Privacy Policy

INTRODUCTION

This Privacy Policy ("Policy") governs the collection, use, storage, and disclosure of personal information by BlackCobra VPN, a service operated by Defied Trust Digital Trading (FZCO), a company incorporated under the laws of the United Arab Emirates ("BlackCobra VPN," "we," "our," or "us"). This Policy is designed to comprehensively inform users of our privacy practices and to demonstrate our unwavering commitment to user privacy and data security.

BlackCobraVPN is founded on the principle of maximum privacy with minimal data collection. Our systems are engineered to protect user privacy through technological design and operational practices that significantly limit the data we possess. This approach ensures that even when legally compelled, we cannot produce data that we do not collect or retain.

1. LEGAL FRAMEWORK AND JURISDICTION

BlackCobra VPN operates under the legal framework of the United Arab Emirates, specifically governed by the laws applicable in the Emirate of Dubai, where Defied Trust Digital Trading (FZCO) is incorporated. Our privacy and data protection practices comply with applicable UAE federal laws and regulations, including the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).

For users located in the European Economic Area (EEA), we also comply with the General Data Protection Regulation (GDPR), including provisions concerning data subject rights and cross-border data transfers.

2. INFORMATION COLLECTION PRACTICES

2.1 Data We Expressly Do Not Collect

In furtherance of our commitment to user privacy, BlackCobra VPN does not collect or store browsing history, traffic destination, data content, DNS queries, connection timestamps, source IP addresses, outgoing VPN IP addresses, VPN session durations, or any logs that could link users to specific online activities or behaviours. Our system architecture is specifically designed to prevent the collection of sensitive user data, ensuring that we maintain no records that could compromise user privacy or be subject to disclosure demands.

2.2 Limited Personal Data Collection

To maintain operational functionality and service delivery, BlackCobra VPN collects strictly limited personal information. We require email addresses solely for account management, communication regarding service updates, and customer support provision. Payment information is processed securely through third-party payment processors with limited retention of transaction identifiers only, ensuring that sensitive financial details remain protected. Authentication credentials are securely stored in encrypted form using industry-standard encryption protocols to prevent unauthorized access while enabling seamless service delivery.

2.3 Technical Data Collection

We collect minimal technical data that cannot be used to identify individual online activities. This includes app version information for troubleshooting and technical support purposes, ensuring our support team can efficiently diagnose and resolve issues. We maintain connection success metrics as aggregate data regarding successful connections to VPN locations without timestamp specificity, which helps us monitor service quality. General connection metrics regarding country/ISP of connection origin are collected without specific IP addresses, allowing us to optimize network performance while preserving anonymity. We also monitor aggregate bandwidth utilization as total data transfer volume to ensure service quality and network capacity planning without tracking individual user activities.

2.4 Optional Diagnostic Information

With explicit user consent, we may collect anonymised crash reports containing technical information when the application experiences errors. This may include performance metrics consisting of system-level data to improve application stability and performance, as well as connection diagnostics comprising technical connection parameters to enhance service reliability. This information is strictly used for service improvement and cannot be linked to individual user identities or online activities. Users may enable or disable diagnostic information collection at any time through the application settings, maintaining complete control over this optional data sharing.

3. USE OF COLLECTED INFORMATION

3.1 Essential Service Provision

BlackCobra VPN utilizes collected information solely for legitimate purposes directly related to service provision and improvement. We process the limited data we collect to provide, maintain, and improve our VPN services, ensuring optimal performance and security for our users. The information enables us to process subscriptions and facilitate payment transactions accurately and securely, while also authenticating user access to subscribed services. Our limited data collection supports our ability to deliver technical support and resolve user inquiries efficiently, as well as communicate service updates and security notifications when necessary for the proper functioning of our services.

3.2 Email Communications

When you provide your email address, it may be used for several important purposes related to your account management and service experience. We may send account verification and security notifications to protect your account from unauthorized access. Your email enables subscription management and billing communications, ensuring you remain informed about your service status. Critical service announcements and updates may be delivered to your email when necessary for service continuity. We also use email to respond to user-initiated support requests, providing the assistance you need. With your explicit consent, we may send marketing communications about service enhancements and promotions, always including clear opt-out mechanisms that respect your communication preferences.

3.3 Analytical Purposes

Anonymized and aggregated technical data may be used internally for service optimization purposes that benefit all users. We analyze this non-identifying information to improve network performance and reliability, ensuring consistent high-quality connections. The data helps us enhance application stability and user experience through targeted improvements to our software. By examining anonymized technical information, we can identify and resolve technical issues more efficiently, minimizing service disruptions. This data also informs our planning for infrastructure capacity and network resources, allowing us to scale our services appropriately while maintaining performance standards. All analytical processing is performed using data that cannot be linked to individual users or their online activities, preserving the privacy that is fundamental to our service.

4. DATA PROTECTION MEASURES

4.1 Technological Safeguards

We implement comprehensive security measures to protect user information from unauthorized access, disclosure, alteration, and destruction. All data transmitted between your devices and our systems is protected with encryption protocols to maintain confidentiality and integrity. Our security approach includes forward secrecy mechanisms to prevent compromise of past sessions. Our infrastructure is hosted in protected environments with comprehensive security measures including electronic access controls and continuous monitoring protocols. We perform regular security assessments and testing to identify and address potential vulnerabilities in our systems.

4.2 Operational Safeguards

We maintain strict operational protocols to protect user privacy throughout our organization. Access to systems containing user information is limited to essential personnel who require it to perform their job functions, implementing the principle of least privilege. All staff and contractors are bound by strict confidentiality agreements that prohibit unauthorized disclosure of user information and establish clear consequences for violations. Our systems are designed according to privacy-by-design principles that minimize data collection by default, incorporating privacy protection into the core architecture of our services. We conduct regular compliance reviews to ensure adherence to this Policy and applicable laws, adjusting our practices as necessary to maintain the highest standards of privacy protection.

4.3 Data Retention Limitations

We retain collected information only for the duration necessary to fulfill the purposes outlined in this Policy, applying stringent limitations to minimize privacy risks. Account information is retained only while your account remains active or as required to provide services, and is promptly deleted or anonymized upon account termination except where retention is legally required. Payment information is retained only as required for financial reporting and tax compliance, with personal identifiers removed when no longer needed for these purposes. Support communications are retained to provide ongoing support and service improvement, with regular reviews to determine when such retention is no longer necessary. Technical data is retained in anonymized form for limited periods as necessary for service operations, and is regularly purged according to established data retention schedules. When retention is no longer necessary for any category of information, data is securely deleted or anonymized according to established data destruction protocols that prevent recovery.

4. DATA PROTECTION MEASURES

4.1 Technological Safeguards

We implement comprehensive security measures to protect user information from unauthorized access, disclosure, alteration, and destruction. All data transmitted between your devices and our systems is protected with encryption protocols to maintain confidentiality and integrity. Our security approach includes forward secrecy mechanisms to prevent compromise of past sessions. Our infrastructure is hosted in protected environments with comprehensive security measures including electronic access controls and continuous monitoring protocols. We perform regular security assessments and testing to identify and address potential vulnerabilities in our systems.

4.2 Operational Safeguards

We maintain strict operational protocols to protect user privacy throughout our organization. Access to systems containing user information is limited to essential personnel who require it to perform their job functions, implementing the principle of least privilege. All staff and contractors are bound by strict confidentiality agreements that prohibit unauthorized disclosure of user information and establish clear consequences for violations. Our systems are designed according to privacy-by-design principles that minimize data collection by default, incorporating privacy protection into the core architecture of our services. We conduct regular compliance reviews to ensure adherence to this Policy and applicable laws, adjusting our practices as necessary to maintain the highest standards of privacy protection.

4.3 Data Retention Limitations

We retain collected information only for the duration necessary to fulfill the purposes outlined in this Policy, applying stringent limitations to minimize privacy risks. Account information is retained only while your account remains active or as required to provide services, and is promptly deleted or anonymized upon account termination except where retention is legally required. Payment information is retained only as required for financial reporting and tax compliance, with personal identifiers removed when no longer needed for these purposes. Support communications are retained to provide ongoing support and service improvement, with regular reviews to determine when such retention is no longer necessary. Technical data is retained in anonymized form for limited periods as necessary for service operations, and is regularly purged according to established data retention schedules. When retention is no longer necessary for any category of information, data is securely deleted or anonymized according to established data destruction protocols that prevent recovery.

5. DISCLOSURE OF INFORMATION

5.1 No-Selling Commitment

BlackCobraVPN does not sell, rent, or otherwise monetize user data under any circumstances. Your information is never sold to advertisers, data brokers, or other third parties for marketing or profiling purposes. We consider your privacy to be paramount and fundamentally incompatible with the practice of data selling. This commitment applies to all user information, regardless of how it was collected or processed, and extends to all categories of data in our possession. Our business model is based on providing premium privacy services to users, not on extracting value from user data through sales or sharing arrangements.

5.2 Limited Third-Party Service Providers

We engage select third-party service providers solely to facilitate necessary business operations essential to delivering our services. Payment processors are used to facilitate subscription transactions securely while minimizing our access to sensitive financial information. Email service providers support the delivery of account-related communications in a reliable and secure manner. Cloud infrastructure providers host our services securely with appropriate technical and organizational safeguards. All service providers are bound by contractual obligations to process data solely as instructed by BlackCobra VPN, maintain appropriate security measures commensurate with the sensitivity of the data, prohibit use of data for any purposes beyond those specified in our agreements, and comply with applicable data protection laws in all jurisdictions where we operate.

5.3 Circumstances of Disclosure

BlackCobra VPN may disclose information in certain limited circumstances where required by law or necessary to protect legitimate interests. We may disclose information when compelled by valid legal process properly served under UAE law, such as a court order, subpoena, or search warrant. Disclosure may occur when necessary to protect our rights, safety, or the rights of users or third parties from imminent harm or illegal activity. In connection with corporate transactions such as a merger, acquisition, or sale of assets, information may be transferred with appropriate confidentiality protections and notifications to affected users. We may also disclose information when users expressly consent to specific disclosures for purposes they have authorized. In all cases, we limit disclosures to the minimum information necessary to fulfill the specific purpose of the disclosure.

5.4 Legal Process Response

When responding to legal requests for information, we apply rigorous scrutiny to protect user privacy to the maximum extent permitted by law. We carefully examine each request for legal validity and scope, ensuring it complies with applicable laws and is properly served through appropriate legal channels. We strictly limit disclosures to only what is legally required under the specific request, refusing to provide information beyond the scope of the legal obligation. Whenever permitted by law and the terms of the legal process, we notify affected users about requests for their information to provide transparency and opportunity for users to assert their rights. Most importantly, we cannot provide information we do not collect or possess, which is why our limited data collection practices serve as a fundamental privacy safeguard for our users.

6. INTERNATIONAL DATA TRANSFERS

BlackCobra VPN may transfer, process, and store information on servers located outside the user's country of residence, including the United Arab Emirates, in order to provide our global services efficiently. When transferring personal information across international borders, we implement appropriate safeguards to ensure data protection in accordance with this Policy and applicable laws, recognizing the varying legal standards that may apply in different jurisdictions. We assess the privacy laws and practices of each destination country to determine appropriate protection measures for user data. For users in the European Economic Area, we employ appropriate data transfer mechanisms (such as standard contractual clauses approved by the European Commission) to ensure adequate protection of transferred personal data in compliance with GDPR requirements. We commit to maintaining equivalent levels of protection for all user data regardless of where it is processed, applying our strict privacy standards consistently across all operating locations.

7. USER RIGHTS AND CHOICES

7.1 Access and Control

Users have comprehensive rights regarding their personal information collected and processed by BlackCobra VPN, reflecting our commitment to data subject autonomy. You have the right to request copies of personal information we hold about you, delivered in a structured, commonly used, and machine-readable format. You may request correction of inaccurate information in our records to ensure the integrity of your personal data. You can request deletion of personal information when it is no longer necessary for service provision or where other legal grounds for processing no longer apply. In certain circumstances, you may request limitation of processing without full deletion of your data. You have the right to request transfer of your data to another service provider where technically feasible. You may object to certain types of processing based on your particular situation, especially regarding processing based on legitimate interests. Where processing is based on consent, you maintain the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

7.2 Exercising Your Rights

To exercise these rights, users may utilize several convenient methods designed to be accessible and responsive. You can access many privacy settings directly within the BlackCobraVPN application, providing immediate control over certain aspects of your information. For more comprehensive requests, you may contact our dedicated Privacy Team at www.blackcobravpn.com with specific inquiries about your personal information. Alternatively, you may submit a request through our customer support channels at www.blackcobravpn.com, where our team is trained to properly route and handle privacy-related concerns. We commit to responding to verified requests within 30 days or as required by applicable law, and will not discriminate against you for exercising any of these rights. To protect your privacy and security, we may need to verify your identity before processing certain requests, using reasonable methods appropriate to the nature of the request.

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 Website Cookies

Our website uses cookies and similar technologies for essential functions, performance optimization, and analytical purposes, providing a balanced approach to functionality and privacy. Essential cookies are required for website functionality, enabling basic features such as page navigation, secure areas access, and e-commerce functionality; these cookies do not track users for marketing purposes and cannot be disabled as they are necessary for site operation. Performance cookies help us understand how visitors interact with our website by collecting and reporting information anonymously, allowing us to improve site structure and content based on user behavior patterns. Analytical cookies, which are only enabled with your explicit consent, provide more detailed insights into site usage that help us improve our website and services through a better understanding of user preferences and needs. Users can manage cookie preferences comprehensively through browser settings or our dedicated cookie preference center, maintaining control over their browsing experience.

8.2 Do Not Track

We respect user privacy choices by honoring Do Not Track (DNT) signals, as if available and activated, from browsers, demonstrating our commitment to privacy-respecting practices. When a DNT signal is detected from a user's browser, we automatically disable non-essential cookies and analytics collection for that browsing session, limiting data collection to only what is necessary for basic site functionality. This practice acknowledges and implements the user's expressed preference against tracking, going beyond minimum compliance requirements to actively respect privacy choices. Our systems are configured to detect DNT signals from all major browsers and apply consistent privacy-protective measures regardless of the specific browser technology used. This approach aligns with our broader philosophy of empowering users with meaningful control over their personal information and online privacy.

9. CHILDREN'S PRIVACY

BlackCobra VPN services are not directed to individuals under the age of 16, and we are committed to protecting children's privacy in compliance with applicable laws worldwide. We do not knowingly collect personal information from children under 16 years of age, and our Terms of Service explicitly prohibit use of our services by individuals under this age threshold. Our account creation processes are designed to reasonably detect and prevent registration by underage users without collecting unnecessary personal information. If we become aware that we have inadvertently collected personal information from a child under 16, we will promptly delete such information and take appropriate measures to terminate the associated account. Parents or guardians who believe we may have collected information from a child under 16 should contact us immediately at www.blackcobravpn.com with details so we can investigate and take appropriate action. We encourage parents and guardians to monitor and guide their children's online activities and to help enforce our age restrictions.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our practices, services, or applicable laws, ensuring that our privacy practices remain transparent and current. Material changes to our Policy will be communicated through prominent notice on our website, appearing for a reasonable period before the changes take effect to ensure users have adequate opportunity to review the modifications. The revised Policy will include an updated effective date clearly indicating when the new terms come into force. Your continued use of our services after such modifications constitutes acceptance of the updated Policy, though we encourage all users to review policy changes to stay informed about how their information is protected.

11. DATA BREACH NOTIFICATION

In the unlikely event of a data breach involving user information, we will respond swiftly and transparently to protect affected users and comply with applicable laws. We will promptly investigate the incident to determine its scope, nature, and impact, engaging cybersecurity experts when necessary to ensure a thorough assessment. We will notify affected users as required by applicable law, providing timely information about the breach and recommending steps they can take to protect themselves. Our team will take appropriate measures to address the breach and prevent recurrence, including technical remediation, security enhancements, and process improvements based on lessons learned. We will cooperate with regulatory authorities as required, providing necessary information and documentation while advocating for the interests of our users. Throughout this process, we will maintain transparency with affected users while ensuring that our communications do not compromise ongoing security efforts or investigations.

12. LIMITATION OF LIABILITY

BlackCobra VPN assumes no liability for the consequences of your unlawful, willful, or negligent activities while using our Services. You bear personal responsibility for ensuring that your use of our Services complies with applicable laws and respects third-party rights. We cannot be held liable for: (i) Information you voluntarily disclose through our Services to third parties; Loss of your personal data due to your failure to maintain the confidentiality of your account credentials; Temporary service interruptions necessary for maintenance, updates, or circumstances beyond our reasonable control; Consequential, incidental, indirect, or punitive damages arising from your use of our Services; (ii) Our liability shall be limited to the maximum extent permitted by applicable law. In jurisdictions where the exclusion or limitation of liability for consequential or incidental damages is not permitted, our liability shall be limited to the greatest extent allowed by law. This limitation of liability does not affect mandatory statutory rights that cannot be excluded under applicable law.

13. CONTACT INFORMATION AND DISPUTE RESOLUTION

For questions, concerns, or requests regarding this Privacy Policy or our privacy practices, we provide accessible communication channels to ensure responsive and helpful engagement. Our dedicated Privacy Team can be reached at www.blackcobravpn.com for general privacy inquiries, rights requests, and policy clarifications. For formal matters, our Data Protection Officer may be contacted at  BlackCobraVPN/Defied Trust Digital Trading (FZCO) [Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates]. We strive to resolve all privacy concerns promptly and satisfactorily through these direct channels, with trained team members ready to assist with your specific situation. For unresolved privacy concerns, users may also have the right to lodge a complaint with their local data protection authority, though we encourage initial communication with our team to allow us the opportunity to address concerns directly. We are committed to engaging constructively with users and regulatory authorities to ensure compliance with applicable privacy laws and to maintain the trust our users place in our services.

14. SEVERABILITY

If any provision of this Privacy Policy is found to be unenforceable or invalid by a court of competent jurisdiction, the remaining provisions will remain in full force and effect. The unenforceable or invalid provision shall be replaced by a valid and enforceable provision that comes closest to the intention underlying the unenforceable provision. This severability clause ensures that the overall Privacy Policy remains effective even if specific provisions cannot be enforced in certain jurisdictions or under particular circumstances. Our commitment to privacy protection extends to all aspects of our services and will be maintained regardless of the enforceability of individual policy provisions. We will promptly address any provisions found to be unenforceable by modifying them as necessary to comply with applicable law while preserving the privacy protections intended by this Policy.

15. GOVERNING LAW

This Privacy Policy is governed by and construed in accordance with the laws of the United Arab Emirates, reflecting the jurisdiction of our corporate establishment and primary operations. Any disputes arising under this Policy shall be subject to the exclusive jurisdiction of the courts located in the United Arab Emirates, specifically in the jurisdiction where Defied Trust Digital Trading - FZCO maintains its principal place of business. This choice of law provision does not diminish the rights of users in other jurisdictions to benefit from the protections of their local privacy laws, which we respect and comply with wherever we operate. In the event of conflict between this governing law provision and mandatory consumer protection or privacy laws in a user's jurisdiction, those local protections will apply to the extent required by applicable law. We remain committed to complying with all applicable privacy laws across the jurisdictions where we serve users, while maintaining the consistency and predictability provided by a unified governing law for our global Privacy Policy.

Effective Date: June 5, 2025

Last Updated: June 5, 2025