We want you to understand what information we collect, what we don’t collect, and how we collect, use, and store information. We do not collect logs of your activity, including no logging of browsing history, traffic destination, data content, or DNS queries. We also never store connection logs, meaning no logs of your IP address, your outgoing VPN IP address, connection timestamp, or session duration. Our guiding principle toward data collection is to collect only the minimal data required to operate a world-class VPN service at scale. We designed our systems to not have sensitive data about our customers; even when compelled, we cannot provide data that we do not possess. This privacy policy will help you understand how GNUAPP UNIPESSOAL LDA (“GnuAPP,” “we,” “our,” or “us”) collects, uses, and stores information.
ClusterVPN collects four types of information:
This information is collected for the purpose of administering your ClusterVPN subscription and includes your name, email address, and payment information, which you submit on our order page when you subscribe for the Services.
ClusterVPN collects minimal information about usage in order to maintain excellent customer support and quality of service. The section below specifies in detail what information we collect. These statistics never include anything about what the user did with the VPN: no data about the contents or destinations of VPN traffic.
App diagnostic data, which include crash reports, usability diagnostics, and VPN connection diagnostics, are anonymized and cannot be tied back to individual ClusterVPN users. This feature is similar to a “send bug report” option. Users can specify in the settings menu of any ClusterVPN App whether to send these data to us.
ClusterVPN collects personal information that you provide to us directly through the Site. We require that you provide personal information, such as an email address and payment information, in order to establish an ClusterVPN account, and so that we can email you, collect payments from you, and respond to support queries that you initiate. The specific information collected varies depending on the payment method you choose. To minimize the amount of personal information you submit to us, we recommend that you use Crypto payments when subscribing to our Service. With some forms of payment, the Site may redirect you to the website of a third-party payment processor (any payment systems) to complete the transaction. To understand what personal information these processors collect and store, please refer to the respective processor's terms and privacy policy. ClusterVPN uses your email address for the following reasons: To send emails related to payment transactions. To provide links to our Site, including password reset emails. To send you updates and announcements. To communicate with you about your VPN services or respond to your communications. To send marketing information, such as ClusterVPN offers, surveys, invitations, and content about other matters in connection with ClusterVPN (“Marketing emails”). You may choose to not receive Marketing emails by following the opt-out procedure described in these emails. ClusterVPN uses your personal information only for the purposes listed in this Privacy Policy, and we do not sell your personal information to third parties. Any personal information associated with ClusterVPN accounts is controlled only by ClusterVPN, including being stored on systems and servers owned or leased by ClusterVPN and its subsidiaries. In the limited circumstances where this data may need to be processed by other related entities, it may be shared only when required, and for the duration required, for processing solely related to the purposes and legitimate interests outlined in this Privacy Policy, while ensuring at all times the same data protection standards. For avoidance of doubt, these circumstances do not include any situations where control of personal information of ClusterVPN users will be transferred to any other related entities, including but not limited to our ultimate holding company, GNUAPP UNIPESSOAL LDA, for any duration of time.
We ensure that we never log browsing history, traffic destination, data content, IP addresses, or DNS queries. Therefore: We do not know which user ever accessed a particular website or service. We do not know which user was connected to the VPN at a specific time or which VPN server IP addresses they used. We do not know the set of original IP addresses of a user’s computer. Should anyone try to compel ClusterVPN to release user information based on any of the above, we cannot supply this information because the data don’t exist. In order to maintain excellent customer support and quality of service, ClusterVPN collects the following information related to your VPN usage:
We collect information related to which Apps and Apps version(s) you have activated. Knowing your current version of the Apps allows our Support Team to troubleshoot technical issues with you.
We collect information about whether you have successfully established a VPN connection on a particular day (but not a specific time of the day), to which VPN location (but not your assigned outgoing IP address), and from which country/ISP (but not your source IP address). This minimal information assists us in providing technical support, such as identifying connection problems, providing country-specific advice about how to best use our Service, and to enable ClusterVPN engineers to identify and fix network issues.
We collect information regarding the total sum of data transferred by a given user. Although we provide unlimited data transfer, if we notice that a single user pushes more traffic than thousands of others combined, thereby affecting the quality of service for other ClusterVPN users, we may contact that user for an explanation. We’ve engineered our systems to categorically eliminate storage of sensitive data. We may know THAT a customer has used ClusterVPN, but we never know HOW they have utilized our Service. We stand by our firm commitment to our customers’ privacy by not possessing any data related to a user’s online activities.
With your permission, we collect anonymized app diagnostic data, which include crash reports, usability diagnostics, and VPN connection diagnostics. We use this data in our network operations tools to help optimize network speeds and to let us identify problems and areas for improvement related to specific apps, VPN servers, or ISPs. The information we receive is fully anonymized and cannot be tied back to individual ClusterVPN users (i.e., we do not store which user sent which data, and we do not store user IP addresses). If you opt in to share this information with ClusterVPN, we will collect the following anonymized information: Diagnostic information about if and how a VPN connection attempt failed. Speed test data. App diagnostics, including crash reports and usability diagnostics, also without any personally identifiable information. These are handled in an anonymized form by these third parties, dependent on the platform you are using ClusterVPN on: Windows: Hockeyapp, owned by Microsoft, and Sentry, owned by Functional Software, Inc. See Microsoft’s Privacy Policy and Sentry’s Privacy Policy. Mac: Crashlytics, owned by Google, and Sentry, owned by Functional Software, Inc. See Crashlytics’s Privacy Policy and Sentry’s Privacy Policy. Linux: Sentry, owned by Functional Software, Inc. See Sentry’s Privacy Policy. iOS: Firebase Crashlytics, owned by Google, and Apple. See Apple’s Privacy Policy and Firebase’s Privacy and Security documentation. You can disable Apple’s crash reporting in iOS settings as described here. Android: Firebase Crashlytics, owned by Google. See Firebase’s Privacy and Security documentation. Browser extensions: Google Analytics, owned by Google. See Google’s Privacy Policy. Upon activation of any ClusterVPN App, you will be asked if you would like to share these data. You can start or stop sharing these diagnostic data at any time in the App’s settings menu. On iOS, Apple’s crash reporting can be turned off in iOS settings.
ClusterVPN’s core mission is to keep your information private. In service of this mission, ClusterVPN’s headquarters and registered place of business is in Portugal and Applicable law by Portugal and EU regulations.
ClusterVPN uses best-in-class physical, procedural, and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of information. Access to user information is restricted to staff who require such access to perform their job functions. While we believe these systems are robust, it is important to understand that no data security measures in the world can offer 100% protection. Servers are housed in data centers with strong security practices. None of these data centers require us to collect or store any traffic data or personal information related to your use of VPN Services. If any data center were to ask us to log such data, we would immediately cease operations with said data center and find alternative options. Even if a government were to physically seize one of our VPN servers and manage to break its disk encryption, there would be no logs or information that would tie any individual user to a particular event, website, or behavior.
A cookie is a small text file used to store information about your visit to the Site. Cookies let ClusterVPN optimize and improve the user experience of the Site by helping us deliver certain functionalities, such as website login and language settings. The cookies we use may vary over time as we continuously update and improve our Site.
You are free to change your cookie preferences at any time. You can do this in the settings panel for your browser. Depending on which browser and device you use, you may be able to control which cookies you allow, which cookies you want to block in the future, and delete cookies. For more information about these settings, please refer to the “help” section of your browser. Note that ClusterVPN’s Site may not work as intended if you choose to disable cookies.
The cookies set by ClusterVPN enable us to set your language preference, attribute visitors to a marketing channel, and, once you log in, securely show you information that is specific to your account. The cookies contain a user identifier, but no directly personally identifying information such as your name or email address, and do not track any activity outside of ClusterVPN’s domains.
ClusterVPN uses third-party services such as Google Analytics, AdMob and Adwords. Cookies from such services are used to collect data for statistical reports. For example, we may generate reports regarding the amount of time users spend on the Site and the number of users who visit a particular page. ClusterVPN uses Google AdMob, AdWords remarketing to show advertisements on third-party websites (including Google) to users who have visited our Site. We may show such users advertisements on a Google search results page, or on a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Site. Any data collected will be used in accordance with our Privacy Policy and Google’s privacy policy. Users may opt out of Google’s use of cookies by visiting the Google Advertising Opt-out Page. Users may opt out of Google Analytics by visiting the Google Analytics Opt-out Page. Users may opt out of third-party vendor use of cookies by visiting the Network Advertising Initiative Opt-out Page.
A mobile identifier is an identifier provided by an Android or iOS device. It does not contain your name or email address. ClusterVPN uses mobile identifiers to generate statistics related to the marketing channels and advertising partners through which users learned about and signed up for ClusterVPN mobile apps.
Users may disable or reset the mobile identifiers associated with their devices at any time. For instructions, see Apple’s page on Advertising Privacy on iOS devices and Google’s page on Managing your Google Settings on your Android device.
The Site may contain links to external websites that do not fall under ClusterVPN’s domain. ClusterVPN is not responsible for the privacy practices or content of such external websites.
By using the Site, Content, Apps, Software, or Services, you agree to have your information handled as described in our Terms of Service and Privacy Policy. The Services are intended for adults aged 18 and above. If you believe your child has provided information to us, please let us know immediately.
ClusterVPN is committed to user privacy globally, and our existing practices reflect that through minimal collection of data and ensuring users have control over their personal information. The General Data Protection Regulation (GDPR) of the European Union (EU) requires us to outline those practices in a specific manner for users in the EU. In line with the GDPR, we collect and process the data outlined in this Privacy Policy on one of the following bases, depending on the circumstances: For the purposes of fulfilling our contractual obligations to users, including: Providing users with the Services and Apps they have requested. Managing user subscriptions and processing payments. Providing customer support. For a legitimate interest associated with the operation of our business, including: Enhancing the quality, reliability, and effectiveness of our Site, Services, and Apps. Communicating with customers to provide information and seek feedback related to our Services and Apps. With the consent of users, which users can withdraw at any time. You can exercise your rights under the GDPR to access, transfer, correct, delete, or object to the processing of your personal information by contacting us at clustervpn@gnuapp.com.
We may change our Privacy Policy from time to time, without prior notice to you, consistent with applicable privacy laws and principles. Your continued use of the Site or Services constitutes your acceptance of our Privacy Policy.
If you have any questions regarding our Privacy Policy and how we handle your information, please feel free to contact ClusterVPN at the following email address: privacy@gnuapp.com