This document ("Privacy Policy") explains the privacy rules that apply to all information collected or submitted when you access, install or use the Spell Services.

All definitions and capitalized words used in this Privacy Policy are defined here or in our General Terms.

By visiting our website, by submitting your personal data to us, and by accessing, installing and/or using the Services, you confirm that you have read this Privacy Policy and agree to be bound by it. If you do not agree to the provisions of this Privacy Policy, please do not use our services.

The information in this Privacy Policy is presented hierarchically, which means that all information relevant to our general personal data processing practices is provided here.

What personal information do we collect?

"Personal Information" means any information relating to an identified or identifiable individual. We obtain personal information about you from various sources as follows. Where applicable, we will explain whether and why you must provide us with your personal information, and the consequences of not doing so. If you do not provide personal information as requested, you may not be able to benefit from certain features of our Services if that information is necessary to provide you with that feature of our Services.

There are two basic categories of personal information we collect:

- Personal information you choose to provide to us

- We automatically collect personal information when you use our services

You can rest assured that the personal information we may collect, including your email, IP address, username or unique mobile ID, will never be linked to any online activity you engage in while connected to Spell. Additionally, when connected to Spell, your IP address is stored in an encrypted format for the duration of the session and deleted after you disconnect from the VPN.

Personal Information We Collect Automatically When You Use the Services

• When you use Spell to download, connect to or visit our website, we and our third-party service providers will automatically collect information about you or your equipment. Below is a more complete explanation of the types of personal information collected when you use our Services:
• When you launch the Spell app, before you connect to the VPN, we and our service providers collect device-specific information such as unique mobile ID, hardware model, operating system version, language, and network information. We may also use but never log or store your IP address to obtain your approximate (city level) location. We use this information to provide and improve the Services, and to troubleshoot and analyze our Services.
• When you connect to Spell, we collect your IP address, encrypt it immediately and store it only for the duration of your VPN session. Your IP address will be deleted when you disconnect from the VPN. We do not associate your IP address with your online activity, and we do not store or log your IP address after you disconnect from the VPN.

We do not attribute any particular website visit or application usage to any particular user. We do not keep logs of your online activity or associate any domains or applications you use with you, your device or email.

Your personal data protection rights

You can ask us to inform you about the personal data we collect about you, request the correction or correction of inaccurate information, object to certain processing of personal data (e.g. for marketing purposes), provide you with a structured, commonly used and machine-readable format, to transfer (if technically feasible) your personal data to another controller, or to delete your personal data. You can also request the restriction of the processing of your personal data (if there are legal grounds for this). If your personal data is processed on the basis of separate consent, you have the right to withdraw your consent to the processing of your personal data at any time.

If you do not agree to the processing of your data by Spell, you are free to choose not to use the Spell service and to stop using it at any time. You can ask us to stop processing your personal data, in which case your data will only be processed to the extent necessary to affect your ceasing to use Spell services (e.g. final settlement, or deletion of all data based on personal data ) on your email address), or to complete other Spell legal relationships with you (eg accounting, invoicing, processing chargebacks).

For technical reasons (e.g. backup copies of databases), your personal data can only be finally deleted after 60 days or more, if enforced by statutory requirements.

If you wish to use Spell services again, you must re-accept and agree to this Privacy Policy.

How we process your data?

Spell only processes user data to a very limited extent - only to the extent absolutely necessary to provide the Spell service, process payment for the Spell service, and operate the Spell website and mobile applications.

Personal data is processed automatically and manually by Spell. Unless expressly stated otherwise, Spell or its designated subsidiary in your country shall act as the responsible personal data controller for any data processed. Spell uses third-party data processors only for the processing of payment data and basic website analytics.

Spell guarantees a strict no-logs policy for Spell services, which means that your use of Spell services is provided by automated technical processes and will not be monitored, recorded, logged, stored or passed on to any third parties. We do not store connection timestamps, session information, bandwidth used, traffic logs, IP addresses or other data. From the moment a Spell user opens the Spell software, their Freeernet data is encrypted. ISPs, third-party snoopers, or cybercriminals can no longer see any online traffic coming from user devices. Also, Spell has a strict no-logs policy when it comes to viewing online user activity: Spell is based in Panama and requires no data storage.

Anyone can browse our website, install Spell applications and mobile applications without registering for the Spell service, but the functionality of the Spell service will be very limited or non-existent. If you want to use the full functionality of the Spell service, you need to create a user account and provide basic personal data as shown below.

Payment related information.

In order to maintain the VPN service, Spell also processes limited technical information, which may sometimes be considered personal data. This information is used to improve the functionality and usability of our website and Spell services. If you decide not to provide this limited information, we may not be able to provide you with the full range of Spell services. Said information may also include:

Server load information. We monitor server performance in order to recommend the most suitable server to our clients.

Customer Service Information. Spell stores inquiries and communications with users through the "Contact Us" and "Community Area" pages, unless the user requests deletion of the conversation.

biscuit. Spell uses several different cookies to improve the user experience on the website, such as:

Google Analytics for statistical evaluation and website performance improvement;

Associate cookies to identify customers referred to the Site by our partners so that we can provide referrals with commissions;

Cookies used to personalize website content for users, such as setting a default language.

You can set a warning each time a website places a cookie on your browser, or you can choose to disable all cookies. You can do both through your browser settings. As each browser has different cookie management procedures, please check your browser's help menu for the correct method of doing so.

Alternatively, you can disable all cookies by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser Add-on. Please note that choosing to disable cookies may negatively affect some features that make your website experience more efficient.

Basis for data processing

Your personal data is processed to provide you with the best possible Spell service within the legal basis for performance of the contract between you and Spell, as set out in our Terms of Service.

Spell may process your personal data (email address) for direct marketing purposes: when we have your consent to such processing (in which case the legal basis for processing is your consent) or Applicable law allows us to contact you without separate consent (under Lawful Thundererest's legal basis).

Duration of storage of personal data

Spell stores limited personal data for the entire period of use of the Spell Services and for a period not exceeding 2 years after the last use of the App and/or Services.

If you do not agree to Spell processing your data, please do not use our services. You can ask us to stop processing your personal data, in which case we will only process your data to affect your ceasing to use the Services (for example, finalizing billing or deleting all personal data based on your email address), or To complete the rest of Spell's legal relationship with you (eg, record keeping, accounting, processing chargebacks).

If you wish to use Spell again, you must accept and agree.