Privacy Policy of FUBBLE VPN Websites

February 10, 2025

Keynote

We are proud to say that we fight for users’ privacy, and we are strongly committed to this principle and to being as transparent as possible.

We believe that privacy is a fundamental human right. That’s why we are transparent about what Fubble VPN does and explain the purpose of every little bit of information that may be gathered by our apps and services.

Who we are

FUBBLE VPN LIMITED (“We”, “Us”, “Our”) processes your data in accordance with this Privacy Policy and in compliance with the applicable data protection laws when you:

Visit websites related to Fubble VPN software and services (hereafter, the “Websites”):
- Fubble VPN website at fubblevpn.com,
Use Fubble VPN Account services at fubblevpnaccount.com (hereafter, the “Fubble VPN Account”).
Use Fubble VPN Affiliate Account services at fubblevpnpartner.com (hereafter, the “Affiliate Account”).

FUBBLE VPN LIMITED is a company registered in Limassol, Cyprus, registered office is at Anexartisias and Athinon 79, Nora Court Flat/Office 203–205, 3040 Limassol, Cyprus. FUBBLE VPN LIMITED acts as the data controller when processing your data.

This Privacy Policy provides you with the necessary information regarding your rights and our obligations and explains how, why and when we process your data. Our general principle is to collect only the information that is necessary to provide you with full functionality of our products and services. We strictly follow the principle of “minimization” when processing your data.

This Privacy Policy does not apply to third-party websites or services that you visit, even if the Websites, the Fubble VPN Account, or the Affiliate Account have links to such third-party websites or services. You should familiarize yourself with privacy policies of third-party websites and services.

If you have any questions about this Privacy Policy or if you want to exercise any of your rights, please contact us at privacy@fubblevpn.com.

PLEASE READ THIS PRIVACY POLICY THOROUGHLY.

IF YOU AGREE AND ACCEPT THIS PRIVACY POLICY, WE WILL PROCESS YOUR DATA STATED BELOW FOR THE DECLARED PROCESSING PURPOSES IN ACCORDANCE WITH THIS PRIVACY POLICY.

IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT VISIT OR USE THE WEBSITES, THE FUBBLE VPN ACCOUNT, OR THE AFFILIATE ACCOUNT, AND DO NOT PROVIDE YOUR INFORMATION TO US.

What data we process

We process different data depending on the situation. You can learn details about what data we process in this section.

Some data that we receive and process may be treated as personal data (“Personal Data”) in accordance with the laws of certain territories and countries. When we use terms “personal data” or “personal information”, we mean any information relating to an identified or identifiable natural person, excluding any anonymized and depersonalized data where your identity is absent or has been removed and cannot be recovered.

When you visit the Websites, the Fubble VPN Account, or the Affiliate Account and their subdomains, we process the following information obtained by our web server to provide you with the content you request: IP addresses in anonymized form, timestamp of the server request, type and version of your web browser, name and version of your operating system, requesting domain (URL), address of the previously visited page (referrer URL), host name.

When you visit the Websites

You can visit and use the Websites for informational purposes without having to provide any personal data. However, to provide you with certain functionality of our Websites listed below, we need to process some of your personal data. Without such processing, we will not be able to provide you with such functionality of our Websites.

Sending messages. We may use your email address to communicate with you when we need to make announcements, inform you of updates and new features in our software or services, provide you with advice, and communicate with you when you report errors.
You may also give us your consent to process your email to send you marketing messages about other Fubble VPN software or services. You may withdraw your consent at any time by unsubscribing from our newsletter via the Fubble VPN Account or by clicking the “Unsubscribe” button or link in the email itself.
Buying a license. We process your email address for billing and payment purposes. If you buy a subscription to Fubble VPN software, we’ll use the email address you provide to send you information about the purchase, such as your subscription status and renewal notifications (if applicable), and to recover your license key if you request it.
We conduct all transactions via two payment providers — Paddle.com Inc. and PayPro Global — to process payments when you purchase a subscription to use our software and services. Processed data: your email address, country of residence, zip/postal code, and if you use a bank card to make a purchase, the card number, name, expiration date and the security code associated with the bank card. Paddle privacy policy: www.paddle.com/legal/privacy. PayPro Global privacy policy: docs.payproglobal.com/documents/legal/privacyPolicy.pdf
The third-party service provider may transmit some of your personal data to us, but not including payment information, unless you specifically agree (as may be the case if you purchase a subscription with auto-renewal). We may use the information to verify your registration or subscription status, or for renewal of your subscription, if applicable.

When you use the Fubble VPN Account

To use our Fubble VPN Account, you need to register your account and sign in.

Registering your account. We process your email address and a hash of the password you use for authorization. That ensures that you can retrieve your password if needed.
If you choose to register your account using your third-party account, such as a Google, Apple, or Facebook account, we will process an authentication token to prove your identity. Fubble VPN does not request or have access to your third-party accounts.
Sending messages. To keep you informed about the operation and new features of the Fubble VPN Account, we will process your email address.
To receive newsletters and promotional emails about the Fubble VPN software, you can opt-in and subscribe to the newsletters. You can withdraw your consent at any time by unsubscribing in your account settings or by clicking on the appropriate link in the email you receive.
Data processing during the use of the Fubble VPN software as well as the sections of the Fubble VPN Account related to the Fubble VPN software is governed by the privacy policies of the respective software.

When you use the Affiliate Account

To use our Affiliate Account, you need to register your account and sign in.

Registering your account. We process your username, email address, and a hash of the password you use for authorization.
Processing your payouts. To process payments via the payout method you have chosen, we will process the email address you indicate as an account identifier of a third-party payment service to which you want to receive your payouts.
We conduct all transactions via third-party payment providers. To process payments via the payout method you have chosen, we will share some of your personal data with a third party payment service to which you want to receive your payouts.
- (a) If you choose PayPal as your payout method, Fubble VPN will share the email address you indicate with PayPal (Europe) S.à r.l. et Cie, S.C.A.. PayPal privacy policy: www.paypal.com/cy/webapps/mpp/ua/privacy-full.
- (b) If you choose Mellow as your payout method, Fubble VPN will share the email address you indicate with TMS SolarWeb Ltd. Mellow privacy policy: www.mellow.io/documents/privacy-policy.
Fubble VPN does not request or have access to your accounts in third-party payment services.
Processing data of users referred by you and by your affiliate referrals. To properly calculate your commission when a subscription to the Fubble VPN software is purchased or renewed by a user referred by you or by your affiliate referral, we will process the email address used to create the user’s account in the Fubble VPN Account and username and email address of your affiliate referral.
Sending messages. To keep you informed about the Affiliate Account and the Fubble VPN affiliate program, we will process your email address.
Providing support. To assist you, we process the information you share when submitting a support ticket. Please note that in most cases, we do not need any additional personal information to provide you with support.

Use of cookies

We use our cookies to personalize the content and facilitate your use of the Websites, the Fubble VPN Account, and the Affiliate Account, such as setting the default language.

Cookies are small text files with parameters and their values that your web browser stores on your device. Some cookies are only stored for the duration of your current browsing session, some cookies may be stored for longer.

None of the information we may collect through cookies is considered Personal Data as it does not allow us to identify you. You can always disable or clear cookies in your browser, but please note that some of our services may not function properly without the aid of cookies.

We do not use any javascript-based tracking or cookies. Instead, we use our server logs (i.e. information about what pages were requested) to measure how people use our website. We do not use raw logs, instead raw logs are aggregated to build general reports for us.

What legal bases we use to process your Personal Data

We use different legal bases to process Personal Data, depending on the type of data involved and the purposes and circumstances of processing.

Consent. We process your Personal Data if you have provided us with your consent to use your Personal Data for certain purposes. For example, to send you marketing emails. You can withdraw your consent any time without any detriment to your use of the Websites, the Fubble VPN Account, or the Affiliate Account.
Performance of a contract. We process your Personal Data when it is necessary to fulfill our contractual obligations to you, including providing the functionality of our software and services or at your request prior to entering into a contract with you.
Legal obligations. We process your Personal Data where it is necessary for compliance with our legal obligations, such as to exercise or defend our legal rights, or for taxation purposes.
Legitimate interest. We process your Personal Data when we pursue our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of data subjects.

Where we process your Personal Data

We store your Personal Data in our own data center located in Frankfurt, Germany. Your Personal Data may be processed by our employees, who can only access your data on a need-to-know basis as part of their job duties. If you have any questions or would like to know from which countries access may be possible, you can write to us at privacy@fubblevpn.com.

When we transfer data to other countries, we always implement appropriate safeguards to ensure that your Personal Data always remains safe and that your rights are respected:

The country or the third party is recognized as providing adequate protection.
A valid transfer mechanism, such as the Standard Contractual Clauses, is applied. Additional measures are taken where necessary.
The transfer has your explicit consent.
The transfer is necessary to perform a contract with you or to take steps requested by you prior to entering into that contract.

If you wish to obtain a copy of the Standard Contractual Clauses used, please contact us at privacy@fubblevpn.com.

To determine if a non-EU country has an adequate level of data protection, please visit commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.

How we use your Personal Data

Retaining your data

We will retain Personal Data for as long as necessary to provide you with our products and services, or until you revoke your consent to share this information.

Your rights

In some countries and regions, you may have certain rights in relation to your Personal Data under applicable data protection laws.

If you wish to exercise your rights with respect to your Personal Data, please contact us at privacy@fubblevpn.com. We will consider and act upon any request in accordance with applicable data protection laws. We may ask you to further confirm your identity and will respond to you within the time period specified by applicable data protection law. Please note that we may charge you a reasonable fee for processing your request or refuse your request in certain cases specified by applicable data protection laws.

You are entitled to exercise the following rights in relation to your Personal Data:

Right of access: the right to obtain all your Personal Data we store. In some cases, the right of access may be limited for technical reasons, including if the data has been anonymized and cannot be linked to any data subject.
Right to erasure or right to be forgotten: the right to have your Personal Data completely deleted. You can delete your data related to your Fubble VPN Account and Affiliate Account accounts yourself via the settings of these accounts. Alternatively, you can send us a request at privacy@fubblevpn.com.
Right to rectification: the right to correct any incomplete or inaccurate Personal Data about you. We will do so as quickly as possible, unless there is a valid reason not to, in which case you will be notified.
Right to restriction: the right to impose restrictions on processing of your Personal Data.
Right to object: the right to object to processing of your Personal Data.
Right to data portability: the right to receive provided Personal Data in a structured, commonly used and machine-readable format and to transmit that data to another controller. You can export all your Personal Data related to your Fubble VPN Account to a local file from in the Fubble VPN Account settings.
Right not to be subject to a decision based solely on automated processing, including profiling.
Right to withdraw a consent where the data processing is based on the consent.
Right to lodge a complaint with a data protection authority. You can find the contact details of our data protection authorities here: www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/contact_en/contact_en?opendocument.

If we receive your Personal Data from a third party, we will use reasonable efforts to inform you about it.

Safeguarding measures

We make every possible effort to protect you and your Personal Data from unauthorized access, alteration, disclosure, or destruction. We implement and maintain the following technical and security measures:

System access controls: We take reasonable measures to prevent Personal Data from being used without authorization. These controls shall vary based on the nature of the processing undertaken and may include, but are not limited to, authentication via passwords and/or two-factor authentication, documented authorization processes, documented change management processes and/or logging of access on several levels.
Data access controls: We take reasonable measures to ensure that Personal Data is accessible and manageable only by properly authorized staff. Direct database query access is restricted and application access rights are established and enforced to ensure that individuals entitled to use a data processing system only have access to the Personal Data to which they have access privileges; and that personal data cannot be read, copied, modified, or deleted without authorization in the course of processing.
Storing data in a data center: Personal information is stored in our own data center located in Frankfurt, Germany. This is secure: the data center does not demand that we collect any data about your traffic or your use of our products and services. If they request us to start doing so, we will stop working with them and find an alternative.
Transmission controls: We take reasonable measures to ensure that it is possible to check and establish to which entities the transfer of personal data by means of data transmission facilities is envisaged so personal data cannot be read, copied, modified, or removed without authorization during electronic transmission or transport.
Input controls: We take reasonable measures to make it possible to check and establish whether and by whom personal data has been entered into data processing systems, modified, or removed.
Data backup: Databases are backed up regularly. They are secured and encrypted to ensure that personal data is protected from accidental destruction or loss while hosted by us.
Logical separation: Personal Data is logically segregated on our systems to ensure that Personal Data collected for different purposes can be processed separately.

Consequences of not providing your Personal Data

You are under no obligation to provide your Personal Data to us. However, because this information is necessary for us to provide you with our services or respond to your requests, we will not be able to provide some or all of our services without it.

Age limitations

To the extent not prohibited by applicable law, we do not allow the use of the Websites, the Fubble VPN Account, or the Affiliate Account by anyone under the age of 18 years. If you learn that anyone younger than 18 has unlawfully provided us with Personal Data, please contact us and we will take steps to delete such information.

Do Not Track

We respect your right to privacy and therefore respect the Do Not Track (“DNT”) settings in your web browser. If you have DNT enabled in your web browser, any analytical tools, including first-party, will not be loaded and used on the Websites, in the Fubble VPN Account, and in the Affiliate Account.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time and notify you of any important changes. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes on this page and encourage you to review our Privacy Policy to stay informed.