NetGuardVPN Personal Data Processing Policy
Version dated
Download PDF (Russian)1 Data Controller and Scope
1.1. The personal data controller for the NetGuardVPN service is individual entrepreneur Roman Vladimirovich Korepanov, INN (taxpayer identification number) 180934843380, OGRNIP (primary state registration number for an individual entrepreneur) 326180000069496. For questions about personal data and to exercise your rights, contact support@netguardvpn.com or Telegram https://t.me/netguardvpnhelp.
1.2. This Policy applies to the website https://netguardvpn.com, the web application https://app.netguardvpn.com, and the Telegram bot https://t.me/NetGuardVPN_bot. It describes the processing of data relating to visitors, users, and people who contact support.
1.3. Data is processed in accordance with the applicable requirements of Federal Law No. 152-FZ “On Personal Data” and other mandatory rules. This Policy provides information about processing and does not replace separate consent where such consent is required.
1.4. Telegram and payment providers also process data under their own documents. Using a third-party platform does not give the Controller access to all information processed by that platform.
2 Data Processed
2.1. When you use the Telegram bot or sign in through Telegram, your Telegram ID and username are used. They are necessary to identify your account, link it to a subscription, sign you in, and handle requests.
2.2. When you sign in by email, the email address you provide and the information necessary to verify it are processed. They are used for authentication, linking to your account, and necessary messages about access to the service.
2.3. To set up and maintain a subscription, information is processed about the plan, access period, number of devices, recorded traffic volume, internal balance, renewal settings, referral rewards, payments, and refunds. Payment information may include the transaction identifier, date, amount, status, and payment method.
2.4. When you contact support, the contents of your request, the contact details you provide, and the information necessary to resolve the issue are processed. Avoid sharing secret payment credentials, passwords, or other people’s personal data unless necessary.
2.5. To operate the VPN connection, network traffic is technically transmitted through the selected server infrastructure. Traffic volume is recorded to apply subscription limits. The list of NetGuardVPN website pages visited, collected by website analytics tools, relates to analytics of the website itself, rather than the history of websites accessed through the VPN.
2.6. The website uses Yandex.Metrica and Google Analytics. These services may process cookies and browser identifiers, browser and device information, IP addresses and location information derived from them, referral sources, NetGuardVPN pages viewed, visit times, and actions on the website. The Yandex.Metrica configuration includes click maps and Webvisor.
2.7. The Controller does not request full bank card numbers, CVV/CVC codes, banking passwords, or verification codes in support chats or bot messages. Such information is entered only in the payment interfaces intended for that purpose.
3 Purposes and Grounds for Processing
3.1. Data is used to sign in and identify users, provide and maintain subscriptions, record balances and payments, operate the referral program, handle support requests, refunds, and data requests, analyze website operation, and meet mandatory legal requirements.
3.2. Information necessary to enter into and perform a contract with a user is processed on the basis of that contract and the conditions for such processing provided by law. Accounting and payment records may be processed to meet mandatory legal requirements. Where consent is required, it is obtained separately for the relevant purpose.
3.3. Processing may include collecting, recording, organizing, accumulating, storing, using, updating, making necessary transfers, restricting processing, and deleting data. The volume of data is limited to the purposes for which it was obtained.
3.4. Accepting the public offer, starting the bot, or using the website does not, by itself, constitute consent to any and all processing purposes, optional analytics, or advertising messages. Data necessary for the service and processing based on separate consent are handled separately.
4 Cookies and Website Analytics
4.1. Technical cookies and similar mechanisms may be used to save settings, authenticate users, and operate the interface. Optional analytics serves a separate purpose: assessing traffic and improving the website.
4.2. The use of analytics tools that process personal data requires an appropriate legal basis. Where consent is used, it must be obtained separately before such processing begins. Refusing optional analytics must not prevent users from using the main functions of the service.
4.3. Browser settings allow you to restrict or delete cookies; restricting technical cookies may affect authentication and saved settings. You may withdraw your consent to analytics by contacting the Controller using the details provided. Following withdrawal, processing for which no other lawful basis remains is stopped.
4.4. The analytics services’ documents are available at https://yandex.ru/legal/metrica_termsofuse/ and https://policies.google.com/privacy?hl=ru.
5 Data Recipients
5.1. To the extent necessary for the selected function, information may be received by payment providers, infrastructure providers, technical contractors, and Telegram when its interfaces are used. Payments are handled through connected providers, including CloudPayments and RollyPay.
5.2. When website analytics is used, the relevant technical information is received by Yandex.Metrica and Google Analytics. The Controller takes into account the separate purposes of such processing and the requirements regarding its legal basis.
5.3. Data may be provided to authorized bodies where required by law and where an appropriate basis exists. Making users’ data publicly available is not a purpose of processing under this Policy.
5.4. Data transfers and the appointment of third parties to process data are carried out in accordance with applicable legal requirements. Additional consent or another action required by law is obtained or performed where necessary for a particular transfer.
6 Storage and Protection
6.1. Data is processed for as long as necessary for the relevant purpose. Account and subscription information is used to provide the service; support requests are used to resolve the issue and related claims; mandatory accounting records are retained for the period prescribed by law.
6.2. After use of the service ends, further processing is permitted only where a legal basis exists, including mandatory accounting, payment settlement, and handling claims. When the purpose of processing has been achieved or an obligation to stop processing arises, the conditions and time limits for destroying data prescribed by law apply.
6.3. The Controller takes the necessary organizational and technical measures to prevent unlawful access, alteration, disclosure, and loss of data. Access is provided to the extent necessary to perform the relevant tasks.
7 User Rights
7.1. In the cases provided by law, users have the right to obtain information about processing, correct their data, request restriction or cessation of processing, deletion of data, and withdrawal of consent. Where another lawful basis exists, certain information may be retained after consent is withdrawn.
7.2. Requests can be sent to support@netguardvpn.com or Telegram https://t.me/netguardvpnhelp. Necessary information may be required to verify ownership of the account. Secret bank card details and banking passwords are not required for this purpose.
7.3. Accounts are deleted upon a request to support. If there is an active subscription or a monetary balance, support will coordinate the termination of service and refund matters. Certain accounting records are retained where required by law.
7.4. Requests are reviewed within the time limits prescribed by law. Users also have the right to contact Roskomnadzor or a court.
8 Policy Changes and Contact Details
8.1. The current version is published on the service’s official resources. If the categories of data or processing purposes change, the information is updated and any necessary new consent is obtained separately. Changing the text of this Policy does not, by itself, create consent to a new processing purpose.
Controller: individual entrepreneur Roman Vladimirovich Korepanov.
INN: 180934843380. OGRNIP: 326180000069496.
Email: support@netguardvpn.com. Telegram support: https://t.me/netguardvpnhelp.