Privacy Policy

Effective Date: January 18, 2025

Data Controller: LAISECA_TEST
Contact: privacy@laiseca-test.com
DPO Contact: dpo@laiseca-test.com

1. Introduction

LAISECA_TEST ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy complies with the General Data Protection Regulation (GDPR) (EU) 2016/679 and explains how we collect, use, share, and protect your information.

2. Legal Basis for Processing

We process personal data under the following legal bases:

• Contract Performance: To provide our VPN services as requested (Article 6(1)(b) GDPR)
• Legal Obligations: To comply with applicable laws (Article 6(1)(c) GDPR)
• Legitimate Interests: For fraud prevention and network security (Article 6(1)(f) GDPR)
• Consent: For marketing communications and optional features (Article 6(1)(a) GDPR)

3. Data We Collect

3.1 Account Data (Necessary for Service)

• Email address (encrypted at rest)
• Account creation date
• Subscription status and type
• Payment method identifier (tokenized)

3.2 Technical Data (No Activity Logging)

• Total bandwidth used (monthly aggregate only)
• Number of simultaneous connections
• App version and operating system type

3.3 Data We Never Collect

• IP addresses (origin or VPN)
• DNS queries or browsing history
• Connection timestamps or session duration
• Traffic content or destination

4. How We Use Your Data

• Provide and maintain VPN services
• Process payments and prevent fraud
• Send service-related communications
• Comply with legal obligations
• Improve service quality and develop new features

5. Data Retention

• Account Data: Retained for duration of service plus 30 days
• Payment Records: 7 years (legal requirement)
• Support Tickets: 2 years after resolution
• Marketing Consent: Until withdrawn

6. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Access (Article 15): Request a copy of your data
• Rectification (Article 16): Correct inaccurate data
• Erasure (Article 17): Request deletion ("right to be forgotten")
• Restriction (Article 18): Limit processing of your data
• Portability (Article 20): Receive data in machine-readable format
• Object (Article 21): Object to certain processing
• Withdraw Consent: Where processing is based on consent

To exercise these rights, contact: privacy@laiseca-test.com

7. Data Security

• AES-256 encryption for data at rest
• TLS 1.3 for data in transit
• Regular security audits and penetration testing
• ISO 27001 certified infrastructure
• Zero-knowledge architecture for passwords

8. International Transfers

All data is processed and stored within the European Economic Area (EEA). No transfers to third countries occur without appropriate safeguards under Chapter V of the GDPR.

9. Third-Party Services

• Payment Processors: Stripe (PCI-DSS compliant)
• Email Service: SendGrid (for transactional emails only)
• Infrastructure: Google Cloud Platform (EU region)

All third parties are bound by Data Processing Agreements (DPAs) ensuring GDPR compliance.

10. Cookies and Tracking

We use minimal cookies essential for service functionality. See our Cookie Settings for details and preferences.

11. Children's Privacy

Our services are not directed to individuals under 16. We do not knowingly collect data from children under 16.

12. Data Breach Notification

In the event of a personal data breach, we will notify affected users within 72 hours in accordance with Article 33 and 34 of the GDPR.

13. Supervisory Authority

You have the right to lodge a complaint with your local data protection authority. For EU residents, contact details can be found at: EDPB Members

14. Changes to This Policy

We will notify you of material changes via email at least 30 days before they take effect. Continued use after changes constitutes acceptance.

15. Contact Information

Data Protection Officer:
LAISECA_TEST DPO
Email: dpo@laiseca-test.com
Address: [Company Address]
Phone: [Company Phone]