1. (USER-CONTROLLED OPTION): PERSONAL INFORMATION

Our VPN APP is a non-obligatory log network. Innovative are not available for the information related to the personal information of users, including but not limited to names (subscriber names, user names and screen names), addresses (including mailing addresses, residential address, business addresses) and telephones, unless the data you provide depending on the context of your interactions with us and the choices you make, including your privacy settings, and the products and features you use for the purpose of administering your subscription and for the purpose to enjoy our VPN services. Except for the limited exceptions, we don't automatically collect any Personal Information from you.

When you open the APP seeking for our VPN services, the APP assigns a unique identifier to you for the service (such unique identifier just binds up with your device identification code, but does not tie to any other personal information of users). When you use the VPN services, we will check your account information through this unique identifier to determine the level of service you have signed up for before establishing your VPN connection.

With some forms of payment, certain Mac version of our VPN services may redirect you to the website of a third-party payment processor (namely PayPal) to complete the transaction. To understand what personal information the processor collects and stores, please refer to the respective processor's terms and privacy policy. Therefore, except for the limited exception above, we do not know any means or source of user's detailed payment for VPN services (including any credit card or bank account number) or any billing records either.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.

Innovative uses your email address (if any depending on your choice) for the following reasons:

• To communicate with you about your VPN services or respond to your communications.
• To send you updates and announcements.
• To send marketing information, such as Innovative offers, surveys, invitations, and content about other matters in connection with Innovative ("Marketing emails"). You may choose to not receive Marketing emails by following the opt-out procedure described in these emails.

Innovative uses your personal information only for the purposes listed in this Privacy Policy, and we don't sell your personal information to third parties without your prior consent.

2. SERVICE INFORMATION RELATED TO YOUR VPN USAGE

Subject to applicable laws and for the avoidance to infringe any internet service provider, any browsing information, traffic destination, data content, IP addresses, DNS queries or other similar information relating to your online activities transmitted by you to our servers is encrypted and cleared after the VPN "session" is closed. That said, we don't collect any information regarding the websites you visit or any data stored on or transmitted from your device, including any data that applications on your device may transmit through the VPN network. More specifically, Innovative has NO documents/information below under the situations of the limited connecting with your personal information and the non-collection of the websites you visit or any data stored on or transmitted from your device:

• We do not know which user ever accessed a particular website or service.
• We do not know which user was connected to the VPN at a specific time.
• We do not know the set of original IP addresses of a user's computer or the temporarily assigned network addresses.

If anyone would like to access to or try to compel Innovative to release user information based on any of the above, we cannot supply this information because the data don't exist.

For the purpose to fulfill our contractual obligations in good faith and to make you enjoy excellent VPN services, we collect the following information related to your VPN usage:

Information related to Apps and Apps versions

We collect information related to which Apps and Apps version(s) you have activated. It makes our Support Team efficiently find out and eliminate technical issues for you.

Information related to Connection

We collect information about whether a VPN connection is successful on a particular day (but not a specific time of the day), to which VPN location (but not your assigned outgoing IP address), and from which country/ISP (but not your source IP address). The minimal information allows us to provide efficient technical support to you, such as identifying connection problems, providing country-specific advice about how to use our VPN services, and to enable our engineers to identify and fix network issues.

The Size (in MB) of Data transferred (but not any websites you visit or any data transmitted from your device)

We collect information regarding the total sum of data transferred by a given user. It is one of our service principles to provide unlimited data transfer, however if we notice that a user occupies more traffic than thousands of others combined, what influence other users to enjoy high-quality service, we may seek for the reason with the user.

Anonymous Data for Network Diagnostics, Study and Analysis

When you become one of our users for the VPN services, with your permission, we collect minimal usage statistics and anonymized analytics data used for network diagnostics in our network operations tools, for the purpose to optimize network speeds and to let us identify problems related to specific apps, VPN servers, or ISPs. Learning and analyzing the statistics allows us to improve the quality of the services and the products. We ensure the information we receive is fully anonymized and cannot be tied back to individual users (i.e., we do not store which user sent which data, and we do not store IP addresses).

We will collect the following information:

• Diagnostic information about if and how a VPN connection attempt failed.
• Speed test data.
• Crash reports, also without any personally identifiable information. These are handled in an anonymized form by third parties, dependent on the platform you are using.

On iOS, Apple's crash reporting can be turned off in iOS settings.

Conclusion

We collect minimal usage statistics to maintain our quality of service. Although we provide service to users improving the network speed, we can't uniquely identify any specific behavior of any user, because thousands of users share one same location simultaneously to enjoy surfing the internet and the usage pattern overlaps with thousands of other customers who also connected to the same location on the same day.

Regarding to the sensitive data, we've engineered our systems to categorically eliminate the storage of sensitive data. We never know HOW they have utilized our Service. 

We stand by our firm commitment to our customers' privacy by not possessing any data related to a user's online activities.

3. THE USE AND SHARING OF INFORMATION

How we use information

We use the information we collect in various ways, including to:

• Provide, operate, and maintain our Services;
• Improve, personalize, and expand our Services;
• Understand and analyze how you use our Services;
• Develop new products, services, features, and functionality;
• Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Service, and for marketing and promotional purposes;
• Process your transactions;
• Send you text messages and push notifications;
• Find and prevent fraud; and
• For compliance purposes, including enforcing our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

How we share information

We may share the information we collect in various ways, including the following:

• Vendors and Service Providers. We may share information with third-party vendors and service providers that provide services on our behalf, such as helping to provide our Services, for promotional and/or marketing purposes, and to provide you with information relevant to you such as product announcements, software updates, special offers, or other information.
• Aggregate Information. Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified form that can't reasonably be used to identify you.
• Information We Share When You Sign Up Through a Referral. If you sign up for our Services through a referral from a friend, we may share information with your referrer to let them know that you used their referral to sign up for our Services.
• Analytics. We collect minimal usage statistics and anonymized analytics data used for network diagnostics in our network operations tools. Please see more information in Section 2 of this Privacy Policy.
• Business Transfers. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• As Required by Law and Similar Disclosures. We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
• With Your Consent. We may share information with your consent.