Privacy Policy

FF Clear Path LLC, with registered office at 8 The Green Ste R, Dover, Delaware, 19901, United States, formed under the laws of the State of Delaware, Tax Identification Number (EIN): 612207644, is the Controller of the personal data collected by the Service.

§ 1. GENERAL PROVISIONS AND DEFINITIONS

Controller may be contacted via email at thenextstep@vpn.support

Personal data – information about an identified or identifiable natural person.

Processing – any operation performed on personal data, automated or not.

Service – electronic services for downloading software application(s).

Device – a smartphone, mobile phone, tablet, or computer used by the User.

User – an entity who downloads software applications.

Terms and Conditions – available at: https://s3.amazonaws.com/susasus/terms.html

The use of Service does NOT require identification of any User. The Controller does NOT collect or process any personal data unless explicitly described in this Privacy Policy.

§ 2. LEGAL BASIS AND PURPOSES OF USER’S DATA PROCESSING

Personal data is processed in accordance with GDPR and relevant laws.

Data is processed only for:

• Establishing connections allowing software downloads (IP addresses) — Article 6(1)(b) GDPR.
• Fulfilling legal obligations of the Controller — Article 6(1)(c) GDPR.

No other data is processed unless the User explicitly consents.

§ 3. DATA COLLECTED BY CONTROLLER

Controller collects: IP address and device details.

Additional data may be collected voluntarily when User contacts Controller.

Browsing the Service does not require providing personal data beyond connection parameters.

§ 4. THE PROCESSING TIME OF PERSONAL DATA

Data is processed for the period:

• Necessary to provide services.
• Until consent is revoked (if data is processed based on consent).

Data may also be retained for anti-fraud and AML obligations.

§ 5. USER RIGHTS

Users may exercise rights by emailing thenextstep@vpn.support

User rights include:

• Access — Art. 15 GDPR
• Rectification — Art. 16 GDPR
• Erasure — Art. 17 GDPR
• Restriction — Art. 18 GDPR
• Data portability — Art. 20 GDPR
• Objection — Art. 21 GDPR
• Withdraw consent — Art. 7(3) GDPR
• Complaint to the Supervisory Authority — Art. 77 GDPR

§ 6. NECESSITY OF DATA PROVISION

Providing data is voluntary and NOT required for full functionality unless stated.

Failure to provide necessary data may prevent downloading software.

§ 7. DATA SHARING

Data is NOT shared with third parties unless required by law.

§ 8. TECHNICAL MEASURES

Controller applies security measures to protect data from unauthorized access or loss.

Security also depends on User compliance with safety practices.

§ 9. TRANSFER OF PERSONAL DATA OUTSIDE THE EEA

No data is transferred outside the EEA. Servers are located within EEA.

§ 10. DATA PROCESSORS ACTING ON BEHALF OF THE CONTROLLER

Google Analytics may be used for statistical purposes.

§ 11. CHANGE OF THE PRIVACY POLICY

Controller may amend this document. Users will be informed before changes take effect.

Continued use of Service after updates constitutes consent to updated terms.

This document does not limit any User rights under applicable law.