§1 No data storage when using a VPN server
The OkayFreedom service saves neither addresses nor content accessed by the user, the IP address that OkayFreedom assigned to them; nor the user's own IP address through which they are using OkayFreedom. As a result, it is not possible for Steganos to ascertain the content an OkayFreedom user has accessed. Neither the IP address of the user nor that of the accessed servers are saved.
§2 Pseudonymous user-ID instead of e-mail address
Personal data (e.g., email address) isn’t required for the use of OkayFreedom’s free version. For billing and load balancing purposes, OkayFreedom determines which data volume (only the amount of data transmitted, not addresses or content) belongs to which pseudonymous user-ID. The pseudonymous ID is derived from the hash value of the computer's MAC address on which OkayFreedom is being used and is not traceable to a particular computer or user.
§3 De-coupling the payment process from the pseudonymous user-ID
When booking a premium account through Steganos' e-commerce provider, a user will be asked for personal details. THE E-COMMERCE PROVIDER—LIKE STEGANOS—WILL NOT GAIN ACCESS AT ANY POINT IN TIME TO ADDRESSES OR CONTENT OF WEBSITES VISITED BY AN IDENTIFIABLE USER IF AN OKAYFREEDOOM VPN SERVER ROUTED THEM THERE.
§4 Collection and usage of data by Steganos
(1) Within the framework of OkayFreedom's free-of-charge offering, Steganos will only use the user's voluntarily given e-mail address for the provision of offers / services described here (see Terms and Conditions). In particular, Steganos utilizes the user's e-mail address to send updates, newsletters and/or current information. The user can unsubscribe from the newsletter.
(2) Steganos wishes to offer the best service possible to its customers. Under certain circumstances, therefore, the software asks customers whether it may transmit their e-mail address to Steganos for the purpose of informing them about product innovations and special offers. The transmission is voluntary and happens only with express consent of the customer. To save the customer the effort of entering their e-mail address, Steganos software under certain circumstances tries to gather the address. Should the customer agree to transmitting their e-mail address but later decide against receiving further information by Steganos via e-mail, they can unsubscribe with no justification required.
(3) Steganos automatically records certain information of users of the www.okayfreedom website that cannot be attributed to them, including IP address and browser type. THIS DOES NOT APPLY TO THE USE OF THE OKAYFREEDOM VPN SERVER; WHICH STORES NO DATA OF THIS TYPE.
§5 Dissemination of information to third parties
Steganos does not pass along users' personal data to third parties, unless the user previously has provided their express consent or unless there is a legal obligation to do so. An exception is made for certain technical service providers who have been carefully selected by and are under instruction from Steganos to carry out certain tasks. Such tasks include (for example) the distribution of newsletters (processing of project data), the collection and processing of anonymous data for usage patterns or integration of partner programs, as well as the collection of information about software errors that have occured for the improvement of the OkayFreedom website. NEITHER STEGANOS NOR THE COMMISSIONED DATA PROCESSOR SHALL GAIN ACCESS TO WEB ADDRESSES OR CONTENT VISITED BY AN IDENTIFIABLE USER IF AN OKAYFREEDOM VPN SERVER ROUTED THEM THERE.
If a user avails himself of our support, their inquiry will be stored in a database along with voluntarily provided information (where available). This information is for the exclusive use of our support team for processing the inquiry. The data collected in this manner will also be used by Steganos for statistical analysis. Neither the raw data nor the results of the analysis (nor any portion thereof) will be made accessible to third parties.
§8 Access to the OkayFreedom VPN server and the webserver
We store user data on specially protected servers. Access is resticted to a few specially authorized persons.
§9 Personalized advertisements
Users consent to Steganos using their data for its (Steganos') own purposes and to having data transmitted in anonymous or pseudnonymous form to partners for the presenting of personalized advertisements or special offers and services via the OkayFreedom service. NEITHER STEGANOS NOR THE ADVERTISING PARTNER SHALL GAIN ACCESS TO WEB ADDRESSES OR CONTENT VISITED BY AN IDENTIFIABLE USER IF AN OKAYFREEDOM VPN SERVER ROUTED THEM THERE.
§10 Google Analytics
This website uses Google analytics, a website analysis service by Google Inc. („Google“). Google Analytics utilizes cookies (text files that are stored on your computer that enable the analysis of website usage by you). Information gathered from the cookies regarding your use of the website (including your IP address) are transmitted to a server in the USA by Google and are stored there. Google uses this information to analyze usage of the website, to generate reports about the website's activity for the website owner and to produce more services connected to the utilization of website- and Internet usage. Google may also, where applicable, transmit this information to third parties when legally required to do so or when third parties process this data on Google's behalf. Under no circumstances will Google relate your IP address to other data from Google. You can adjust your browser to prevent the installation of cookies; please note that in doing so, you may not be able to use the entire functionality and scope of the website. By using this website, you consent to the processing of your data that Google collects using the previously described methods for the previously mentioned purposes. GOOGLE HAS NO ACCESS TO WEB ADDRESSES OR CONTENT VISITED BY AN IDENTIFIABLE USER IF AN OKAYFREEDOM VPN SERVER ROUTED THEM THERE.
Persons under the age of 18 should not submit any personal data to us without the consent of their parents or guardians.
§12 Changes of policy
§13 Questions and comments
If you need information about the data we have stored or if you have questions, suggestions or comments concerning the protection of your data, please send us an e-mail firstname.lastname@example.org.