PRIVATE INTERNET ACCESS PRIVACY POLICY

This Website ('PrivateInternetAccess.com'), its owners (collectively, ‘We,’ ‘Us,’ ‘Data Controller’ or 'London Trust Media, Incorporated') and constituents believe that the privacy and security of our visitors and clients information are of utmost importance.

The processing of personal information, such as the e-mail address or payment information of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Private Internet Access. By means of this data protection declaration and privacy policy, we would like to inform the general public of the nature, scope, and purpose of the personal information we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the data controller for personal information, we administer strict policies safeguarding your privacy and security. This document ('Privacy Policy') defines and informs our data subjects of any and all of the instances in which your data and information (collectively, ‘Personal Information') may be saved and how it may be used by London Trust Media, and finally the level of protection we use to safeguard your personal information.

TABLE OF CONTENTS


Personal Information we Collect
Uses of Personal Information Collected by Us
Website Registration
Website Contacts
Disclosure and Use of Personal Information
Data Retention
CalOPPA Statement
Name and Address of Data Protection Officer and Name and Address of Data Controller
Maintaining the Security of Your Personal Information
How We Transfer Information Collected Internationally
COPPA Disclosure
Rights of the Data Subject
Provision of personal information as statutory or contractual requirement
Legal Basis for Data Processing
Changes to this Privacy Policy

PERSONAL INFORMATION WE COLLECT


From Clients of our Service
  • E-mail Address for the purposes of account management and protection from abuse.
  • Payment Data for the purposes of processing payments as required by our third-party payment processors. Note that we do not save your full credit card details.
  • Affiliates who use the control panel will receive a temporary cookie to improve delivery of services.
From the Website and Email
  • Google analytics data (this data is anonymized). Google may also store a cookie with your consent. You may opt out here with Google's plugin.
  • Internationalisation (i18n)
  • Affiliates who opt to use the optional control panel will receive a temporary cookie.
  • Information included in any submissions on the 'Contact Us' page.
  • The email address of any e-mails we receive.

USES OF PERSONAL INFORMATION COLLECTED BY US

  • E-mail address is used to send subscription information, payment confirmations, customer correspondence, and Private Internet Access promotional offers only,
  • Payment data is used to manage client signups, payments, and cancellations,
  • Google analytics data is used to improve our website and delivery of our content,
  • Compliance with valid legal process,
  • Contact submissions and e-mails will be used for correspondence, and
  • Temporary cookies are used to handle control panel logins.
The data controller does not collect or log any traffic or use of its Virtual Private Network ("VPN") or Proxy.

WEBSITE REGISTRATION

The data subject has the option to register on the website of the controller with the indication of personal information. The controller requests email data to be transmitted to the controller by the respective input mask (sign-up form) used for the registration. The personal information entered by the data subject is collected and stored exclusively for internal use by the controller, and for its own purposes.

By registering on the website of the controller, the date and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal information, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal information specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal information are stored about the data subject. In addition, the data controller shall correct or erase personal information at the request or indication of the data subject, insofar as there are no statutory storage obligations. A Data Protection Officer particularly designated in this data protection declaration, as well as the entirety of the controller’s employees are available to the data subject in this respect as contact persons.

WEBSITE CONTACTS

The Private Internet Access website includes information that enables data subjects to contact the controller via electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal information transmitted by the data subject is automatically stored. Such personal information transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal information whatsoever to any third parties.

DISCLOSURE AND USE OF PERSONAL INFORMATION

PrivateInternetAccess.com is a business that strives to protect privacy and the privacy rights of our clients. Although we will comply with all valid subpoena requests, our legal team scrutinizes each and every legal request that we receive for compliance with both the "spirit" and letter of the law. For invalid or overly broad subpoenas, we will often question or attempt to narrow the scope of any subject matter sought. Moreover, when it is possible and a valid option we will provide the user an opportunity to object to any requested disclosures. We cannot provide information that we do not have. PrivateInternetAccess.com will not participate with any request that is unconstitutional.

DATA RETENTION

The data controller retains all account information and data indefinitely unless a data subject requests that their personal information be deleted.

CalOPPA STATEMENT

The State of California requires us to post specific language related to our privacy policy. By default, PrivateInternetAccess does not share your private information with any third parties aside from the disclosures already made in this privacy policy. However, if you wish to inquire into how PrivateInternetAccess does not share our user's private information with third parties for direct marketing purposes, you may contact:

NAME AND ADDRESS OF DATA PROTECTION OFFICER AND NAME AND ADDRESS OF CONTROLLER

Our current data protection officer can be reached at the following information below.

John A. Arsenault
London Trust Media, Incorporated
4643 S Ulster Street
Suite 1120
Denver, CO 80237
United States (347)586-9467 (Ext. 904)
privacy@privateinternetaccess.com

MAINTAINING THE SECURITY OF YOUR PRIVATE INFORMATION

Your private information is safeguarded by privateinternetaccess.com. Only some employees are granted access to the servers and information where private information is maintained. Private information is maintained in an encrypted form.

HOW WE TRANSFER INFORMATION COLLECTED INTERNATIONALLY

We collect information globally and primarily store that information in the United States. If We transfer your information from the United States, We will request your consent.

COPPA DISCLOSURE - About Children’s Online Privacy

The Children’s Online Privacy Protection Act (COPPA) was passed to give parents increased control over what information is collected from their children online and how such information is used. The law applies to websites and services directed to, and which knowingly collect information from, children under the age of 13.  Our online services are not directed to children under the age of 13, nor is information knowingly collected from them.  For additional information on COPPA protections, please see the FTC website at: https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online

RIGHTS OF THE DATA SUBJECT

Right of Confirmation.

Each data subject has the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal information concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

Right of Access.

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal information stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  1. the purposes of the processing;
  2. the categories of personal information concerned;
  3. the recipients or categories of recipients to whom the personal information have been or will be disclosed, in particular recipients in third countries or international organizations;
  4. where possible, the envisaged period for which the personal information will be stored, or, if not possible, the criteria used to determine that period;
  5. the existence of the right to request from the controller rectification or erasure of personal information, or restriction of processing of personal information concerning the data subject, or to object to such processing;
  6. the existence of the right to lodge a complaint with a supervisory authority;
  7. where the personal information are not collected from the data subject, any available information as to their source;
  8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Moreover, the data subject has the right to obtain information as to whether personal information are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.

Right to Rectify.

Each data subject has the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal information concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal information completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, they may, at any time, contact our Data Protection Officer or another employee of the controller.

Right to Erasure.

Each data subject has the right granted by the European legislator to obtain from the controller the erasure of personal information concerning him or her without undue delay, and the controller shall have the obligation to erase personal information without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  1. The personal information are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  2. The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  3. The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  4. The personal information has been unlawfully processed.
  5. The personal information must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  6. The personal information has been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal information stored by the Controller, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of Controller or another employee shall promptly ensure that the erasure request is complied with immediately.

Right of restriction of processing.

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies: The accuracy of the personal information is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal information. The processing is unlawful and the data subject opposes the erasure of the personal information and requests instead the restriction of their use instead. The controller no longer needs the personal information for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims. The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

Right to Portability.

Each data subject shall have the right granted by the European legislator, to receive the personal information concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal information has been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal information transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by Company or another employee.

Right to Object.

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal information concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

This data controller shall no longer process the personal information in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

Right to withdraw data protection consent.

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal information at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may at any time directly contact our Data Protection Officer or another employee of the controller.

Provision of personal information as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal information; possible consequences of failure to provide such data

We clarify that the provision of personal information is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal information, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with some personal information when our company signs a contract with him or her. The non-provision of the personal information would have the consequence that the contract with the data subject could not be concluded. Before personal information is provided by the data subject, in this circumstance the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal information is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal information and the consequences of non-provision of the personal information.

CHANGES TO THIS PRIVACY POLICY

BY USING THIS WEBSITE AND/OR SERVICES, YOU AGREE THAT YOU AS THE DATA SUBJECT CONSENT TO THIS PRIVACY POLICY. YOU AGREE THAT PRIVATEINTERNETACCESS.COM MAY MAKE CHANGES TO THIS PRIVACY POLICY AT ANY TIME WITHOUT ANY GIVEN NOTICE AT ITS DISCRETION.

Last revised May 24th, 2018