PRIVACY POLICY

(regarding the processing of personal data of users of the mobile application and website)

This privacy policy (the Policy) defines the procedure and conditions for the processing of personal data of users of the mobile application and website https://ogonvpn.xyz (together, the Service) when providing services offered by ogonvpn.xyz (the Operator).

By using the Service, the User confirms acceptance of this Policy. If the User disagrees with any of its provisions, use of the Service must be discontinued.

1. Terms and definitions

1.1. Personal data means any information directly or indirectly related to an identified or identifiable User, provided during registration, payment and subsequent use of the Service.

1.2. Operator means ogonvpn.xyz, which processes Users' personal data.

1.3. Processing of personal data means any action or set of actions performed with personal data, with or without automation tools, including collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion and destruction.

1.4. User means an individual or legal entity using the Service.

1.5. Cookies mean small data fragments automatically transmitted by the User's device to the Service and used to ensure functionality, personalization and ease of interaction.

2. General provisions

2.1. The Policy is developed in accordance with Federal Law No. 152-FZ "On Personal Data", Federal Law No. 149-FZ "On Information, Information Technologies and Information Protection", and other applicable legal acts of the Russian Federation.

2.2. The Policy applies to all information about Users that the Operator may obtain through the use of the Service, including the mobile application, website, personal account and other Operator-owned services.

2.3. By continuing to use the Service, the User unconditionally accepts the terms of the Policy. If the User disagrees with the terms, use of the Service must be discontinued.

3. Categories of processed data

3.1. The Operator may process the following categories of personal data: — email address; — data provided during registration and/or subscription purchase; — technical information, including IP address, device type and model, operating system version, session data and network connection details; — payment details to the extent necessary for transactions, in anonymized and/or partial form through payment processors; — information provided when contacting support.

3.2. The Operator does not collect or store internet traffic content, correspondence, passwords or other confidential user data.

3.3. Anonymous statistical data may be used for analytics and for improving the Service.

4. Purposes of processing personal data

4.1. Personal data is processed for: — account registration and access to Service functionality; — performance of obligations under the public offer agreement; — ensuring correct and stable operation of the Service and its features; — providing technical and customer support; — informing Users about changes in functionality, terms and pricing; — compliance with applicable laws of the Russian Federation.

5. Legal grounds for processing

5.1. Personal data is processed on the following grounds: — User consent; — conclusion and performance of an agreement with the User; — compliance with legal requirements; — the Operator's legitimate interests, including ensuring information security of the Service.

6. Processing and storage conditions

6.1. Personal data is stored in a form that allows identification of the data subject for no longer than required by the stated processing purposes.

6.2. Processing is carried out using organizational and technical security measures that comply with the legislation of the Russian Federation.

6.3. Transfer of personal data to third parties is allowed in the following cases: — when such transfer is necessary for performance of the agreement, including transfers to payment organizations and processors; — when required by law; — when anonymized statistical data is provided to partners.

7. User rights

The User has the right to: — receive information about their personal data and the purposes and conditions of processing; — request clarification, blocking or deletion of data if it is incomplete, outdated or processed unlawfully; — withdraw consent to processing of personal data; — appeal the Operator's actions or omissions to the competent authority for personal data protection or to a court.

To exercise these rights, the User may contact: 📩 Email: support@ogonvpn.xyz

8. Cookies and analytics

8.1. The Service may use cookies for: — ensuring basic functionality and security; — saving user settings and preferences; — analyzing interactions with the Service to improve quality.

8.2. The User may independently disable cookies in browser or device settings. Some Service functions may then become unavailable.

9. Personal data protection

9.1. The Operator applies legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution and other unlawful actions.

9.2. Access to personal data is granted only to authorized employees who are obliged to maintain confidentiality.

10. International data transfer

10.1. If server infrastructure or counterparties are located outside the Russian Federation, cross-border transfer of personal data may occur.

10.2. Such transfer is carried out only if an adequate level of personal data protection is ensured and applicable legal requirements are observed.

11. Validity period and amendments

11.1. This Policy remains in effect until replaced by a new version.

11.2. The Operator may amend the Policy unilaterally. The current version becomes effective from the moment it is published on https://ogonvpn.xyz.

11.3. The User is responsible for tracking amendments and reviewing the current version of the Policy.

12. Operator contact details

Website: https://ogonvpn.xyz Email: support@ogonvpn.xyz

RELOCUP LLC, 447009282, Georgia, Kobuleti Municipality, Tsikhisdziri Village, 10th Street, N 2