SpyOFF - Privacy Policy

Last Updatet April 2018

SpyOFF is committed to protecting online privacy. Therefore, we encrypt and anonymize our users’ Internet connection according to military standards. Our entire system has been designed to capture only the bare minimum of data needed to provide a world-class VPN service.

We attach great importance to understanding what information we collect, what information we DO NOT collect, and what use we make of your information.

Data protection is our highest priority. Since there is no data retention in San Marino, we can guarantee our no-log policy. Once a user uses our VPN software, their Internet data is encrypted and their activities become invisible to ISPs, snoopers, and criminals, all thanks to the latest security technologies. Users and their activities shall at no time be monitored, logged, recorded, stored, or shared with third parties while using our software.

What is covered by this Privacy Policy?

This privacy policy applies to all services of Sareta S.r.l., this website (spyoff.com), and the VPN software offered in conjunction therewith. By using this website or this software, you accept this Privacy Policy.

What data is collected by SpyOFF?

Personal data:

When you sign up for SpyOFF, you submit your email address and payment details to us. Depending on the payment method you choose, the name of the account holder, for example, might also be included.

- Why are these data collected?

  • Improvement of service and user experience
  • Fulfillment of the contract between you and us, and / or steps that we carry out at your request to enter into such a contract.
  • Fraud detection & prevention
  • To notify you about our new services or changes to our existing services (users can disable unsolicited emails using the unsubscribe option in emails).
  • To send you technical or service-related messages
  • To enforce the terms of use
  • - Will the data be shared with third parties?

  • Your data will only be disclosed if absolutely necessary for the provision of our VPN service and only for this purpose.

    In order to process your payment, your data will be forwarded to selected payment service providers. Their privacy policies can be found here:

  • Paypal: https://www.paypal.com/de/webapps/mpp/ua/privacy-full
    Bitpay: https://bitpay.com/about/privacy

  • Beyond this, your data will NOT be shared with third parties. We do not share, sell, rent, or exchange your personal information with third parties
  • Anonymized / aggregated data:

    We automatically collect anonymous non-personal information about the following technologies:

    - Website:

    User requests to our support are stored to process and subsequently improve our service, unless a user requests us to delete them.

    Our website uses different types of cookies:

    1.Anonymized and aggregated third-party site statistics, such as Google Analytics and Mixpanel, to improve performance and user experience
    2.Affiliate third-party cookies such as Google Adwords, Facebook, and Bing
    3.Proprietary cookies for the personalization of website content, e.g. for website language or our "bring a friend" scheme

    For more information on each third party, click here:

    https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
    https://www.facebook.com/about/privacy/
    https://privacy.microsoft.com/de-de
    https://mixpanel.com/privacy/
    https://www.zendesk.de/product/zendesk-security/

    You can disable the use of cookies by Google by using Google Advertising’s deactivation page: (https://support.google.com/dfp_premium/answer/2839090?hl=de).
    You can make use of the Google Analytics opt-out: (https://tools.google.com/dlpage/gaoptout?hl=de)
    You can also disable the use of third-party cookies by visiting the opt-out page of the Network Advertising initiative (http://optout.networkadvertising.org/?c=1#!/)

    We recommend that you allow all cookies on the website, as the functionality may otherwise be limited. If you still want to disable cookies, please read the following guide depending on your browser of choice:

    Edge:
    https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies

    FireFox:
    https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen

    Chrome:
    https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=de

    Safari:
    https://support.apple.com/kb/PH21411?locale=de_DE

    - VPN Software:

    Anonymous VPN connection diagnostics and crash reports (can be disabled by the user)

    With your permission, we collect anonymized analysis data for network diagnostics. We use this data in our networking tools to optimize network speed and identify issues with specific apps, VPN servers, or ISPs. The information we receive is completely anonymous and cannot be assigned to individual SpyOFF users (we do not store which user sent which data, nor do we store IP addresses). If you choose to share this information with SpyOFF, we collect the following information:

  • Diagnostic information about the failure of a VPN connection attempt.
  • Speedtest data
  • Crash reports, even without personally identifiable information.
  • Depending on your platform, these will be sent to these third parties:

  • Windows: Hockeyapp (owned by Microsoft). See Microsoft Privacy Policy (https://privacy.microsoft.com/en-us/PrivacyStatement)
  • Mac: Crashlytics (Owned by Google). See Crashlytics Privacy Policy (https://try.crashlytics.com/terms/privacy-policy.pdf)
  • iOS: Apple. See Apple Privacy Policy. (https://www.apple.com/privacy/) iOS releases this data by default.. You can disable this in iOS settings as described here (https://support.apple.com/en-us/HT202100)
  • Android: Google Analytics See Terms of Service for Google Analytics. (https://www.google.de/analytics/terms/us.html)
  • After activating the SpyOFF app, you will be asked if you want to share this data. You can start or stop this sharing of diagnostic data at any time in the app’s settings menu. It is non-personal data. There is NO information about the activity being performed in the SpyOFF VPN tunnel, such as browser history, saved web content, VPN traffic destinations, DNS queries, or IP addresses.

    Jurisdiction and applicable law

    SpyOFF (Sareta S.r.l.) is headquartered in San Marino, where stricter information disclosure laws apply than in most other countries. San Marino has no data retention laws or any legal system that requires a company to disclose customer information. Under the law, requests for information from foreign courts or law enforcement agencies are subject to a “double criminality” provision, which means that the petition will only be upheld by the court if the same crime is threatened with at least one year’s imprisonment. If we receive a valid San Marino subpoena, it is important to note that SpyOFF does not collect IP addresses, browsing history, traffic data, or DNS queries that could be used to identify a particular user.

    Forbidden actions

    Due to our no-log policy, there is no possibility for user identification. That being said, we ask our users to make fair use of the service. Freedom on the Net also always means responsibility, which we ask of our users in good faith. Please see also: LINK

    Privacy of minors

    You represent and warrant that you are at least thirteen years old and legally authorized to use our service. If you are under eighteen (18) years of age, please read the agreement with your parents or legal guardians. We do not use the Service to knowingly solicit or market information from children under the age of thirteen (13). We require that such persons provide no personal information about our services. If you are aware of, or have reason to believe, that a child under the age of thirteen has shared information with us, please contact us at: support@spyoff.com and we will take reasonable steps to ensure that this information is obtained from our files in order for it to be deleted.

    How does our website handle Do Not Track signals?

    We respect the “do not track” signals and do not track, use cookies, or use advertisements when there is a “do not track” (DNT) browser mechanism enabled.

    Your rights and prerogatives:

    Your main data protection rights with regard to your personal data are:

  • (a) the right to access information provided to you through your account;
  • (b) the right to rectification;
  • (c) the right to delete;
  • (d) the right to limit processing;
  • (e) the right to object to processing;
  • (f) tthe right to remove your data (data portability);
  • (g) the right to complain to a supervisory authority; and
  • (h) the right to revoke consent.
  • We offer you the opportunity to make certain decisions in connection with our treatment of your personal information. Depending on your relationship with us, these choices may involve access to the personal information we collect about you, or correcting, updating, or deleting the information we hold about you. If you want to exclude yourself from collecting data or cannot exercise your rights via your account, please contact us at: support@spyoff.com. If you make such a request, please be aware that we may need certain information from you to verify your identity and locate your information, and that the process of searching and erasing the data requires reasonable time and effort. The privacy laws and related legislation in your jurisdiction may grant you other or additional rights in connection with the information we receive from you, which may also apply.

    Security measures to protect your information

    SpyOFF uses the best physical, procedural and technical security with respect to our offices and information storage facilities to prevent loss, misuse, unauthorized access, disclosure or alteration of information. Access to user information is restricted to employees who need such access to perform their tasks. Although we believe that these systems are robust, it is important to understand that no data security measures in the world can provide 100% protection. Servers are located in data centers with strong security practices. None of these data centers require the collection or storage of traffic data or personal information related to your use of SpyOFF services. If any data center asked us to log such data, we would immediately stop using the data center and find alternative ways. Even if a government physically confiscates one of our VPN servers and manages to break their hard drive encryption, there are no protocols or information that bind a single user to a particular event, site, or behavior.

    Updating the privacy policy

    If we make changes to our Privacy Policy at our sole discretion, such changes and updates will take effect immediately after notification of the amended Privacy Policy has been made. Therefore, we encourage you to review this Privacy Policy periodically for updates in order to be fully aware of how your information is being collected and used by the company, as well as of your rights to it. The date of the last revision is given in the heading “Status.” Your continued use of the Services after such changes have been made constitutes your acknowledgment and acceptance of any changes to the Privacy Policy, as well as your consent to be bound by the terms of this amended Policy. If we make any material changes to this Privacy Policy, we will notify you through the website and will endeavour to notify you by email before the change takes effect.

    Our details

    Our website is owned and operated by Sareta S.r.l., Serravalle (R.S.M.).

    You can contact us:

  • [by post using the postal address given above];
  • [via our website contact form [help.spyoff.com]
  • through our website contact form [support@spyoff.com]]
  • Responsible for data protection

    For all concerns about data protection, please contact directly: privacy@spyoff.com