Introduction

NymGuard is a virtual private network (VPN) service offered to you by Nymlabs LTD.

Our service helps you connect to the world wide web anonymously and securely from anywhere in the world.

As we respect your privacy, we conform our data use to the European Union’s (“EU”) General Data Protection Regulation (“GDPR”).

We collect minimal data that is only required to run our service in a professional manner and serve you as our client without holding any sensitive data.

Our website www.nymguard.com, mobile APPS, and services are operated by Nymlabs LTD, a Société Anonyme registered in Cyprus under company number HE402603

With our registered office at Steliou Kyriakidi, 6, 3080, Limassol.

Please take a moment to read our privacy policy, and by using our service, you indicate that you accept it and that you agree to its terms.

Scope of Notice.

Nymlabs LTD (“Nymgo“) is committed to protecting the privacy of Nymgo’s Clients.

Personal data provided to Nymgo will always be processed in compliance with the requirements of the EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR“) and with any applicable implementing legislation, and processing systems will be designed to ensure the highest level of protection for the personal data.

This data privacy notice (“Notice“) sets out how Nymgo will process the Clients’ personal data.

For the avoidance of doubt, personal data processed and covered by this Notice will include personal data of Clients, provided by them in the course of the relationship with Nymgo and which Nymgo will deal with in the course of providing services to the Clients.

Please read the information below carefully – it explains how and why personal data is processed by Nymgo, and contains information about the Client’s rights in relation to his/her personal data.

Definitions and Interpretation

For the purpose of this Notice:

    1. the terms “controller”, “personal data”, “data subject” and any other term expressly defined in article 4 of the GDPR shall have the meaning given to these terms in article 4 of the GDPR;
    2. any reference to “you” and “your” shall be construed to include Nymgo’s Clients;
    3. any reference to “we” and “us” shall refer to Nymgo.

Identity of the controller of your personal data

Nymgo is data controller for the personal data collected and processed in the context of your use of Nymgo’s services. In this capacity, Nymgo is responsible of your personal data.

Your personal data will be processed by Nymgo, in a capacity as data controller for a certain number of purposes in the course of operating Nymgo’s services, like name, username, email address, IP address, Password (Encrypted) and other data required for accounting and billing purposes.

The contact details of Nymgo can be found in Section 14 below “How to contact us”.

The purposes for which Nymgo process your personal data are further described in Section 7 below “Why we process personal data“.

In certain circumstances, third party service providers to Nymgo, such as your internet service provider (ISP), and the Website and App Store payment service providers may also act in a capacity as data controller if and when processing your personal data for the purposes of complying with their own legal and regulatory obligations or for their own legitimate interest. Information about processing activities of these third-party service providers is available on their respective websites.

What personal Data do we collect?

The personal data that we collect and process in relation to your use of Nymgo’s services includes in particular:

  • Your name that you provide us, e-mail address, username and your encrypted password;
  • Time and IP address when you connect and disconnect to our VPN service, and the amount of Data transmitted (to support the free allowance packages that we offer).
  • Aggregated statistical (non-personal) data about the usage of the VPN mobile apps and services.
  • Events, like joining date, subscription type, technical data like Speeds, Connection type settings, and general interaction with our products so we can keep improving our customer experience and service.
  • It is important to note that we DO NOT STORE LOGS containing details of, or monitor, the websites you connect to when using our VPN service. It’s also equally important to note that under the laws of Luxembourg, we are not required by law to store those LOGS.

Where we obtain personal data from

We will collect information about you from you directly, as further detailed below.

Information that you give us:

We process the personal data that you provide to us directly, and that we obtain from our dealings with you during the course of our relationship, including when you register with us for the future use of our services; and when you make use of Nymgo’s services.

Do you have to provide us with personal data?

Where we collect personal data from you:

  • You should assume that the provision of your personal data is necessary for the proper operations of Nymgo’s services; and If the provision of your personal data is purely voluntary, we will inform you accordingly and, in this case, there will be no implications for you if you do not wish to provide us with it.
  • Some of the personal data we request is necessary for us to perform our contract with you and solely for legitimate interest and if you do not wish to provide us with this personal data, it will affect our ability to provide our services to you.

Do you have to inform your representative(s) and/or beneficial owner(s)?

In the event that you are not a natural person, you shall indeed inform your representative(s) (as well as your ultimate beneficial owner(s) and all individuals whose information you provide to us in connection with our relationship with you) about the processing of their personal data for the purposes described below in Section 7 “Why we process personal data” (as well as on their related rights, see Section 11 below “Your rights in respect of your personal data“) and you shall, where necessary and appropriate, obtain in advance any consent that may be required for the processing of their personal data. You shall provide these individuals with a copy of this Notice.

We may assume that you have complied with the undertakings contained herein and that your representatives and ultimate beneficial owner(s) have, where necessary given such consent and have been informed of the processing of their personal data for the purposes described in this Notice.

Why we process personal data

We may process your personal data for the purposes listed under Sections 7.1 to 7.3 below.

Where necessary to perform our contract (and/or pre-contractual steps) with you

In the context of our contract (and/or pre-contractual steps) with you, we are collecting and processing your personal data, among other things, in order to:

    • We collect your name to personalize the services we offer to you and collect your username and password in order to provide you with access to the service that we offer. We need your email to help you reset your password if you forgot it and to receive email newsletters and important information about our service. Your IP address is logged to prevent any spam, fraud, or abuse of our services.
    • We collect payment information like Name, Address, and Credit Card Information that is needed to be passed over to our 3rd party payment processors.  We never handle or store complete credit card numbers, as this is done on our behalf by our regulated payment processors.
    • If you contact our support, we generally keep the communication data between you and our customer service to properly follow-up and handle any issues you might encounter
    • Technical data is recorded to monitor the performance of our VPN service, enable us to conduct our internal analysis about how our products function and behave to optimize and improve our service to you.
    • Meet in general all the resulting contractual obligations we have to you.

Nymgo will take all reasonable steps, as required by the GDPR, to ensure the safety, privacy and integrity of your personal data and will, as required by the GDPR enter into contracts with such recipients to protect the privacy and integrity of your personal data supplied.

Do we sell your personal data ?

Nymgo does not sell your personal data to 3rd parties like advertising networks, that is why we only offer our service on a paid subscription model and DO NOT SERVE any ads on our network to keep your data safe

Transfers of personal data outside the EEA.

In principle, Nymgo will not transfer your personal data outside the EEA. In case personal data is transferred by Nymgo outside the EEA, the transferring entity will ensure that your personal data is protected by either:

    • an adequacy decision of the European Commission,
    • appropriate safeguards such as EU model contracts, binding corporate rules, approved code of conduct, approved certification mechanisms.

Please contact Nymgo at the address or email detailed below “How to contact us” if you would like to know more about the safeguards in place with Nymgo

How long we keep personal data?

In accordance with the GDPR principles and in particular article 5 of the GDPR (which lists the cor If you continue to use any of our services, we will store this data for as long as you are using one of our services or have an active account with us In principle, we will retain your personal data for a period of 1 year following the termination of your relationship with Nymgo. Your rights in respect of your personal data WITH NYMGO.

You have certain rights under the GDPR, including:

The right to access your personal data, including the right to ask for a copy of your personal data where it does not adversely affect the rights and freedoms of others (please note that if you request any further hard copies later on, we may charge you a reasonable fee based on administrative costs).

The right to have incomplete or inaccurate personal data corrected (including by means of providing a supplementary statement).

In some limited circumstances:

    1. the right to object to the use of your personal data (where processing is based on Nymgo’s legitimate interest);
    2. the right to restrict the use of your personal data;
    3. the right to require us to erase/delete your personal data; however, please note that if we process your personal data in particular to comply with a legal obligation (see Section 1.1 above), we will not be able to respond positively to your request to erase/delete your personal data.
    4. the right to receive personal data which you have provided to us in a structured, commonly used and machine-readable format and the right to transmit those data to another data controller; however, please note that this right to data portability only arises where: (a) the processing is based on consent or on a contract; and (b) the processing is carried out by automated means, and (c) it does not adversely affect the rights and freedoms of others. This data portability right also only applies to the data that you have provided to us.

Such rights relating to your personal data kept by Nymgo can be exercised by contacting Nymgo at the address and email detailed in section 14 below “How to contact us“. We will respond to you as swiftly as possible.

For the data kept with the third-party providers, the details for exercising your rights may be found on their website.

Your marketing preferences

You have the right to object to our use of your personal data for direct marketing purposes at any time by contacting us at the address and email detailed in Section 14 below “How to contact us”. If you no longer wish to be contacted for marketing purposes, please contact at the address and email detailed in Section 14 below “How to contact us“. You can also simply opt-out of any email communication by simply clicking on “Unsubscribe” link available at the bottom of every email communication we send out.

Complaints and questions to data protection authority

You have the right to ask questions or lodge a complaint about our processing of your personal data with the relevant data protection authority. You can complain in the EEA Member State where you live or work, or in the place where the alleged breach of the GDPR has taken place.

In Cyprus, the relevant data protection authority is the Office of the Commissioner for Personal Data Protection, Iasonos 1, 1082 Nicosia, Cyprus.

How to contact us

If you want more details on the processing of your personal data, if you have any specific queries or concerns regarding the processing of your personal data, if you want to exercise your rights towards us or if you would like to make a complaint, do not hesitate to contact:

In relation to Nymgo:

Nymlabs LTD.

  • To the attention of Data Privacy Officer Steliou Kyriakidi, 6, 3080, Limassol
  • Phone: +44 (20) 33553209 E-mail: dpo@nymgo.com

Amendments to this Notice

This Notice is kept under regular review and may be updated from time to time and you will be notified in writing in case of any changes.