Last updated: 04/07/2024
- We, Innovative IMSOFT . LTD. and its affiliates, are committed to protecting your
privacy. We strictly limit the collection scope of your data. Only data required to maintain
our service is collected.
- This Privacy Policy describes how we collect, use, and share your data in connection with
your use of our websites (
), services, and applications
(collectively, "outline"). This Privacy Policy does not apply to data that you send and/or
receive from third party websites through outline.
1. COLLECTION OF DATA
- 1.1 Data NOT to be collected
- We do not collect the following data:
- 1) Names (including subscriber names, user names, and screen names);
- 2) Addresses (including residential addresses and business addresses);
- 3) 3) Telephone numbers; and
- 4) Payment details:
- a) We do not collect your payment details for outline. We do not collect or store credit
card numbers, bank account numbers, or billing records.
- b) When you make payments to us, outline may redirect you to the website of a third party
payment processor to complete the transaction. If you would like to understand what personal
data the third party processor collects and stores, please kindly refer to the respective
processor's terms and privacy policy.
- We do not collect sensitive data as we have engineered our systems to categorically erase
the storage of sensitive data.
- We do not collect any data related to your online activities. We do not collect data logs of
your activities, including:
- 1) Browsing history;
- 2) Traffic destination;
- 3) Data content; and
- 4) DNS queries.
- We do not collect data of your connection logs, including:
- 1) Your IP address;
- 2) Your outgoing VPN IP address;
- 3) Connection timestamp; and
- 4) Session duration.
- As we do not collect data logs of your activity or connection logs, we would not have
information about:
- 1) The websites you visit;
- 2) The time you connected to outline; and
- 3) The set of original IP addresses of your computer or the temporarily assigned network
addresses.
- 1.2 Data to be collected
- We limit the collection of your data. We only collect data that is required to maintain the
services by outline.
- 1.2.1 Data provided to us
- We collect the data that you provide to us through your interaction with outline. When you
register for an Account, we may ask for your email address. The amount of data that you
provide us depends on your privacy settings.
- We use your email to:
- 1) Communicate with you;
- 2) Send you updates and announcements; and
- 3) Send marketing information, such as our offers, surveys, invitations, and other content.
- If you contact us directly, we may receive data such as your name, email address, phone
number, content of the message and/or attachments, and any other personal data you may
choose to provide to us in your communication to us.
- You may withdraw your consent to our use of your email address for the above purposes.
- 1.2.2 Data necessary for us to maintain the service quality of outline
- We collect the following data related to your use of outline:
- 1) Data related to versions of outline: we collect data related to your version of outline.
This allows us to efficiently identify and eliminate technical issues that you may face.
- 2) Data related to VPN connection: we collect abstracted data related to your use of hello
VPN. This would include success of VPN connections, VPN location you connected to, your
country, and your internet service provider. You cannot be identified from this abstracted
data.
- 3) Amount of data transferred: we collect the aggregate sum of data transferred to ensure
that individual users do not use excessive data at the expense of other users’ experience.
- 4) Anonymous data for network diagnostics, study and analysis: We collect anonymized data to
operate outline, including diagnostic data such as VPN connection failures, speed test data,
and crash reports.
2. USE OF DATA
We use, combine, and process your data for the following purposes:
- 2.1 Security
- We authenticate your use of outline by assigning a unique identifier to you when you
register for the service via your email address. This unique identifier, without reference
to other data, identifies you through your device identification code. The purpose of the
unique identifier is for us to determine the level of service you have signed up for before
we establish your outline connection.
- We do not use any other forms of your data to verify your identity.
- 2.2 System diagnostics
- We use the data related to your outline usage to perform internal operations necessary to
maintain services of outline. This includes operational troubleshooting, conducting data
analysis & activity trend analysis.
- 2.3 Customer support
- We use your data to resolve customer support issues. For example, we may investigate and
address concerns, monitor and improve our customer support, respond to your questions and
feedback, and inform you of suggestive steps to resolve certain regular customer issues.
- We may communicate with you to provide updates relating to outline, and for marketing &
promotional purposes.
- 2.4 Research and development
- We use your data to understand and analyze your use of outline to develop new products,
services, features, and functionalities for you.
- 2.5 Service providers
- We use data from service providers and third-party vendors to provide and market outline.
3. SHARING AND TRANSFER OF DATA
We share and transfer your data in various ways, including the following:
3.1 Aggregated anonymous data
We use and share your data with our partners in aggregated or anonymized form that cannot be used
to identify individual users.
3.2 Referral
If you sign up for outline through a friend’s referral, we may let your friend know that you sign
up for outline via his/her referal.
3.3 Analytics
We share and transfer your anonymized statistics and analytical data for network diagnostics.
3.4 Business transfers
Your data may be disclosed and otherwise transferred to potential acquirer, successor, or
assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar
transaction, or in the event of insolvency, bankruptcy, or receivership.
3.5 With your consent
With your consent and instruction, we may share your data.
3.6 International data transfers
We may process your data to any countries in which we engage service providers. You hereby
acknowledge the transfer of your data outside of the country where you reside. We will ensure
that your data is well protected before the transfer.
4. SECURITY MEASURES
We implement robust security measures to protect your data from unauthorized access, collection,
use, disclosure, copying, modification, disposal, or similar risks. We ensure the security of
our computer networks and sound adoption of control measures. Access of our staff to your data
is restricted to a strict need-to-know basis.
We do not collect or store any traffic data or personal data in our data centers.
5. DATA RETENTION
We retain your data on the condition that we have a legitimate ongoing business need to do so,
such as providing you with service you requested, or complying with applicable legal, tax, or
accounting requirements.
When there is no legitimate ongoing business need to process your data, we will delete or
anonymize it. If it is impossible to delete or anonymize your data (for instance, because it has
been stored in backup archives), then we will securely store it and isolate it from any further
processing until deletion is feasible.
6. RIGHT TO BE FORGOTTEN
- We will erase your data when:
- 1) Your data is no longer necessary for the purpose which we originally collected or
processed it for;
- 2) You withdraw your consent to us holding your data, and we are relying on your consent as
the lawful basis for holding your data;
- 3) You object to our processing of your data, and there is no overriding legitimate interest
for us to continue such processing; or
- 4) We are processing your data for direct marketing purposes and you object to the
processing thereof.
7. THIRD PARTY SERVICES
You may access other third party services while using outline, for example, by clicking on links
of third party services from within outline. We shall not be held responsible for the privacy
policies and/or practices of these third party services. You are encouraged to carefully review
their privacy policies.
8. ADVERTISING
- 1) Paid outline
- For paid outline, we do not work with third party advertising partners.
- 2) Free outline
- For free outline, we work with third party advertising partners to offset the cost of
providing our services. We do not target advertisements based on your data. We do not share
or use your data in connection with third party advertisers without your prior consent.
- Third party advertising partners may set and access their own cookies, pixel tags, and
similar technologies on our services, and may otherwise collect or have access to data about
you which they may collect over time and across different online services.
9. 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 details.
No personal information should be submitted to outline 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 does not meet the minimum legal age required in their state of
residence.
Such a user cannot:
l display their real name or any information in outline
l access the chat, leader board, forums, SNS (Facebook, Game Center, etc.)
l subscribe to newsletters
l use any other feature where users’ real names might appear
With respect to such users, 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 websites & apps with their parents' or
guardians’ authorization and/or their parents' or guardians’ physical presence being required
depending on the state where testing is conducted.
Parents must exercise their privacy rights for their children provided in this Privacy Policy.
10. ORDERS COMPELLING THE DISCLOSURE OF YOUR DATA
Our collection of your data is strictly limited. We collect your device identification code, and
other data you may volunteer to us when you voluntarily contact us by way of email, phone, or
interactions at our website or on outline’s application page on Google Play or App Store. We do
not collect IP addresses, browsing history, traffic data, or DNS queries that could be used to
identify you. As such, the extent of any disclosure of your data is limited.
We are committed to safeguarding your data. Nonetheless, we may be compelled to disclose your
data where we are served with a valid court order that is enforceable in Singapore, an order
from law enforcement agencies, or where we are legally obligated to disclose your data. We will
require the recipient of your data to undertake the protection of your data, to a standard that
is at least comparable to the protection required under Singapore’s Personal Data Protection Act
(“PDPA”).
11. ACCESS
When you become a user of outline, you may request access to your data that is associated only
with you by emailing [email protected] .
To protect your privacy and security, we may take reasonable steps to verify your identity before
acceding to your request. Upon our approval of your access request, we will provide you with
your data that is in our possession or under our control. Where applicable, we will provide you
with information about the ways in which your data has been or may have been used or disclosed
by us within a year of your request. We may charge you a fee for fulfilling the access request.
12. CORRECTION
You may make a request to correct an error or omission about your data that is in our possession
or control, by emailing [email protected] .
We will consider whether the correction should be made. If such correction is to be made, we
shall correct your data as soon as practicable and send the corrected data to every other
organization to which your data was disclosed by us within a year before the date the correction
request was made, unless that other organization does not need the corrected data for any legal
or business purpose.
To protect your privacy and security, we may take reasonable steps to verify your identity before
correcting your data. Your data may be archived or stored periodically by us according to backup
processes conducted in ordinary course of business for disaster recovery purposes.
12. 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 that
the info relates to you and not to any other person.
- You can exercise your rights at any time and ask outline 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 [email protected] .
- 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 processing thereof is mandatory for outline to provide the
services.
- Your actions may force outline to cease providing services. When the conditions below apply,
services will be reset:
- - If you ask for the modification of this mandatory information, we may be unable to
continue providing outline services for you.
- - If you request limitations to processing that are mandatory for outline, or you object to
such processing (in which case, we may not be able to provide you with outline or our other
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 any more, but we will store it to meet 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 [email protected] .
- 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 improper
information, please email us at [email protected] and we will delete the information
from our systems.
- 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, in which case you will be specifically informed.
13. 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 your personal information.
Please note that we do not sell your personal information to provide outline 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 cannot reuse your personal information for
any other purposes. Our contracts are strictly drafted to protect your personal information and
your privacy rights.
13. BREACH NOTIFICATION
We will report serious breaches of your data security to relevant supervisory authority to ensure
the effective protection of your data.
14. CHANGES TO THIS PRIVACY POLICY
To ensure compliance with applicable laws, this Privacy Policy may be modified from time to time
without prior notice to you. Your continued use of outline constitutes your acceptance of our
Privacy Policy. Changes to this Privacy Policy will be posted on our websites.
If we materially change the ways in which we use or share your data previously collected through
outline, we will notify you through outline, email, or other communication.
15. GOVERNING LAW
This Privacy Policy is governed by and construed in accordance with the laws of the Republic of
Singapore.
16. DATA PROTECTION OFFICER