VPN Privacy Policy

Effective Date: September 16, 2024

Sensor Tower, Inc. (“Sensor Tower”, “we”, or “us”) is honored to provide Phone Guardian, My Data Manager, Luna VPN and Adblock Mobile (collectively the “App”), as well as the website and affiliated pages (the “Website”; the Website and the App are together referred to as the “App”), which help provide a better, faster Internet and app experience. When using the App, you may consent to us collecting some of your personal information.

The purpose of this Privacy Policy is to provide you with a clear understanding of what personal information we have access to when you use the App, as well as what personal information may be collected when you allow us to collect usage data, how your personal information is used, and the choices you have to control the collection and/or use of your personal information. We are committed to communicating transparently, providing security, and protecting the privacy of data on our systems.

Contact Information

If you have any questions, comments, or concerns about your personal information, this Privacy Policy, your privacy, or any of our privacy practices, please contact our Data Protection Officer by email at data-protection@sensortower.com or by mailing correspondence to Data Protection Officer at Sensor Tower, Inc., 2261 Market Street #4331, San Francisco, CA 94114.

Overview

This Privacy Policy explains how Sensor Tower collects, stores, uses, transfers and shares your personal information in connection with the App, which may be available for download from the Google Play (TM) store or the App Store (R).

We may and reserve the right to update this Privacy Policy to reflect changes in and to keep you informed about our privacy practices. Please periodically review the App or the relevant Google Play(TM) store page for the latest information on our privacy practices.

If we make any changes, we will notify you by contacting you through the App, by posting a notice on the App, by posting a notice on our Google Play(TM) store or App Store ® page for the App, or by some combination of these methods. If you continue to use the App after the Privacy Policy has been updated, this continued use will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to explicitly accept changes to the Privacy Policy.

If you do not accept the terms of the Privacy Policy, please discontinue using the App immediately.

Personal Information We Collect About You

Local and Services Data

When you install the App, a randomly generated unique identifier (“Generic ID”) is used to distinguish your installation of the App from installations of the App by other users.

Upon installation, you will be explicitly asked to grant the App permission to access your device’s VPN services. Additionally, on Android devices, My Data Manager and Phone Guardian will ask you to grant permission to access your device’s usage data service. In this document, the usage data and VPN services are collectively referred to as (“Device Services”).

Using the Device Services, we collect non-personal ad and app-related information (“Services Data”) from your device.  The non-personal Services Data we collect is designed to not include information that could uniquely identify you. 

Rather, the Services Data may contain app and ad-related information including without limitation ads, ad context, ad interactions, ad metadata, app usage data, website usage data, informational queries, and product and service e-commerce information such as information about orders, transactions, promotions, subscriptions, bills, shipments, and the like. 

We may also prompt you to verify your birth year and demographic information using an in-App survey such as your gender, salary range, education level, etc. (“Survey Data”). We index the Services Data and Survey Data using the Generic ID so as to keep it deidentified and unassociated with your personal identity.

The App locally processes the Services Data and Survey Data to provide various features and functionality to you. You are entirely free to decide whether or not to grant the App access to the Device Services, and can revoke this permission at any time in the App, although doing so may make it infeasible for the App or a feature of the App to function properly.

Collected Data

The App never extracts your name, email, username, handle, phone number, or any of your other personal identifiers that you may use to identify yourself.

The personal information we receive via the App may include:

• Services Data;

• Survey Data;

• your IP address;

• the Generic ID;

• your device type;

• your browser version; and

• your country; (the “Collected Data”)

Any personal information is de-identified upon collection using the Generic ID associated with the installation of the App. If you uninstall the App, any data that was collected becomes permanently anonymized.

Upon receiving any Collected Data, our policy is to delete your IP address from our logs within hours of receipt, unless an error is being debugged, in which case it is deleted upon resolution of the error. When stored, the Collected Data is pseudonymized using your Generic ID. 

Special Category or Sensitive Personal Data

We never receive or process any of your sensitive personal information, such as specific information regarding your sexual orientation, ethnicity, religious affiliation, refugee status, health, or finances (other than general purchase-related information as noted above).

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How We Use Your Personal Information

Basis for Processing

We may process your personal information for the purposes described in this Privacy Policy, with your consent; when we have assessed it is necessary for the purposes of the legitimate interests pursued by Sensor Tower or a third party to whom it may be necessary to disclose information; or to comply with a legal obligation. If you have questions about these legal bases you can contact our Data Protection Officer.

Purposes of Processing

We may use your personal information for the following purposes:

• to operate, maintain, debug, and improve the App;

• to send you technical notices, updates, security alerts and support and administrative messages;

• to respond to your comments, questions and requests and provide customer service;

• to monitor and analyze trends and usage of the App;

• to power and sell, in an anonymized form, other products and services, such as the Sensor Tower available at sensortower.com;

• to use, in an anonymized form, in training of neural networks and artificial intelligence;

• for scientific and academic research purposes; and

• for any other purposes indicated in this Privacy Policy.

Data Minimization and Purpose Limitation

We will not process your personal information in a way that is incompatible with the purposes for which it has been collected or collect any personal information that is not needed for these purposes.

No Sale of Personal Information

We do not and will never sell your personal information to advertising platforms, data brokers, or information resellers. We will also never sell your personal information as may be defined by applicable laws.

Use of Anonymized Information

We may anonymize information from the Collected Data ("Anonymized Information") and use the Anonymized Information for any purpose. For example, we may use Anonymized Information to generate,validate, and sell the Anonymized Information and insights about app ecosystems that we provide on our website at app.sensortower.com. We may provide Anonymized Information to third parties, although third parties that receive Anonymized Information cannot use the Anonymized Information to personally identify you. Some third parties are our customers or partners, and others are our service providers that perform services on our behalf to help us provide, understand, or improve the Apps, help host our services and databases, perform analyses or research, send communications on our behalf, or measure the effectiveness of our advertising. 

Use of Contact Information

In situations where you consensually provide us with contact information for the sole purpose of communicating with us, we may use your information to respond to your communications and send you information you request.

Sharing of your Personal Information

We may share your personal information in the following circumstances:

Service Providers

We will share personal information with third parties who perform services on our behalf or operate our services. For example, we share personal information with our vendors (e.g., data processors, IT services providers, cloud providers, online platforms, debugging platforms, support providers, etc.), partners and consultants. Service Providers can only use the personal information we share with them for the limited purpose under which it was shared.

Other Circumstances

Additionally, from time to time, a situation may arise where we may share personal information with third parties including:

• With Your Consent.

• To Enforce Our Terms of Service.

• To Prevent Unlawful Activities and Misuse of the App.

• With Third-Parties To Protect Our Legal Rights, When Required By Law, or as Necessary to Protect Us or the App. We may access, use, preserve, and share your information with third parties when we have a good faith belief that it is necessary to: detect, prevent and address fraud and other illegal activity; protect ourselves, you and others, including as part of investigations; or prevent death or imminent bodily harm. We may also share such information if we believe that you have abused your rights to use the App, are using the App illegally, or violated an applicable law, or in connection with any dispute between you and us with respect to the App.

• In Response to a Legal Request. We may also access, use, preserve, and share your information,in response to a legal request if we believe in good faith that the response is required by law in that jurisdiction, applies to users in that jurisdiction, and is consistent with internationally recognized standards. Information we receive about you may be accessed, processed, and retained for an extended period of time when it is the subject of a legal request or obligation, government investigation, investigation concerning possible violations of our terms or policies, or otherwise to prevent harm.

• In Connection With a Transfer of Assets. If we sell all or part of our business, make a sale or transfer of assets, are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may confidentially disclose and transfer your personal information to one or more third parties as part of that transaction.

• Other Disclosures. We also may disclose personal information as described to you at the point of collection or pursuant to your consent.

Retention of your personal information

When you use the App

The personal information we collect from you, as described above, is pseudonymized when collected and is retained for as long as needed to accomplish the purposes provided in this Privacy Policy. At any time, you can request that we erase any personal information that we have collected as outlined in the “Your Rights” section of this Privacy Policy.

When you delete the App

If you delete the App from your device, your Generic ID is permanently disassociated with that instance of the App and any of your personal information will become Anonymized Information. You should be aware that we may retain any such Anonymized Information after you have deleted the App. We reserve the right to use the Anonymized Information after you have deleted the App.

Your Rights

With us, you have rights and control over your personal information regardless of the country you live in. Many of these important rights are afforded by Europe's and the UK's General Data Protection Act (GDPR), which include:

• The right to be informed about the collection and use of your personal information, which this Privacy Policy provides.

• The right to access your personal information (called a “subject access request” under the GDPR), which you can do by sending an email to our Data Protection Officer using the contact information provided above. Please note that since we pseudonymize data collected from you, we may need some additional information from you in order to re-identify your personal information. Also, if you have uninstalled the App, any data collected from you will have been anonymized and will not be re-identifiable.

• The right to have any data that is inaccurate or incomplete rectified by correcting or completing it.

• The right to erasure (a.k.a., “be forgotten”) by sending an email to our Data Protection Officer using the contact information provided above and requesting that we delete your personal information. Please note that since we pseudonymize data collected from you, we may need some additional information from you in order to locate and delete your personal information. Also, if you have uninstalled the App, any data collected from you will have been anonymized and we will be unable to locate it.

• The right to restrict the processing of your personal information under certain circumstances provided by Article 18 of the GDPR.

• The right to obtain and reuse a copy of your personal information for your own purposes.

• The right to object to processing of your personal information under certain circumstances provided by Article 21 of the GDPR.

How to exercise your privacy rights

Contact our Data Protection Officer using the contact information provided above to exercise any of your privacy rights. We commit to grant them within 30 days after receipt or less.

If you reside in Europe or the UK, you can also contact Osano, which has been appointed as our representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, Osano can be contacted in addition to our Data Protection Officer, only on matters related to the processing of personal data. To make such an inquiry, please contact Osano by mail using the contact information below: 

UK Representative

Osano UK Compliance LTD

ATTN: 8QL4

42-46 Fountain Street

Belfast

Antrim

BT1 - 5EF

EU Representative

Osano International Compliance Services Limited

ATTN: 8QL4

3 Dublin Landings

North Wall Quay

Dublin 1

D01C4E0

Formalities to exercise your privacy rights

Please keep in mind that in the case of a vague request we may engage the individual in a dialogue so as to better understand the motivation and content of the request. We may also refuse manifestly unfounded and excessive (repetitive) requests.

We might also require you to prove your identity in some cases. This is made to ensure that no rights of third parties are violated by your request.

Other Items

Notification requirements. We commit to notify you, when it is needed under the law, within a reasonable period of time and your data protection authority within the timeframe specified in applicable law about data breaches related to your personal information.

Data Protection Authorities. Subject to applicable laws, you may have the right to lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with applicable law.

The California Consumer Privacy Act

If you are a California resident, then Under the California Consumer Privacy Act (‘CCPA’) you have certain rights regarding the personal information that we may have collected about you. The following sections disclose the “what,” “how,” and “why” behind any personal information we collect about you, who we share it with, and what your rights are over your personal information.

Personal Information We Collect

As summarized in detail in the Collected Data section above, we collect:

• personal identifiers;

• commercial information; and

• Internet or other electronic network activity information.

Why We Collect Your Personal Information

We use identifiers, commercial information, and Internet or other electronic network activity information in order:

• to operate, maintain, debug, and improve the App;

• to send you technical notices, updates, security alerts and support and administrative messages;

• to respond to your comments, questions and requests and provide customer service;

• to monitor and analyze trends and usage of the App;

• to power, in an anonymized form, products and services, such as the Sensor Tower products and services available at sensortower.com;

• to use, in an anonymized form, in training of neural networks and artificial intelligence;

• for scientific and academic research purposes; and

• to ensure security.

How We Collect Your Personal Information

As further described in the Collected Data section above, we collect identifiers and commercial information directly from you and we collect Internet or other electronic network activity from your usage of the App and its services.

We do not use cookies or web beacons to collect personal information from you or track your activity.

With Whom We Share and Sell Your Personal Information

We do not sell your personal information. We do sell de-identified and/or aggregated consumer information, which does not identify you or any individual person and is not considered personal information by the CCPA (Cal. Civ. Code 1798.140(o)(K)(3)) on sensortower.com as summarized in the Use of Aggregated Information section above.

We may share your personal information under the circumstances outlined in the Sharing of your Personal Information section above.

We may also share personal information for other reasons we may describe to you or as permitted by law.

Your Rights under CCPA

The consumer rights you may have under CCPA include the right to:

• Opt out of the sale of your personal information;

• Request that we disclose information about the personal information collected, used, disclosed or sold;

• Request that we delete personal information collected or maintained by us; and

• Not receive discriminatory treatment for exercising your privacy rights.

Right to Opt out of Sale

We do not sell your personal information. While you have the right to direct us to not sell your personal information, as summarized below, such a request could be moot since we do not sell your personal information.

Right to Request Disclosure

You have the right to request that we disclose to you what categories of personal information we have sold or disclosed for a business purpose about you, and the categories of third parties to whom the personal information was sold or disclosed. Additionally, you have the right to request disclosure of specific pieces of information. Below is a list of the information that you can include in your request.

• the categories of personal information that we have collected about you;

• the categories of sources from which we collected the personal information;

• the business or commercial purpose for collecting or selling the personal information;

• the categories of third parties with whom we share personal information;

• the specific pieces of personal information we have collected about you;

• the categories of personal information that we disclosed about you for a business purpose; and

• the categories of personal information that we have sold about you, as well as the categories of third parties to whom we sold the information.

Right to Request Deletion

You have the right to request that we delete any personal information about you that we have collected from you. Please note that there are exceptions where we do not have to fulfill a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation.

The Right to Non-Discrimination

We will not discriminate against you (e.g., through denying goods or services, or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.

Submitting a Request, Question, or Feedback

If you would like to exercise your right to opt out, right to delete, or right to request disclosure, or if you have any questions or would like to provide feedback on this Privacy Policy or our privacy practices, please email us using the following information and our privacy team will examine your request, question, or feedback and respond to you as quickly as possible. 

Data Protection Officer data-protection@sensortower.com

Shine the Light

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We do not participate in the sharing of your personal information with third parties for the third parties’ direct marketing purposes, so there is no need to opt-out.

Your Rights in Various Other Jurisdictions

Various other states, including but not limited to, Colorado, Connecticut, Virginia, and Utah, have passed laws providing their state residents rights that are the same or similar to those afforded under the CCPA and the GDPR. These rights, which we honor in the same fashion as outlined above, include without limitation rights to:

• Confirm whether we process their Personal Information.

• Access and delete certain Personal Information.

• Data portability.

• Opt-out of Personal Information processing for targeted advertising and sales.

Some states also provide their state residents with rights to:

• Correct inaccuracies in their Personal Information, taking into account the information's nature processing purpose.

• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Outside of the US, if you are a resident of another country, state, or province with applicable data privacy laws and regulations that afford you with privacy rights similar to those afforded by the GDPR, CCPA, or other similar laws or regulations, we will honor any requests from you to exercise those privacy rights in accordance with those data privacy laws and regulations to the extent possible.

“Do Not Track” Requests

We adhere to the standards set out in this Privacy Notice and do not monitor or respond to Do Not Track browser requests.

Security of your Personal Information

We maintain reasonable and appropriate safeguards to protect all collected personal information against loss, misuse, theft, unauthorized access, disclosure, alteration, or destruction. While we strive to protect your information and privacy, no data transmission or storage can be guaranteed to be 100% secure. We cannot guarantee or warrant the security of information you disclose or transmit to us and cannot be responsible for the theft, destruction, misuse, unauthorized access, alteration, or inadvertent disclosure of your information.

If we become aware of a security systems breach, we will attempt to inform you by posting a notice, publishing a press release, notifying you via the App, or other appropriate means, and will take appropriate steps to remedy the breach in compliance with any applicable laws and as specified in this Privacy Policy.

Children’s Privacy

General age limitation. We are committed to protecting child privacy. The App is not intended for children and we do not intentionally or knowingly collect information, personal or otherwise, about individuals under the age of 18, much less children under 13 years old. If you are aware of anyone under 18 using the App, please contact us using the contact information provided above and we will take required steps to delete any such information and/or prevent that individual from accessing the App.

Age limitation for EU residents. To the extent prohibited by applicable law, we do not allow use of the App by EU residents younger than 18 years old. If you are aware of anyone younger than 18 using the App, please contact us using the contact information provided above and we will take required steps to delete any such information and/or prevent that individual from accessing the App.

Storage and International Transfers

Sensor Tower is based in the United States of America (U.S.) and the personal information we collect is governed by U.S. law. Please be advised that the laws in the U.S. and the laws of other countries may not offer the same protections as the law of your jurisdiction, and may be deemed inadequate relative to your country’s data protection law.

Further, you agree that we may store and process your information through third-party or affiliate hosting services in the United States, European Economic Area (“EEA”), and other international jurisdictions. As a result, we, our affiliates, subsidiaries, or agents may securely transfer your information to a jurisdiction with different data protection laws than your jurisdiction. By using the Services, you explicitly and unambiguously consent to the transfer of your information outside of your own country for the purposes described in this Privacy Policy.

Third-party Data Processors

We use data processors that perform particular operations with your personal information for us.

Data processors (or just processors) are companies that help us, the Data Controller, run the App, support our communication with you or perform other App-related activities. They may process certain personal information on our behalf to accomplish the goals related to the App functions and associated activities. Data processors act only in accordance with instructions and process only the personal information that we instruct them to process. We are liable for any acts or omissions of our data processors and engage with them under data processing agreements to the extent required by applicable law.

The following is a list of our main data processors:

Changes to this Policy

We keep our Privacy Policy under regular review. This new version was published on September 16, 2024, and supersedes the prior privacy policies that individually or collectively covered Phone Guardian, My Data Manager, Luna VPN, and Adblock Mobile.

Third-party Links

This Privacy Policy may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.