Matreshka VPN Privacy Policy
This Privacy Policy explains how VPN Ghostwalk Limited, registered at 487 Ripon Road, Stevenage, Herts, England, SG1 4NT, processes your personal data when you use our Services or interact with our Website. This Privacy Policy is effective until replaced by a new policy. We may update this Policy at our discretion, so you should check this page periodically for possible changes. The most current version of the policy will be indicated by the date of the last update at the bottom of the page. Your continued use of our Website and Services will mean that you accept and understand the terms of this Policy in its current version.

1. What information is collected and why? We do not keep logs of our Services. We do not collect any data that could help us learn about your online activities. Matreshka VPN values your privacy, so we are committed to not processing any information about our users' online activities. Matreshka VPN's jurisdiction does not require us to store or share user information. We do not collect any data about what you do online (IP addresses visited, browsing history, session information, bandwidth used, connection timestamps, network traffic and any other such information). You can be assured that we do not store any data about the websites or applications you visit. When you visit our website or use our application (collectively, the "Website"), we collect and use certain data to improve the performance of our Website. The information we collect on our Website may include anonymous "traffic information" provided by the host or a similar provider of such data (such as Google Analytics) that does not identify you personally. This information is statistical in nature and includes information about which pages of the Matreshka VPN Website or application visitors open and how long they stay on a particular page. This provider also provides information about which browser, network or device is used to visit our Website. More about Google Analytics and how to opt-out of its services can be found at https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en. The legal basis for such processing is our legitimate interest in analyzing and improving our Website and user interactions. This does not mean that we track your online activities while using our Services. When you use our Services, we collect and use the following data and for the following purposes: Authorization information: your apple/google ID, app access key, or email address. To provide our Services and to verify your subscription and expiration date. We process a limited amount of information related to the use of our Services (authorization data: email address, account registration date, subscription information). To provide our VPN Service (currently available for IOS, macOS and Android, Android TV, Windows users) we collect information about the devices on which it is used. We need this data to verify compliance with the limit on the number of devices on which a single customer can use the VPN service under our Terms of Service. If you use the mail authorization feature, we process your email address to verify and send you a one-time password. We use a reliable transactional mailing provider to implement this functionality. The legal basis for processing the information is the fulfillment of a contract to which you are a party. Please note that this information is necessary for the conclusion of the contract and if you do not provide it (or if we are unable to retain it), we will not be able to provide our Services to you. Analyze and improve the performance of our Services and user interactions (while using our Services). In order to maintain the excellence of our Services and provide effective support, we collect diagnostic data and track reports about failures in our applications and extensions, solely with your consent. The information we collect contains aggregate performance data, frequency of use of our Services, failed connection attempts, and other similar information. Please note that diagnostic data does not contain personally identifiable information. Occasionally, we may need information about your device to resolve problems using our applications. We will only have access to this information if you agree to provide it. You can be assured that we do not share this data with third parties or retain it. We may contact you by email for this purpose, but we still recommend contacting us via the online contact form to get a VPN on the best terms. We may ask you to provide some information about yourself so that we can respond to your requests more effectively. We use users' e-mail addresses to: 1) verify the user on our Services; and 2) respond to their inquiries and questions. In addition to your e-mail, we process your inquiry and other data you provide during communication. The legal basis for processing personal information is to fulfill the terms of your contract with us (in the case of important communications in connection with our Services) or your consent (in the case you send a request to our support team). To interact with you via social media. Accounting, payments, legal requirements and legal proceedings. We are subject to accounting, tax and other legal requirements. We may need to collect and store some of your data: e-mail address, subscription and payment information, legal documents, if necessary to protect your rights and legitimate interests. Payment-related information: our payment processing partners collect the data necessary to process payments and/or chargeback requests (transaction date, full name of the owner and credit card number). We process only a very small portion of this payment information (payment amount and currency, payment date) to address payment-related issues (e.g., fraud prevention). If you choose the payment method via your IOS, Android, macOS system - payments will be processed by the payment system provider apple pay / google pay, including information about VAT and other taxes in your region. If you choose a bank payment method for payments for our Services, we will collect data about the payer, such as: date and time of payment, specified payer ID, specified payer mail (to send a payment check). The legal basis for processing personal information is the legal obligation that applies to us (where it is necessary to collect your data in accordance with legal regulations) and our legitimate interest in protecting our rights and interests (where there are other legal processes relating to you).

2. How long do we keep your personal information? Data Retention Don't forget that one of our most important principles is that we do not retain logs (see our Terms of Service for details), so we collect the minimum of your data necessary to provide you with our services. How long we retain your personal data depends on the purpose for which we process it as described in paragraph 1 of this Policy: Personal information required to provide our Services is processed for as long as you use Matreshka VPN, and for no more than 1 year after discontinuation of use or for no more than 24 hours when you delete your account from the system Personal information necessary to analyze and improve our Website/Services and user interaction is processed prior to deleting your account. Personal information necessary to provide our Services to you is processed for as long as you use them or give us consent to such processing. Personal information necessary for communication and customer support is processed for no longer than three months from your last contact, with the exception of device data (collected with your consent to resolve your issues with the app), which we keep for no longer than 7 days. Personal information required to interact with you via a social network is processed for as long as you are registered on that social network.

3. How does our Website interact with third party services and content? Transfer of information Your information from point 1 may travel a little around the world, but we always take care to keep it safe and secure. Your information from point 1 may be stored and processed in any country where we have infrastructure or partnerships with other service providers. Please note that we apply standard contractual clauses approved by the European Commission (available here) to transfers of your personal information from the EEA to other countries, or transfer personal information to countries that the European Commission recognizes as countries with an adequate level of data protection (list of countries available here). Information recipients Maintaining our Services requires multiple services and resources. We use third-party tools and services for marketing activities, payments, transactional letters, and other tasks. Because they operate independently of us, we encourage you to review their terms and policies on their websites. Matreshka VPN shares personal information with recipients of information only when necessary for the purposes described in paragraph 1 and as permitted by applicable law. We do not sell your data to anyone, ever. We do not ask for personal information and cannot disclose it, even to law enforcement agencies or courts of competent jurisdiction.

4. What choices do you have about how your information is used? We comply with the GDPR and other privacy laws. You can request that we delete your data or exercise any of your other rights by sending an email to support@matreshkavpn.com. You may be aware that the EU General Data Protection Regulation (GDPR) and other privacy laws give people certain rights in relation to their personal information. As such, we have provided our users with additional transparency to help them exercise these rights. Except where restricted by applicable law, individuals have the following rights: You can access your personal information or a copy of it by contacting us. You may object to the processing of your personal information, ask us to limit the processing or request the portability of your personal information where technically possible. If necessary, you may request the correction of incorrect personal information and, depending on the nature of the collection and use, the addition of incomplete personal information (right to rectification). The right to have your personal information referred to in paragraph 1 deleted, except where required by applicable law or where we have a legitimate reason to retain certain personal data. If we have collected and processed your personal data with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of their processing prior to your withdrawal, nor will it affect the processing of your personal information carried out on lawful bases of processing other than consent. You have the right to lodge a complaint with the supervisory authority for personal data protection. If you wish to exercise any of the above rights, please contact us: support@matreshkavpn.com

5. Do we use automated individualized decision making, including profiling? No. Automated decision-making is the process of making a decision by automated means without human involvement. Profiling analyzes aspects of a person's personality, behavior, interests and habits to predict or make decisions about them. We assure you that we do not make decisions based solely on automated processing, including profiling, that may have legal implications for you.

6. How do we protect your information? We do care about your security and privacy and do what is necessary to protect it. That being said, it is important to realize that if someone promises you 100% protection against anything, they either have a poor understanding of the issue or are trying to mislead you. We have implemented various security measures including SSL/TLS encryption for data transmission, hashed passwords, firewalls and regular independent audits. We take all steps reasonably necessary to process your information securely. You should be aware that with all security measures in place on our Website and Services, it is not always possible to ensure 100% security. Every time you provide your data online, there is a risk that a third party may intercept and use it. While we do our best to protect your information and privacy, we cannot guarantee the security of your data that you disclose online. By using the Services, you expressly acknowledge and agree that we cannot guarantee the security of data submitted by you or received by us through the Services and that any general information, other information or information collected from you through the Website or Services is provided by you at your sole responsibility.

7. Does our Website and applications respond to "do not track" signals? Yes. Matreshka VPN recognizes automatic browser signals regarding tracking mechanisms that may have "do not track" instructions.

8. Who should I contact with questions or concerns? Our 24/7 support team is always on call and ready to help. If you have any questions or comments regarding Matreshka VPN Services, email us at support@matreshkavpn.com or Telegram @matreshkavpn_support

9. Other Terms and Conditions The English language version of this Privacy Policy shall prevail. Translations of this Privacy Policy into other languages may not be up-to-date or incomplete, therefore, in the event of any conflict between the English and translated versions of this Privacy Policy, the English version shall prevail.

10. When was this policy last updated?
October 24, 2023.
It is important to keep an eye out for available updates.