Privacy Policy

1. General provisions

1.1. This Privacy Policy (the “Policy”) is prepared in accordance with Federal Law No. 152-FZ “On Personal Data” and defines the rules for processing and measures for protecting personal data in the Nethra VPN service (the “Service”).

1.2. The Policy governs relations between an Internet user (the “Client”) and the Service with respect to the processing of personal data.

1.3. The Client must review this Policy before using services, offers and features provided through https://nethra.online, the personal cabinet at https://cabinet.nethra.online, and the Telegram bot https://t.me/nethravpn_bot (the “Website”).

1.4. Continued use of the Service means the Client’s full acceptance of this Policy.

1.5. If the Client disagrees with this Policy, the Client must stop using the Website and its services.

1.6. The Service does not collect or process personal data within the meaning established by Federal Law No. 152-FZ “On Personal Data”.

2. Definitions

2.1. Personal data means any information relating directly or indirectly to an identified or identifiable individual (the data subject).

2.2. Processing of personal data means any action or set of actions performed with personal data, whether automated or non-automated, including collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer, anonymisation, blocking, deletion and destruction.

2.3. Automated processing of personal data means processing personal data using computer technology.

2.4. Website means the set of graphical and informational materials, software and databases providing access to the Service online at https://nethra.online, https://cabinet.nethra.online and through the Telegram bot https://t.me/nethravpn_bot.

2.5. User means an individual using the Service’s functionality.

3. Principles of personal-data processing

3.1. The Service does not collect or process personal data within the meaning defined by Federal Law No. 152-FZ “On Personal Data”.

3.2. The only technical information available to the Service is a Telegram ID received when interacting with the Telegram bot. A Telegram ID does not make it possible to identify a user without additional information and is not personal data.

3.3. Information about users’ payments and payment details is not transferred to the Service. All transactions are performed by the payment provider Platega, and the Service has no access to users’ payment details.

4. Purposes of data processing

4.1. Telegram ID is used exclusively for:

• automatically providing access to the Service;
• notifying the user about subscription status;
• identifying the user to use the Service;
• improving service quality and developing new services;
• informing users about new products and services, special offers and events.

5. Processing and storage conditions

5.1. Telegram ID may be stored in the Service’s databases exclusively for technical purposes: to provide authorisation and automated activation or deactivation of access.

5.2. The Service does not transfer or disclose Telegram ID to third parties, except in cases provided for by the legislation of the Russian Federation.

6. Security measures

6.1. The Service takes necessary legal, organisational and technical measures to protect information from unlawful or accidental access, destruction, alteration, blocking, copying and dissemination.

7. Rights of the data subject

7.1. A data subject has the right to receive information concerning the processing of their personal data, except in cases provided for by federal laws.

7.2. A data subject has the right to require the Service to clarify, block or destroy personal data where it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing.

7.3. A data subject may contact the Service and request cessation of processing in the event of a breach of Russian personal-data legislation.

7.4. A data subject may request the cessation of processing, blocking or destruction of their data without giving reasons.

8. Transfer of data to third parties

8.1. The Service may transfer data to third parties where:

• the Client has given explicit consent to the transfer;
• the transfer is necessary to provide a specific service to the user or to perform an agreement with the user;
• the transfer is provided for by Russian or other applicable law under the established procedure.

9. Data storage

9.1. User data is processed and stored for the period necessary to achieve the purposes of processing, for the period established by Russian law, or for the duration of the agreement with the user.

10. Changes to the Policy

10.1. The Service may amend this Policy, including where such changes are related to changes in applicable legislation or changes in the operation of the Website.

10.2. When changes are made, the current version states the date of the last update. The new version of the Policy takes effect when published unless otherwise provided by the new version. The user undertakes to independently monitor changes to this Policy.