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Privacy Policy

Last updated: March 24th, 2023

This document (“Privacy Policy”) explains the privacy rules

applicable to all information collected or submitted when you

access, install, or use 360 VPN HOTSPOT.

All definitions and capitalized words used in this Privacy Policy

are defined here or in our General Terms.

By visiting our websites, 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 this Privacy Policy. If you disagree with the rules of this

Privacy Policy, please do not use our Services.

Information in this Privacy Policy is provided in layers, meaning

that all information related to our general personal data

processing practices is provided here. Meanwhile, additional

Service-specific information applicable to separate 

360 VPN HOTSPOTproducts or websites are accessible via links in this Privacy


Processing of your data

processes user data to a limited scope – for

provision of the Services, processing payments for the Services,

as well as the functioning of our websites and mobile applications.

We process the following basic information:

Information for creating your account

Email address. We ask for your email address as part

of your registration. It is necessary for establishing a 360 VPN HOTSPOT

account, retrieving a lost password, and using

our Services.

Payment related information

Payment data (if using paid Services). This information

is necessary to collect payments for our Services. In addition


to the traditional payment methods, such as credit cards,

users can buy our Service with cryptocurrency. Our payment

processing partners process basic billing information for

payment processing and refund requests (such as date of

purchase, payer’s IP address, zip code, card owner's full

name and credit card information). We also process some of

the same payment information ourselves (e. g., card owner's

full name, last few digits of your credit card) in cases of

recurring payments.

Country details. When providing your payment details,

we ask our users to provide the country where they are

registered, have a permanent address or usually live. This

information is necessary for VAT calculation purposes.

Communication data

Email address. We use your email address to: i) send

you important updates and announcements related to your

use of our Services; ii) respond to your requests or inquiries;

iii) send you offers, surveys and other marketing content

(you can opt-out of those at any time).

Communication optimization data. We use various tools

to help us optimize our emailing campaigns. These tools

may track events you perform with an email, such as open

and unsubscribe. We may also be able to see the user

device’s operating system (e.g., windows, mac, ios, android)

in order to optimize push notifications.

Chat-bot. If you contact us via our chat-bot on our

website, in addition to collecting your contact information, we

will be able to see your IP address. This additional

information is necessary for our support to determine the

user's country and to see if the user is connected to our

servers or not.

Information collected on our website

Access logs. As most websites on the internet, our

website collects access logs (such as IP address, browser

type, operating system) to operate our services and ensure

their secure, reliable, and robust performance. This

information is also essential for fighting against DDoS

attacks, scanning and similar hacking attempts.

Cookies. Cookies, pixels and other similar technologies

are usually small text or image files that are placed on your

device when you visit our website. Some cookies are

essential for our website to operate smoothly; others are

used to improve website functionality or analyze aggregated

usage statistics to improve website performance (as in the

case of Google Analytics cookies). We also use affiliate

cookies to identify the customers referred to the website by

our partners so that we can grant the referrers their

commission. You can check what cookies we use in the

detailed cookie table that is accessible here.

Additional information per product

As our products cater to different user needs, they may collect

different data points during their performance. The following links

provide further information on:


Sharing your personal data

We do not share your personal information with third parties

except as described in this Privacy Policy.

Service providers. We use third-party service providers to help us

with various operations, such as payment processing, email

automation, website and app diagnostics, analytics and other. As

a result, some of these providers may process personal


Some of our main long-term service providers:

Live chat and support service platform – Zendesk

(provided by Zendesk Inc.);

Emailing service providers – Iterable (by Iterable Inc.),

Sendgrid (by Twilio Inc.);

Application analytics and diagnostics – Google

Analytics, Firebase Analytics (provided by Google);

AppsFlyer (by AppsFlyer Ltd.), Bugsnag (by Bugsnag


Conversion attribution system – Hasoffers (provided by

Tune Inc.);

Sometimes our service providers, for example, distributors,

resellers, and app store partners, will be independent controllers

of your data. Their terms and conditions and privacy policies will

apply to such relationships.

Your personal information may be processed in any country in

which we engage service providers. When you use our Services,

you acknowledge the transfer of your personal information outside

of the country where you reside.

Requests for data. Any request for user data should follow an

appropriate official legal process to be recognized by the laws of

the United States (e.g., mutual legal assistance treaty, letters

rogatory). We carefully review each request to make sure it

satisfies laws applicable to our company, laws of requesting

country, international norms and our internal policies. Being based

in United States allows us to keep no logs of users’ online activity

(no IP addresses, browsing data, traffic information, etc.). This

means that we are unable to link an individual user to a specific IP

address, connection timestamp or other information that we do

not collect. Therefore, even in cases we receive a rightfully served

request, it might be impossible for us to identify a specific person

or provide any identifying information related to that person. In

cases where, following an appropriate legal process, we are able

to identify a specific person, we will provide the limited data we

process as per our Privacy Policy. Contact information for

government authorities: 360 VPN HOTSPOT 

2135 E Independance Ave

#1017 Springfield, MO 65807


Choices related to your data

If you’d like to edit your profile information, delete your account or

data, or request to provide you with a copy of your personal

information, please contact our support team. Please note that

you may need to pass through a couple of account verification

steps so that we can verify you are the owner of the account.

If you wish to unsubscribe from our communication, you can opt

out at any time by clicking the unsubscribe link at the bottom of

each message or contacting us at SUPPORT@360VPNHOTSPOT.COM

You can control the use of cookies at the individual browser level.

To disable cookies, follow your browser’s instructions on how to

block or clear cookies.

Some browsers have incorporated a “do-not-track” feature that

can send a signal to the websites you visit, indicating you do not

wish to be tracked. Currently, our systems do not recognize

browser “do-not-track” requests.

If you disagree with the processing of your data by 360 VPN HOTSPOT

please do not use our Services. You can request us to

discontinue processing your personal data, in which case your

data will be processed only as much as it is necessary to effect

the discontinuation of your use of the Services (e.g., final

settlement, or deleting all personal data based on your email

address), or finalizing other 360 VPN HOTSPOT legal relationship

with you (e.g., record keeping, accounting, processing refunds).

If you wish to use the Services again, you will have to accept and

agree to this Privacy Policy anew.

Data security

We take data security very seriously and take all steps reasonably

necessary to secure your data (whether technical, physical, or

administrative). However, no company can guarantee the

absolute security of internet communications. By using the

Services, you expressly acknowledge that we cannot guarantee

the security of any data provided to or received by us through the

Services and that any information received from you through the

website or our Services is provided at your own responsibility.

Information for users in the European Economic Area (EEA)

The European Union's General Data Protection Regulation

(“GDPR”) requires that we provide notice in a specific way to our

European users about their privacy rights. Please find all the

necessary information here

Information for users in California

If you are a California resident, you can implement your rights as

provided in the California Consumer Privacy Act (CCPA) by

contacting us at SUPPORT@360VPNHOTSPOT.COM.  As per definitions

in the CCPA, please note that 360 VPN HOTSPOT does not sell

your personal information.

Other Terms

The Privacy Policy is governed by and shall be construed in

accordance with the laws provided in our General Terms.

To ensure the security of personal data, 360 VPN HOTSPOT

employs various administrative, technical and physical security

measures; however, it is your responsibility to exercise caution

and reason when using the Services. You will be personally

responsible if such action violates any third party’s privacy or any

other rights, or any applicable law. Under no circumstances is

360 VPN HOTSPOT liable for the consequences of your unlawful

activities, your willful and negligent activities that violate

applicable laws or third-party rights, and any circumstances that

may not have been reasonably controlled or foreseen.

Our website may include links to other websites whose privacy

practices may be different from ours. If you submit personal

information to any of those sites, your information is governed by

their privacy policies. We encourage you to carefully read the

privacy policy of any website you visit.

This Privacy Policy may be modified and updated at any time, at

our sole discretion, for any or no reason, and without liability, as

indicated below. The date of the most current wording of the

Privacy Policy is indicated at the top of the text. We ask all users

to ensure that they are familiar with the most current wording of

the Privacy Policy. The amendment of the Privacy Policy may be

communicated to you by sending an email and/or by publishing

the updated Privacy Policy on this website. Updates of the

Privacy Policy come into force as of the moment when they are


You may not assign or transfer your rights or obligations under

this Privacy Policy to any third party.

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