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Your privacy is critically important to us. At Portal Cloud Inc., we have a few 
fundamental principles:
We are thoughtful about the personal information we ask you to provide
We collect as little information as possible through the operation of our 
services.
We store personal information for only as long as we have a reason to keep it.
We aim to make it as simple as possible for you to control what information on 
your server is shared publicly (or kept private), indexed by search engines, 
and permanently deleted.
We help protect you from overreaching government demands for your personal 
information.
We aim for full transparency on how we gather, use, and share your personal 
information.
Below is our Privacy Policy, which incorporates and clarifies these principles.
Who We Are and What This Policy Covers
We are the folks behind Portal Cloud VPN, a service designed to allow anyone 
– from professionals, travelers, startups, small businesses, and enterprises 
- to run their own VPN server. Our mission is to help keep your team’s 
information/data private, promote net neutrality, and build self hosted 
privacy-enabled apps.

This Privacy Policy applies to information that we collect about you when you 
use:
Our website (including portal.cloud);
Our mobile applications (including the Portal Cloud VPN mobile app for Android 
and iOS);
Our other products and services that are available on or through our websites 
(including Portal Cloud VPN plans); and

Throughout this Privacy Policy we will refer to our website, mobile 
applications and other products and services collectively as “Services.” 

Please note that this Privacy Policy does not apply to any of our products or 
services that have a separate privacy policy.

Below we explain how we collect, use, and share information about you, along 
with the choices that you have with respect to that information.
Information We Collect
We only collect information about you if we have a reason to do so – for 
example, to provide our Services, to communicate with you, or to make our 
Services better. We collect information in three ways: if and when you provide 
information to us, automatically through operating our Services, and from 
outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. 
The amount and type of information depends on the context and how we use the 
information. Here are some examples:
Basic Account Information: We ask for basic information from you in order to 
set up your account. For example, we require individuals who sign up for a 
Portal Cloud VPN account to provide a username and email address – and 
that’s it. You may provide us with more information – like your name – 
but we don’t require that information to create a Portal Cloud VPN account.
Transaction and Billing Information: If you buy something from us – a 
subscription to a Portal Cloud VPN plan, for example – you will provide 
additional personal and payment information that is required to process the 
transaction and your payment, such as your name, credit card information, and 
contact information.
Credentials: Depending on the Services you use, you may provide us with 
credentials for your server (like SSH, and VPN config files). For example, 
Portal Cloud VPN may provide us with these credentials in order to use our 
setup guides, or to allow us to troubleshoot problems on your server more 
quickly.
Communications With Us: You may also provide us information when you respond to 
surveys, support questions, or post a question in our public forums.
Information We Collect Automatically
We also collect some information automatically:
Log Information: Like most online service providers, we collect information 
that web browsers, mobile devices, and servers typically make available, such 
as the browser type, IP address, unique device identifiers, language 
preference, referring site, the date and time of access, operating system, and 
mobile network information. We collect log information when you use our 
Services – for example, when you create or make changes to your account on 
Portal.cloud.
Usage Information: Other than server bandwidth, we do not collect or log any 
usage information.
Location Information: We may determine the approximate location of your device 
from your IP address. We collect and use this information to, for example, 
calculate how many people visit our Services from certain geographic regions. 
Information from Cookies & Other Technologies: A cookie is a string of 
information that a website stores on a visitor’s computer, and that the 
visitor’s browser provides to the website each time the visitor returns. 
Pixel tags (also called web beacons) are small blocks of code placed on 
websites and emails. Portal Cloud Inc. uses cookies and other technologies like 
pixel tags to help us identify and track visitors, usage, and access 
preferences for our Services, as well as track and understand email campaign 
effectiveness and to deliver targeted ads. For more information about our use 
of cookies and other technologies for tracking, including how you can control 
the use of cookies, please see our Cookie Policy.
Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you 
are invited to join a Portal Cloud VPN server, we will receive information from 
that server (such as your email address) via the authorization procedures used 
by that server. We may also get information, such as an email address, from 
third party services about individuals who are not yet our users (…but we 
hope will be!), which we may use, for example, for marketing and advertising 
purposes.
How And Why We Use Information
Purposes for Using Information
We use information about you as mentioned above and for the purposes listed 
below:
To provide our Services – for example, to set up and maintain your account, 
host your server, backup and restore your account, or charge you for any of our 
paid Services;
To further develop and improve our Services – for example by adding new 
features that we think our users will enjoy or will help them to create and 
manage their servers more efficiently;
To monitor and analyze trends and better understand how users interact with our 
Services, which helps us improve our Services and make them easier to use;
To measure, gauge, and improve the effectiveness of our advertising, and better 
understand user retention and attrition – for example, we may analyze how 
many individuals purchased a plan after receiving a marketing message or 
continue to use our Services after a certain length of time;
To monitor and prevent any problems with our Services, protect the security of 
our Services, detect and prevent fraudulent transactions and other illegal 
activities, fight spam, and protect the rights and property of Portal Cloud 
Inc. and others, which may result in us declining a transaction or the use of 
our Services;
To communicate with you, for example through an email, about offers and 
promotions offered by Portal Cloud VPN and others we think will be of interest 
to you, solicit your feedback, or keep you up to date on Portal Cloud VPN and 
our products; and
To personalize your experience using our Services, provide content 
recommendations, target our marketing messages to groups of our users (for 
example, those who have a particular plan with us or have been our user for a 
certain length of time), and serve relevant advertisements.
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for 
processing information about you under EU data protection laws, which is that 
our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfill our commitments to you under our 
Terms of Service or other agreements with you or is necessary to administer 
your account – for example, in order to enable access to our website on your 
device or charge you for a paid plan; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of 
another person; or
(4) We have a legitimate interest in using your information – for example, to 
provide and update our Services, to improve our Services so that we can offer 
you an even better user experience, to safeguard our Services, to communicate 
with you, to measure, gauge, and improve the effectiveness of our advertising, 
and better understand user retention and attrition, to monitor and prevent any 
problems with our Services, and to personalize your experience; or
(5) You have given us your consent–for example before we place certain 
cookies on your device and access and analyze them later on, as described in 
our Cookie Policy.
Sharing Information
How We Share Information
We do not sell our users’ private personal information.
We share information about you in the limited circumstances spelled out below 
and with appropriate safeguards on your privacy:
Subsidiaries, Employees, and Independent Contractors: We may disclose 
information about you to our subsidiaries, our employees, and individuals who 
are our independent contractors that need to know the information in order to 
help us provide our Services or to process the information on our behalf. We 
require our subsidiaries, employees, and independent contractors to follow this 
Privacy Policy for personal information that we share with them.
Third Party Vendors: We may share information about you with third party 
vendors who need to know information about you in order to provide their 
services to us, or to provide their services to you or your site. This group 
includes vendors that help us provide our Services to you (like payment 
providers that process your credit and debit card information, fraud prevention 
services that allow us to analyze fraudulent payment transactions, postal and 
email delivery services that help us stay in touch with you, customer chat and 
email support services that help us communicate with you, registrars, 
registries, and data escrow services that allow us to provide domain 
registration services, and your hosting provider if your server is not hosted 
by Portal Cloud VPN), those that assist us with our marketing efforts (e.g. by 
providing tools for identifying a specific marketing target group or improving 
our marketing campaigns), those that help us understand and enhance our 
Services (like analytics providers), who may need information about you in 
order to, for example, provide technical or other support services to you. We 
require vendors to agree to privacy commitments in order to share information 
with them. Other vendors are listed in our more specific policies (e.g. our 
Cookie Policy).
Legal Requests: We may disclose information about you in response to a 
subpoena, court order, or other governmental request. For more information on 
how we respond to requests for information about Portal Cloud VPN users, please 
see our Legal Guidelines.
To Protect Rights, Property, and Others: We may disclose information about you 
when we believe in good faith that disclosure is reasonably necessary to 
protect the property or rights of Portal Cloud Inc., third parties, or the 
public at large. For example, if we have a good faith belief that there is an 
imminent danger of death or serious physical injury, we may disclose 
information related to the emergency without delay.
Business Transfers: In connection with any merger, sale of company assets, or 
acquisition of all or a portion of our business by another company, or in the 
unlikely event that Portal Cloud Inc. goes out of business or enters 
bankruptcy, user information would likely be one of the assets that is 
transferred or acquired by a third party. If any of these events were to 
happen, this Privacy Policy would continue to apply to your information and the 
party receiving your information may continue to use your information, but only 
consistent with this Privacy Policy.
With Your Consent: We may share and disclose information with your consent or 
at your direction. For example, we may share your information with third 
parties with which you authorize us to do so.
Aggregated or De-Identified Information: We may share information that has been 
aggregated or reasonably de-identified, so that the information could not 
reasonably be used to identify you. For instance, we may publish aggregate 
statistics about the use of our Services and we may share a hashed version of 
your email address to facilitate customized ad campaigns on other platforms.
Published Support Requests: And if you send us a request (for example, via a 
support email or one of our feedback mechanisms), we reserve the right to 
publish that request in order to help us clarify or respond to your request or 
to help us support other users.
Information Shared Publicly
Information that you choose to make public is disclosed publicly.
That means, of course, that information like your public profiles, posts, other 
content that you make public, and your “Likes” and comments on other 
websites, are all available to others.
How Long We Keep Information
We generally discard information about you when we no longer need the 
information for the purposes for which we collect and use it – which are 
described in the section above on How and Why We Use Information – and we are 
not legally required to continue to keep it.
For example, we keep the web server logs that record information about a 
visitor to Portal.cloud, such as the visitor’s IP address, browser type, and 
operating system, for approximately 30 days. We retain the logs for this period 
of time in order to, among other things, analyze traffic to Portal Cloud 
VPN’s websites and investigate issues if something goes wrong on one of our 
websites.
Security
While no online service is 100% secure, we work very hard to protect 
information about you against unauthorized access, use, alteration, or 
destruction, and take reasonable measures to do so, such as monitoring our 
Services for potential vulnerabilities and attacks.
To enhance the security of your account, we encourage you to enable our 
advanced security settings, like Two Step Authentication.
Choices
You have several choices available when it comes to information about you:
Limit the Information that You Provide: If you have an account with us, you can 
choose not to provide the optional account information, profile information, 
and transaction and billing information. Please keep in mind that if you do not 
provide this information, certain features of our Services may not be 
accessible.
Limit Access to Information On Your Mobile Device: Your mobile device operating 
system should provide you with the ability to discontinue our ability to 
collect stored information or location information via our mobile apps. If you 
do so, you may not be able to use certain features.
Opt-Out of Electronic Communications: You may opt out of receiving promotional 
messages from us. Just follow the instructions in those messages. If you opt 
out of promotional messages, we may still send you other messages, like those 
about your account and legal notices.
Set Your Browser to Reject Cookies: At this time, Portal Cloud VPN does not 
respond to “do not track” signals across all of our Services. However, you 
can usually choose to set your browser to remove or reject browser cookies 
before using Portal Cloud Inc. websites, with the drawback that certain 
features of Portal Cloud VPN’s websites may not function properly without the 
aid of cookies.
Close Your Account: While we’d be very sad to see you go, if you no longer 
want to use our Services, you can close your Portal Cloud VPN account. Please 
keep in mind that we may continue to retain your information after closing your 
account, as described in How Long We Keep Information above – for example, 
when that information is reasonably needed to comply with (or demonstrate our 
compliance with) legal obligations such as law enforcement requests, or 
reasonably needed for our legitimate business interests.
Your Rights
If you are located in certain countries, including those that fall under the 
scope of the European General Data Protection Regulation (AKA the “GDPR”), 
data protection laws give you rights with respect to your personal data, 
subject to any exemptions provided by the law, including the rights to:
Request access to your personal data;
Request correction or deletion of your personal data;
Object to our use and processing of your personal data;
Request that we limit our use and processing of your personal data; and
Request portability of your personal data.
You can usually access, correct, or delete your personal data using your 
account settings and tools that we offer, but if you aren’t able to do that, 
or you would like to contact us about one of the other rights, scroll down to 
‘How to Reach Us’ to find our contact information.
EU individuals also have the right to make a complaint to a government 
supervisory authority.
Controllers and Responsible Companies
Portal Cloud Inc.’s Services are worldwide. Different Portal Cloud Inc. 
companies are the controller (or co-controller) of personal information, which 
means that they are the company responsible for processing that information, 
based on the particular service and the location of the individual using our 
Services.Depending on the Services you use, more than one company may be the 
controller of your personal data. Generally, the “controller” is the Portal 
Cloud Inc. company that entered into the contract with you under the Terms of 
Service for the the product or service you use. In addition, Portal Cloud Inc., 
our US-based company, is the controller for some of the processing activities 
across all of our Services worldwide.

The chart below explains the controllers for processing your personal 
information. We use the term “Designated Countries” to refer to Australia, 
Canada, Japan, Mexico, New Zealand, and all countries located in the European 
continent.

How to Reach Us
If you have a question about this Privacy Policy, or you would like to contact 
us about any of the rights mentioned in the Your Rights section above, please 
contact us.
Other Things You Should Know (Keep Reading!)
Transferring Information
Because Portal Cloud Inc.’s Services are offered worldwide, the information 
about you that we process when you use the Services in the EU may be used, 
stored, and/or accessed by individuals operating outside the European Economic 
Area (EEA) who work for us, other members of our group of companies, or third 
party data processors. This is required for the purposes listed in the How and 
Why We Use Information section above. When providing information about you to 
entities outside the EEA, we will take appropriate measures to ensure that the 
recipient protects your personal information adequately in accordance with this 
Privacy Policy as required by applicable law. These measures include:
In the case of US based entities, entering into European Commission approved 
standard contractual arrangements with them, or ensuring they have signed up to 
the EU-US Privacy Shield; or
In the case of entities based in other countries outside the EEA, entering into 
European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your 
personal information when transferring it from the EU.
Ads and Analytics Services Provided by Others
Ads appearing on any of our Services may be delivered by advertising networks. 
Other parties may also provide analytics services via our Services. These ad 
networks and analytics providers may set tracking technologies (like cookies) 
to collect information about your use of our Services and across other websites 
and online services. These technologies allow these third parties to recognize 
your device to compile information about you or others who use your device. 
This information allows us and other companies to, among other things, analyze 
and track usage, determine the popularity of certain content, and deliver 
advertisements that may be more targeted to your interests. Please note this 
Privacy Policy only covers the collection of information by Portal Cloud, Inc. 
and does not cover the collection of information by any third party advertisers 
or analytics providers.
Third Party Software
If you’d like to use third party plugins or extensions that enable services 
provided by third parties, or other third party software, please keep in mind 
that when you interact with them you may provide information about yourself (or 
your site visitors) to those third parties. We don’t own or control these 
third parties and they have their own rules about collection, use and sharing 
of information, which you should review.
Visitors to Our Users’ Websites
We also process information about visitors to our users’ websites, on behalf 
of our users and in accordance with our user agreements. Please note that our 
processing of that information on behalf of our users for their websites 
isn’t covered by this Privacy Policy. We encourage our users to post a 
privacy policy that accurately describes their practices on data collection, 
use, and sharing of personal information. If you’d like, you can also read 
more about the data we collect on behalf of our users in our Privacy Notice.
Privacy Policy Changes
Although most changes are likely to be minor, Portal Cloud Inc. may change its 
Privacy Policy from time to time. Portal Cloud Inc. encourages visitors to 
frequently check this page for any changes to its Privacy Policy. If we make 
changes, we will notify you by revising the change log below, and, in some 
cases, we may provide additional notice (such as adding a statement to our 
homepage or the Portal Cloud VPN Blog, or sending you a notification through 
email or your dashboard). Your further use of the Services after a change to 
our Privacy Policy will be subject to the updated policy.

That’s it! Thanks for reading.
Change log
October 7, 2018: Published Privacy Policy