Fort VPN Privacy Policy

Last Updated: August 1, 2024
Effective Date: August 1, 2024
Version Number: 20240801V1.0

COIHUB TECHNOLOGY LIMITED (hereinafter referred to as "Fort VPN", "we", or "our") is the provider and operator of the Fort VPN application software and services (hereinafter referred to as "this software"). We fully respect your privacy rights and will do our utmost to protect your personal information security.

In the process of providing you with products or services (collectively referred to as "this service"), we may collect and use your personal information based on your consent or in accordance with relevant applicable laws and regulations. This Privacy Policy (hereinafter referred to as "this policy") is designed to help you understand how we collect, use, disclose, process, and protect the personal information you provide when using Fort VPN products or services, the rights you have regarding these personal information, and how we maintain these rights.

This policy applies to all products and services provided by Fort VPN, including applications for computers, mobile smart terminals, mini-programs, web pages, software development kits (SDKs) for third-party websites and applications, and application programming interfaces (APIs) or any other form that may appear in the future. It should be specifically noted that this policy does not apply to services provided to you by other third parties.

You may receive content or network links provided by third parties. Please carefully choose whether to access links, content, products, and services provided by third parties. Before submitting personal information to third parties, please read the third party's privacy policy carefully.

To ensure you fully understand this Privacy Policy and make an independent choice, we try to explain it to you in clear and understandable terms and highlight or emphasize key reading content (especially in bold, uppercase, underlined, etc.). We also provide pop-up prompts when you first use our services and guide you to understand the core content of this Privacy Policy.

Please read this policy carefully before using our products or services, submitting personal information to us, or agreeing to our collection of your personal information to understand our practices regarding your personal information. Please visit frequently to learn about updates to this policy.

If this Privacy Policy is updated, we will post a notice on the relevant products or websites to inform you of our updates. If you access or use our services after we issue such a notice, you agree to the updated Privacy Policy. You can confirm the latest update time of the Privacy Policy by viewing the "Last Updated" at the top of this policy.

If you have any questions, please feel free to contact us:
Email: FortVPN@outlook.com

You can also access this Privacy Policy through:
Fort VPN APP > Settings > About > Privacy Policy

Table of Contents

  1. How We Collect and Use Your Personal Information
  2. How We Use Cookies and Similar Technologies
  3. How We Store and Protect Your Personal Information
  4. How We Share, Transfer, and Disclose Your Personal Information
  5. How Your Personal Information is Transferred Across Borders
  6. Your Rights Regarding Your Personal Information
  7. How We Handle Children's Personal Information
  8. Third-Party Service Providers and Their Services
  9. Supplemental and Updated Provisions of This Policy
  10. How to Contact Us

1. How We Collect and Use Your Personal Information

General Overview

Fort VPN believes that basic privacy rights should not vary based on where you live in the world. Therefore, we consider any information that is identified or identifiable to a natural person, especially the natural person's name, identity information, location data, online identifier, or data specific to the natural person's physical, physiological, genetic, psychological, or related data, to be "personal information."

We only collect information necessary for specific, clear, and legitimate purposes and ensure that your information is not further processed in ways that are incompatible with these purposes. If we intend to use your personal information for purposes not explicitly stated in this Privacy Policy, we will seek your consent again.

When collecting your personal information, we will collect it in the following three ways:

  1. Information you provide directly to us (e.g., nickname, avatar, name, phone number you provide when logging in or participating in our marketing activities)
  2. Information we collect automatically during your use of this software (e.g., device information, service log information)
  3. Information we obtain from other sources

You have the right to choose whether to provide personal information when using Fort VPN products or services or when we request it. You are not required to provide personal information to Fort VPN, but in some cases, if you choose not to provide it, Fort VPN may not be able to provide you with related products or services, nor respond to or resolve the issues you encounter.

We will only collect and use your personal information for the purposes described in this policy.

Main Business Functions of Fort VPN and Collection and Use Scenarios

The primary business function of this software is to provide you with VPN proxy connection services.

1.1 To Provide VPN Proxy Connection Services

Fort VPN provides VPN proxy connection services, and the personal information we collect depends on your interaction with us. During your use of this software, we will automatically collect your device-related information to ensure you can use our products and services normally, including:

(1) Device-related information: When you start using this software, we will receive and record your mobile device-related information (including phone model, operating system version information, system language, hardware device identifiers (Google Advertising ID, MAC address, Android ID), Fort VPN version number, and location information of the phone (including the country or region location information of the phone you authorized and network access method)) based on your specific operations in the software and the specific permissions granted by you during software installation and use.

(2) Service log information: When you use the VPN service of this software, we will automatically collect your detailed usage of our services as service logs, including access times, usage duration, event information (errors, crashes, restarts, upgrades), and other log information generated by the device.

Please note that this separate device information and service log information cannot identify specific natural persons. If we combine this non-personal information with other information to identify specific natural persons or use it in conjunction with personal information, this non-personal information will be considered personal information during the combined use period. If we do so, we will anonymize and de-identify such personal information unless authorized by you or required by laws and regulations.

The above information is the basic information necessary to provide services. If you refuse to provide such information, we may not be able to provide you with the relevant services of this software.

Please note that we will also collect the above device information and service log information in various business functions and scenarios of this software (with slight differences in different business functions and scenarios). In these business functions and scenarios, we need to obtain your BIND_VPN_SERVICE permission. If you refuse the aforementioned required permissions, we may not be able to provide you with this service.

1.2 To Provide Advertising and Marketing Services

During your use of Fort VPN products and services, we may collect your GAID, advertising interaction information, and display relevant promotional content to you (including more relevant personalized advertising content). During this process, we will strictly protect your privacy.

We may create profiles (placing your personal information in one or more fields) by analyzing the above information and establishing user groups. Targeted advertising will only be delivered to you to the extent required by applicable laws and with your consent.

We may combine the above information with other information (including information across different services or such as computers, mobile phones, and other connected devices) to provide and improve our products, services, content, and advertising.

You have the right to opt-out of receiving personalized ads and object to user profiling, including identity analysis for direct marketing and automated decision-making purposes. To exercise these rights, you can turn them on or off anytime in the settings or contact us at FortVPN@outlook.com. The path to disable might vary with different versions.

Please understand and agree that the information you submit on the advertising page is collected and used by third-party advertisers or advertising companies, and they are responsible for protecting the personal information you submit. When using such third-party services, you need to accept their privacy policy, so please read their privacy policy carefully.

1.3 Other Situations Where Your Information May Be Collected

In some cases permitted by law, we may obtain your personal information from other individuals, business entities, public sources, or other third parties you instruct, other partners providing our products or services, and assisting us in ensuring information security and preventing fraud through legitimate channels. We will explain this to you when collecting and obtain your consent.

We may also collect other information about you, your devices, or your use of services in other ways, which will be explained to you at the time of collection and obtain your consent.

To better improve our product layout and provide you with better services, we may conduct research, statistical analysis, and predictions on the collected information in an anonymized manner (including using anonymous data for machine learning or model algorithm training). We will take technical measures and other necessary measures to process the collected personal information so that the data cannot be re-identified to specific individuals and cannot be restored. According to applicable laws and regulations, the use of such processed data does not require additional notification and consent from you.

2. How We Use Cookies and Similar Technologies

This service does not use cookies or similar technologies.

3. How We Store and Protect Your Personal Information

3.1 How We Store Your Personal Information

Based on your consent, we will store the personal information we collect in accordance with the personal data protection laws and regulations of the relevant country. Where permitted by local laws and regulations, we may also store the collected personal information in countries or regions outside the country where the business is located.

Currently, Fort VPN may store your personal information in: Ireland.

Specifically: The personal information we collect and generate during operations will be stored on servers located in Ireland. Depending on business needs, we may introduce servers from other regions or countries in the future, and we will update this policy accordingly.

Whether personal information is stored in the country where the business is located or in other countries or regions where it is not prohibited by law, we will store it in accordance with data storage regulations of relevant laws and regulations. We will also consider the characteristics, scope, purpose of personal information processing, the risks that may be encountered during processing, and the serious consequences that may occur if damage occurs, and implement necessary security measures.

For example, we will use encryption and de-identification methods to store the collected personal information. At the same time, we will store the information according to the shortest storage period required for business operations unless you agree to extend the retention period or it is permitted by law. Data that exceeds the storage period or that you request us to delete will be deleted or otherwise appropriately handled as long as it does not violate relevant laws and regulations.

3.2 How We Protect Your Personal Information

We will take other necessary measures to ensure the security of your personal information to prevent data misuse, unauthorized access, modification, disclosure, or destruction. We implement security measures to protect your personal information and regularly monitor our systems for potential vulnerabilities and attacks.

We use administrative, technical, and physical safeguards to protect your personal information by considering the nature, processing, and security of personal information. We continuously improve these protection measures to ensure the security of your personal data.

Of course, it should be reminded that no measure can absolutely guarantee the avoidance of data storage security incidents. If a security breach occurs, we will report it to the relevant regulatory authorities in accordance with relevant laws and regulations and provide information on the type of personal data involved, the number of data subjects, the possible consequences of the data breach, and the remedial measures we intend to take according to regulatory requirements.

We will take every possible measure to remedy or mitigate the damages and consequences caused by data breaches. In cases where it is permitted or required by law, we will promptly notify you of the possible consequences or significant damage that the data breach may cause, so you can take appropriate measures to protect your rights as much as possible.

Since any website, Internet transmission, computer system, or wireless connection is not absolutely secure, besides our necessary security measures, users also need to enhance their awareness of privacy security risks. For example, be cautious and read the terms of use of third-party websites, links, products, or services you access through our services. We do not assume any legal responsibility for data security issues caused by third parties.

If you find that certain content, advertisements, or functions of our website, products, or services may be provided by third parties and may endanger your personal privacy and security, please contact us promptly, and we will handle it according to laws and regulations.

4. How We Share, Transfer, and Disclose Your Personal Information

Regarding the sharing, transfer, and disclosure of your personal information, we adhere to the principles and requirements of minimization, necessity, and legal constraints. Generally, we will not share, transfer, or disclose your personal information to external parties, but in cases where applicable laws and regulations allow or require, we may do so under the following circumstances:

4.1 How We Share Your Personal Information

We will not sell any personal information to third parties.

To provide you with timely services, your personal information may be shared with Fort VPN's affiliated companies. We will only share your information within Fort VPN's affiliated companies for legitimate and explicit purposes and only share the necessary information for providing services, subject to the purposes stated in this Privacy Policy. If related purposes are not included in this policy, we will explain them in the privacy policy or notice of the specific product or service.

We may share necessary personal information with authorized third-party partners (including technology service providers, data storage service providers, marketing promotion service providers, etc.) to perform certain functions or provide better services and user experiences. Specifically, we will use cloud storage services provided by cloud service providers to ensure the operation of this product, and our advertising partners will obtain your device information and installed application lists to provide better recommendation services.

We adhere to the principles of minimization, necessity, and legality for such sharing activities. Before sharing information, we will sign strict confidentiality agreements with authorized partners, requiring them to handle personal information in accordance with this policy and the confidentiality and security measures required by applicable laws in your jurisdiction. Additionally, we will require them to provide data security features and information security qualifications (e.g., protection level evaluation, information security management systems).

When we embed authorized partner SDKs or other similar applications in this software, we will fulfill our duty of caution and require the SDKs collecting information to protect your data security. Specifically:

No. Source of Third-Party SDK Purpose of Collecting Type of Personal Information Collected Privacy Policy Link
1 Firebase SDK Provide data statistical analysis service Device identifier, IP address, in-app behavior records, in-app event info https://firebase.google.com/support/privacy

To provide assessment, analysis, or other business services, we may also share your non-personal information with third parties. For example, we may use aggregated information to help partners (e.g., advertising service providers) understand the effectiveness, feedback, and usage trends of their services.

In mergers, acquisitions, bankruptcy liquidations, asset transfers, or other related transactions, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy through agreements or other appropriate measures and require such entities to adopt confidentiality and security measures not lower than the requirements of this policy to handle personal information.

4.2 How We Transfer Your Personal Information

Fort VPN will not transfer your information to any other party unless:

  1. We have obtained your explicit consent.
  2. In cases of mergers, acquisitions, or sales involving Fort VPN's assets that may affect your personal information, we will notify you prominently via email and/or our website or other appropriate methods of any changes in ownership, rights, and choices regarding your personal information.
  3. As stated in this Privacy Policy or notified to you in other ways.

4.3 How We Disclose Your Personal Information

Fort VPN may need to disclose your personal information as required by law, legal processes, litigation, and/or requests from government departments and authorities. If disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.

Additionally, we may share your personal information with the following:

  1. Our lawyers, accountants, auditors, or similar advisors when we require professional advice.
  2. Investors and other relevant third parties if an actual or potential sale or other corporate transaction occurs and is related to entities within our group.
  3. Other third parties, such as disclosing specific information at your request.

5. How Your Personal Information is Transferred Across Borders

For purposes described in this Privacy Policy, we may transfer your personal information to the resources or servers mentioned in Section 3 of this policy for storage or processing, and we may also transfer your personal information to third-party service providers and business partners. Therefore, your data may be transferred to other countries or regions.

The privacy protection laws of these countries or regions may differ, and the jurisdictions of these servers may or may not protect personal information according to the same standards as your jurisdiction. However, we will still strive to comply with our privacy policy to protect your personal information, and we will carry out cross-border transfers and other processing of personal information in accordance with the laws of the country or region where the personal information is located.

If we transfer personal information to regions outside your jurisdiction, whether to our affiliated companies or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security and protection measures to ensure that all such transfers comply with the requirements of applicable local data protection laws.

6. Your Rights Regarding Your Personal Information

As a data subject, you have certain rights regarding your personal information, including the right to confirm, access, correct, delete, withdraw consent, and file complaints (hereinafter referred to as "requests"). We fully understand and respect your rights, and according to applicable laws, these rights are also subject to specific exclusions and exceptions.

We will take active measures to ensure your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request.

For legitimate and reasonable requests, we generally do not charge a fee. However, for multiple repetitive requests that exceed reasonable limits, we will charge a reasonable fee based on actual administrative expenses within the scope permitted by applicable laws.

We may refuse requests that are unfounded, require excessive technical means (e.g., developing new systems or fundamentally changing current practices), pose risks to the legitimate rights of others, or are very impractical or violate mandatory legal provisions.

6.1 Right to Confirm and Access

We inform you about how we collect and process personal information through this privacy policy or specific product service scenarios' privacy policies or notices. You have the right to confirm or refuse such collection and processing actions by checking appropriate options. However, if you refuse, some functions that require your explicit authorization may not be available.

For personal information you have provided to us, you can directly query it in the interface of our products or services. For situations where queries are not possible, you can send an email to FortVPN@outlook.com, and we will process your request promptly upon receipt.

6.2 Right to Correction and Deletion

When your personal information changes or when you find that the personal information we collect and process about you is incorrect or incomplete, you have the right to request corrections or supplements. For some of your personal information, you can directly correct or modify it on the relevant function page of the product or service.

When the personal information we collect about you has achieved the purpose of collection or is no longer necessary, or when you find that we have collected and processed your personal information in violation of laws, administrative regulations, or this privacy policy, you have the right to request the deletion of relevant personal information.

For personal information that does not yet provide correction or deletion channels, you can contact FortVPN@outlook.com to request correction or deletion.

However, in some cases, we may not approve your deletion request, such as when you request us to delete transaction data that Fort VPN is legally obligated to retain to comply with applicable local laws. Also, note that if you request to delete your information from our products and services, due to certain applicable local laws and technical limitations, we may not immediately delete the corresponding information from the backup system. However, we will securely store your personal information and prevent it from being further processed until the backup system is updated, and your information can be deleted or anonymized.

6.3 Right to Withdraw Consent

To achieve certain functions of our different products or services, we will need necessary personal information as required by applicable local laws. This is explained in the section "How We Collect and Use Your Personal Information" in this privacy policy.

You can withdraw your consent previously granted for a specific purpose, including the collection, use, and/or disclosure of your personal information controlled by us, by deleting the information, disabling device functions, or sending a consent withdrawal request. You can contact us via email at FortVPN@outlook.com to carry out relevant operations.

We will process your request within a reasonable time after you send it. Afterward, we will not collect, use, and/or disclose your personal information based on your request.

If you withdraw your consent, you may not be able to continue to access some or all of the functions of Fort VPN products and services. Withdrawing your consent or authorization will not affect the validity of our previous processing activities based on your consent.

6.4 Right to Complain

You have the right to contact us by sending an email to FortVPN@outlook.com to file a complaint. We will respond promptly upon receiving your complaint.

If you are not satisfied with our response, especially if our personal information processing behavior infringes on your legitimate rights and interests, you can also file a complaint or report to the local statutory personal data protection department or initiate a lawsuit in a court with jurisdiction.

6.5 Right to Manage Privacy Settings

You have the right to control your privacy settings. You can limit our collection, use, disclosure, or processing of your personal information through these privacy settings. For example, you can choose to enable or disable the functions and permissions of "location access", "camera", and "SMS". You can also obtain more detailed information about device security status in "Settings".

If you previously agreed to enable the corresponding permissions or consented to our use of your personal information in the aforementioned business scenarios, you can disable it through Settings > Application Management > Permission Management or contact us at FortVPN@outlook.com to change your decision.

6.6 Right to Cancel Services or Accounts

You can request to cancel your account through the cancellation path provided in this service or by contacting us at FortVPN@outlook.com. Please make the account cancellation decision carefully.

You understand and acknowledge that after canceling your account, we will stop providing the products and services based on that account. Unless otherwise required by applicable laws in your region, we will also delete the corresponding personal data under your account.

If you logged into this service through a third-party account authorization, please apply to the third party to cancel the account.

6.7 Rights in Certain Jurisdictions

Please note: According to the applicable laws of certain jurisdictions, you may have the following data subject rights:

  1. Right to Restriction of Processing. You have the right to request us to restrict the processing of your personal information. We will examine the reasons for your restriction request. If the reasons comply with applicable data protection laws, we will only process your personal information under such laws and notify you before lifting the restriction.
  2. Right to Object to Automated Decision-Making. You have the right to refuse automated decision-making, including performance analysis and other automated processing that may affect you legally or similarly.
  3. Right to Data Portability. You have the right to request the transfer of your personal information to another data controller in a structured and commonly used format.

We have the right to refuse your request and may refuse certain requests based on applicable exemptions or compliance with applicable laws. For example, some requests are clearly unfounded or excessively repetitive, or require excessive technical means (e.g., developing new systems or fundamentally changing current practices), risk the legitimate rights of others, or are very impractical.

7. How We Handle Children's Personal Information

Fort VPN's products and services are not provided to children under the age of 14 or the equivalent age specified by the laws of your jurisdiction (the definition of children varies by country or region, and we will define children based on the laws and regulations of the specific country or region where the business is located).

We do not actively collect personal data of children, nor do we use children's personal information for marketing purposes. If you find that relevant children's information has been transmitted to us, please send an email to FortVPN@outlook.com to contact us, and we will delete the relevant information as soon as possible.

If we discover that we have collected children's personal information, we will also strive to delete the relevant content as soon as possible.

8. Third-Party Service Providers and Their Services

When you use Fort VPN products or services (e.g., life services, online customer service, etc.), you may receive links to websites or content and services provided by third parties outside of Fort VPN. Some third-party products or services may be provided through SDKs and other means.

You can choose whether to access or accept the websites, products, and services provided by third parties based on your judgment. Our privacy policy does not apply to any products or services provided by third parties.

Since we cannot substantially control third parties, we cannot be responsible for the personal information collected and processed by such third parties. When you submit any information to such third parties, please understand their privacy policy carefully and pay attention to protecting your personal information.

9. Supplemental and Updated Provisions of This Policy

Based on changes in our business, technology, applicable laws, and operations, we reserve the right to update or modify this policy from time to time. If this policy is modified, we will post the latest policy here (this page).

Please pay regular attention to this page or the notices we send you to stay informed of updates to this Privacy Policy. Although this Privacy Policy may be adjusted, we will not reduce the rights you enjoy under this Privacy Policy without your explicit consent.

When we collect other personal information from you or when we use or disclose your personal information for new purposes, we will seek your explicit consent again in accordance with applicable laws.

If you continue to use the products and services on websites, mobile devices, and/or any other devices, you will be bound by the updated Privacy Policy.

The content of Fort VPN products or services described in this Agreement may vary based on the type of product you use, the system version, or the requirements of local laws and regulations.

10. How to Contact Us

If you have any suggestions, questions, or concerns about our Privacy Policy or our personal information protection practices, please contact us through the following means:

Email: FortVPN@outlook.com

Note: This email is only for receiving emails related to our Privacy Policy or our personal information protection practices

We will review your privacy or personal information request as soon as possible and respond within 15-30 days after verifying your user identity. If your request involves complex or significant issues, we may ask you to provide more information.

If you are not satisfied with our response, especially if our personal information processing behavior infringes on your legitimate rights and interests, you can seek solutions from the relevant data protection supervisory authority in your jurisdiction. If you consult us about the above issues, we will provide information on possible applicable complaint channels based on your situation.

Thank you for taking the time to read our Privacy Policy!