consent
We may share data with third parties only when you have given your explicit consent or provided instructions for such sharing.

 

4.Data Security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, misuse, or alteration. These include but are not limited to:

·      Secure and encrypted transmission protocols.

·      Access controls limiting data exposure to authorized personnel only.

·      Regular security audits and infrastructure monitoring.

We do not collect or store personal browsing activity, traffic content, or connection logs in our data centers.

 

5.Data Retention

We retain data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as applicable legal requirements. Once the data is no longer needed:

·      It will be securely deleted or anonymized.

·      If immediate deletion is not possible (e.g., due to technical limitations backup systems), the data will be isolated from further processing until deletion becomes possible.

 

6.Your Rights

You have the following rights regarding your personal data, subject to applicable law:

Right to Access
You may request access to the personal data we hold about you by emailing us at vpnmaster@lemonclove.net. To protect your privacy, we may require identity verification. We may charge a reasonable fee for access requests, where permitted by law.

Right to Correction
You may request correction of any inaccurate or incomplete data. If we agree the correction is justified, we will update the data promptly and, where applicable, notify any third parties who previously received the incorrect data.

Right to Deletion (“Right to be Forgotten”)
You may request deletion of your data if:

·      It is no longer needed for the original purpose;

·      You withdraw your consent and we rely on consent as the legal basis for processing;

·      You object to the processing and there are no overriding legitimate grounds; or

·      The data is used for direct marketing and you object to that use.

If you wish to delete any information collected through our app, you may do so by contacting us at the support email address listed below. Please note that as we do not store personal account data or user activity logs, such requests will primarily apply to locally stored information or data managed by third-party SDKs, where applicable.

 

7.Data Breach Notification

In the unlikely event of a data breach that results in a risk to your rights and freedoms, we will promptly notify the appropriate supervisory authorities and, where required by law, inform you without undue delay.

 

8.Interactions With Third-Party Services

Our Services may contain links to or integrations with third-party services, platforms, or websites. These third-party services operate independently and are governed by their own privacy policies and terms of use. We do not control and are not responsible for the content, privacy practices, or data processing activities of such third-party services. We encourage you to review the privacy policies of any third-party services you choose to engage with.

Analytics and Performance Monitoring

To maintain and improve the quality, reliability, and security of our Services, we utilize certain third-party tools for analytics and diagnostics purposes, including:

·      Firebase (by Google), which supports crash reporting, in-app performance monitoring, and usage analytics in a de-identified manner.

All analytics data is processed in accordance with applicable privacy laws and is not used to personally identify individual users.

Advertising Partners (Free Version Only)

To support the availability of our free Services, we may display advertising content provided by selected third-party advertising partners. These advertising networks may include, but are not limited to: Admob by Google, Liftoff, InMobi, Unity, Bigo Ads and TradPlus. These partners may use technologies such as cookies, SDKs, and similar tools to deliver contextual advertisements and to measure ad effectiveness.

Please note:

·      We do not share your personal data with third-party advertisers without your explicit consent;

·      We do not use VPN usage data or traffic content for targeted advertising purposes;

·      Any data collected by third-party advertisers is subject to their own privacy policies.

 

9.Country-Specific Provisions

GDPR

If you are a resident of the EEA, we ask that you keep the information that you provide to us updated. You can correct any information you have provided by contacting us through this form.

You represent and warrant that all information you provide us is true and correct, and relates to you and not to any other person.

You can exercise your rights at any time and ask our Services for access to, or rectification or erasure of, your information.

Please note that other third parties (our data partners) may be controllers of your information. You can obtain more details and opt out of the sharing of your personal information to third parties for any purpose by contacting us by emailing vpnmaster@lemonclove.net.

If you have previously consented to any direct marketing communication from us or subscribed to our newsletters, you can unsubscribe by clicking on a link available in each communication and newsletter we send you.

Please note that VPN functionality, services and features can be affected by your actions. Some of your information and its processing is mandatory for our Services to provide the services.

Your actions may force our Services to cease providing the services. When the conditions below apply, it will be reset:

·      If you ask for the modification of this mandatory information, we may not be able to continue to link our Services or our services to you.

·      If you request limitations to processing that are mandatory for our Services, or you object to such processing (in which case, we may not be able to provide you with our Services or our services).

·      If you withdraw your consent or ask for the deletion of your information.

·      If you withdraw your consent or ask for the deletion of your information, we will not use or process your information anymore but we will store it to answer regulatory or police requests. We also reserve the right to retain an archive of such information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such information.

Please specify your request by emailing to vpnmaster@lemonclove.net.

If you are the parent of a child who is under 13 years of age (or under another age specified by applicable regulations) and believe your child has provided us with information, please fill out by emailing vpnmaster@lemonclove.net and we will delete the information from our system.

To preserve the confidentiality of your information, we must be able to correctly identify you. For this reason, please provide us with a copy of an official document to prove your identity. This copy will be safely destroyed within two months of your request being received and closed.

Our team will look into your request and answer you within one month, unless your request requires further investigation. You’ll be specifically informed if that is the case.

CCPA

The California Consumer Privacy Act of 2018 (CCPA) permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has collected, shared with, and/or sold to third parties for a business or commercial purpose during the immediately preceding calendar year.

As a Californian consumer, you also have the right, at any time, to opt out of any type of selling of your personal information.

Please note that we do not sell your personal information to provide our Services or our services described in this Privacy Policy. Our partners and providers who work with us may have access to your personal information in order to provide you with the services within the limits and throughout the duration of our agreement, but they can’t reuse your personal information for any other purposes. Our contracts are strictly drafted to protect your personal information and your privacy rights.

 

10.Children’s Privacy

We encourage parents and guardians to teach their children about privacy and how their information may be used on the Internet. Children should never disclose their name, address or phone number, or any personal information, without their parents’ or guardian's prior permission.

We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their state of residence.

If we consider that any of our services are directed at users under the minimum legal age required in their country of residence, we can block such users from using the services or from providing information and/or limit the collection of information from such users as described below in more detail.

No personal information should be submitted to our Services by users under the minimum legal age required in their state of residence. We apply the following limitations to personal information collection for a user that is not of the minimum legal age required in their state of residence.

Such a user cannot:

·      display their real name or any information in our Services

·      access the chat, leaderboard, forums, SNS (Facebook, Game Center, etc.)

·      subscribe to newsletters

·      use any other feature where users could appear under their real names

With respect to such a user, we will prevent the collection and use of their precise geolocation data and display to them contextual advertising only (excluding any behavioral advertising).

Children can be invited to take part in testing our apps with their parents' or guardians’ authorization and/or their parents' or guardians’ physical presence being required depending on the state where the playtest is conducted.

Parents must exercise their privacy rights for their children provided in this Privacy Policy.

 

11.Changes to Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal, regulatory, or operational requirements, or to reflect updates to the features of the Services. Any material changes will be communicated by posting the revised version within the Services, and where appropriate, by other means in accordance with applicable laws.

Your continued use of the Services following the effective date of any changes constitutes your acknowledgment of the updated Privacy Policy. We encourage you to review this Policy periodically to stay informed about our data practices.

 

12.Contact Information

Our Data Protection Officer ("DPO") is Cecilia Fung. You may contact the DPO at dataprotectionofficer@lemonclove.net. If you have any questions or concerns about this Privacy Policy, you may also contact us at vpnmaster@lemonclove.net.