Privacy Policy

This Privacy Policy explains how valtrogen Network ("valtrogen," "we," "us," or "our") collects, uses, and protects your personal data when you use our encrypted network transport services, in accordance with the General Data Protection Regulation (GDPR) and applicable data protection laws.

1. Introduction

valtrogen is committed to protecting your privacy and personal data. This Privacy Policy describes our practices regarding the collection, use, and disclosure of personal data when you use our website (valtrogen.com) and encrypted network transport services (the "Services").

By using our Services, you acknowledge that you have read and understood this Privacy Policy and our Terms of Service.

2. Data Controller

valtrogen Network is the data controller responsible for your personal data. You can contact us at:

valtrogen Network

Sepapaja tn 6, Lasnamäe linnaosa

Tallinn, Harju maakond, 15551

Estonia

Email: [email protected]

3. Information We Collect

3.1 Information You Provide

Account Information: Name, email address, and similar identifiers when creating your account.
Billing Information: Payment details processed through third-party payment processors (we do not store full payment card details).
Support Communications: Records of requests and feedback submitted to our support team.

3.2 Automatically Collected Information

Connection Metadata: Timestamps, connection duration, and bandwidth usage for service operation.
Device Information: Device type, operating system, and application version.
Usage Data: Service performance metrics and diagnostic data.

3.3 Information We Do Not Collect

We do not log, monitor, or store the content of your network traffic. Our encrypted transport service is designed to protect your communications in transit. We do not maintain records of websites you visit, data you transmit, or your online activities while using our Services.

4. Legal Basis for Processing

Under GDPR Article 6, we process your personal data based on the following legal grounds:

Contract Performance: Processing necessary to provide the Services you have requested (Article 6(1)(b)).
Legitimate Interests: Processing for our legitimate interests, such as fraud prevention, security, and service improvement, where these interests are not overridden by your rights (Article 6(1)(f)).
Legal Obligations: Processing required to comply with applicable laws (Article 6(1)(c)).
Consent: Where you have given explicit consent for specific processing activities (Article 6(1)(a)).

5. How We Use Information

We use collected information for:

Service Delivery: Managing your account, processing payments, and providing the Services.
Communications: Sending service notifications, security alerts, and account updates.
Support: Responding to inquiries and resolving issues.
Improvements: Analyzing usage patterns to enhance service quality and develop new features.
Security: Detecting and preventing fraud, abuse, and unauthorized access.
Legal Compliance: Fulfilling legal obligations and regulatory requirements.

7. International Data Transfers

We are headquartered in Estonia, within the European Economic Area (EEA). Your data is primarily processed within the EEA.

Where we transfer personal data outside the EEA (for example, to service providers), we ensure appropriate safeguards are in place, including:

EU Commission adequacy decisions;
Standard Contractual Clauses (SCCs) approved by the EU Commission;
Other legally recognized mechanisms for cross-border data transfers.

You may request a copy of the safeguards we use by contacting [email protected].

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data in accordance with GDPR Article 32, including:

Encryption of data in transit and at rest;
Regular security assessments and vulnerability testing;
Access controls and authentication measures;
Staff training on data protection;
Incident response procedures.

No security measures are completely foolproof. If you believe your account has been compromised, contact us immediately at [email protected].

9. Your Rights Under GDPR

Under GDPR, you have the following rights regarding your personal data:

Right of Access (Art. 15): Request a copy of the personal data we hold about you.
Right to Rectification (Art. 16): Request correction of inaccurate or incomplete data.
Right to Erasure (Art. 17): Request deletion of your data ("right to be forgotten") in certain circumstances.
Right to Restriction (Art. 18): Request limitation of processing in certain circumstances.
Right to Data Portability (Art. 20): Receive your data in a structured, commonly used, machine-readable format.
Right to Object (Art. 21): Object to processing based on legitimate interests or for direct marketing.
Right to Withdraw Consent (Art. 7): Where processing is based on consent, withdraw consent at any time.
Right to Lodge a Complaint: File a complaint with a supervisory authority (see Section 14).

To exercise these rights, contact us at [email protected]. We will respond within one month as required by GDPR.

10. Cookies and Tracking

We use cookies and similar technologies to maintain your session, analyze usage, and enhance security. We obtain your consent for non-essential cookies in accordance with EU ePrivacy requirements.

You can manage your cookie preferences through our cookie consent tool or your browser settings. Disabling certain cookies may affect the functionality of our Services.

11. Data Retention

We retain personal data only as long as necessary to fulfill the purposes outlined in this Policy, or as required by law. Specific retention periods:

Account Data: Duration of your account plus 30 days after deletion request.
Billing Records: As required by tax and accounting laws (typically 7 years).
Support Communications: 2 years after resolution.
Connection Metadata: 90 days for operational purposes.

When data is no longer needed, we securely delete or anonymize it.

12. Children's Privacy

Our Services are not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If you become aware that a child has provided us with personal data, contact us at [email protected], and we will take steps to delete such data.

13. Changes to This Policy

We may update this Privacy Policy periodically. We will post changes on our website and update the "Last Updated" date. For material changes, we will provide notice via email or prominent website notice at least 30 days in advance where required. Continued use of the Services after changes become effective constitutes acceptance.

14. Contact & Complaints

For privacy-related questions or to exercise your data protection rights:

Email: [email protected]