Personal Data Processing Policy

1. General Provisions

1.1. This Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been developed in accordance with the applicable requirements of Federal Law No. 152-FZ of the Russian Federation dated July 27, 2006, “On Personal Data,” the legislation of the Republic of Kazakhstan on personal data and its protection, and other applicable laws and regulations.

1.2. This Policy establishes the procedures for processing, storing, using, and protecting the personal data of users of the POTOK VPN / Potok Service (hereinafter referred to as the “Service”).

1.3. Personal data processing within the Service is carried out by the following entities (hereinafter collectively referred to as the “Operators”):

1.4. The Operators are committed to respecting the rights and freedoms of Users when processing personal data, including the right to privacy and the protection of personal information.

1.5. This Policy applies to all official POTOK VPN interfaces, including:

1.6. This Policy applies to personal data collected during registration, subscription purchases, VPN connections, technical support requests, and interactions with other features of the Service.

2. Definitions

2.1. Personal Data — any information relating directly or indirectly to an identified or identifiable natural person.

2.2. User — any individual who uses the website, applications, Telegram bot, user dashboard, or other features of POTOK VPN.

2.3. Personal Data Processing — any operation or set of operations performed on personal data, including collection, recording, organization, accumulation, storage, modification, use, transfer, anonymization, restriction, and deletion.

2.4. Automated Processing — processing of personal data using computer technology.

2.5. Operator — an entity that independently or jointly with others determines the purposes and means of personal data processing.

2.6. Anonymization — actions that make it impossible to identify a specific User without additional information.

2.7. Service — the POTOK VPN / Potok Service software and technical system, including VPN infrastructure, applications, subscription management, user dashboard, Telegram bot, and related components.

2.8. Cookies — small pieces of data that may be stored on a User’s device to ensure website functionality, authentication, and preservation of user preferences.

3. Personal Data Collected and Processed

3.1. Depending on how the Service is used, the Operators may process the following categories of personal data.

3.2. The Operators do not request or use special categories of personal data concerning racial or ethnic origin, political opinions, religious beliefs, health, or intimate life for the provision of the Service.

3.3. Banking details and payment information may be processed directly by third-party payment providers. The Operators receive only the information necessary to confirm payments, manage subscriptions, process refunds, and fulfill contractual obligations.

3.4. When using a VPN connection, network traffic is technically transmitted through the Service’s infrastructure. Technical connection information may be processed to maintain connectivity, manage traffic limits, diagnose issues, and protect the infrastructure.

3.5. The processing of technical information is limited to the purposes of providing the Service and ensuring its security. This Policy does not constitute a guarantee of complete anonymity on the Internet.

4. Purposes of Personal Data Processing

4.1. Personal data is processed for the following purposes:

4.2. The Operators do not use personal data for purposes incompatible with those for which it was originally collected.

4.3. Advertising and marketing communications requiring separate consent under applicable law are sent only when an appropriate legal basis exists.

4.4. Users may opt out of non-essential marketing notifications by contacting support@potokservice.com.

5. Legal Basis for Personal Data Processing

5.1. Depending on the nature of the processing, the legal basis may include:

5.2. By providing information during registration, subscription purchases, or support requests, the User confirms that the information provided is accurate.

5.3. Where separate consent is required for specific processing activities, the Operators obtain such consent in accordance with applicable legal requirements.

5.4. Users have the right to withdraw previously granted consent. Withdrawal of consent does not prevent continued processing where another lawful basis exists.

6. Conditions for Processing and Storing Personal Data

6.1. Personal data may be processed using automated systems or by other means.

6.2. The Operators do not sell Users’ personal data to third parties.

6.3. Personal data may be shared with third parties to the extent necessary for the operation of the Service, including the following categories of recipients:

6.4. When using the Telegram bot, application stores, or third-party VPN clients, Users may also interact with independent platforms whose data processing practices are governed by their own terms and privacy policies.

6.5. Personal data is retained only for as long as necessary to achieve the purposes of processing, fulfill contractual obligations, or comply with legally required retention periods.

6.6. Once the purposes of processing have been fulfilled, or other legally prescribed grounds arise, personal data will be deleted, destroyed, or anonymized unless there is a lawful basis for continued retention.

6.7. Users may request the deletion of their account and associated personal data when they stop using the Service.

6.8. Account deletion may result in the termination of access to associated subscriptions and device settings. Certain payment and transaction records may be retained for periods required by applicable law.

7. Personal Data Protection

7.1. The Operators implement appropriate organizational and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, restriction, copying, disclosure, and distribution.

7.2. Depending on the nature of the data and infrastructure, these measures may include:

7.3. Access to personal data is granted only to authorized personnel to the extent necessary for performing their duties.

7.4. Despite the security measures implemented, data transmission over the Internet cannot be guaranteed to be completely secure against all possible threats.

7.5. Users are responsible for maintaining the confidentiality of their account credentials, connection links, and other access information provided by the Service.

8. Cross-Border Transfer of Personal Data

8.1. POTOK VPN uses technical infrastructure that may be located in different countries.

8.2. Depending on the features used and the locations of third-party service providers, personal data processing or transfer may involve cross-border operations.

8.3. Cross-border transfers of personal data are carried out on appropriate legal grounds and in compliance with applicable legislation.

8.4. With respect to personal data of citizens of the Russian Federation, the Operators undertake to comply with applicable Russian data localization requirements and the established rules governing cross-border data transfers.

8.5. Connecting to a VPN server located outside the User’s country does not, by itself, mean that all account information is transferred to a foreign entity in that country.

9. User Rights

9.1. Users have the right to:

9.2. To exercise these rights, Users may contact:

9.3. Users are encouraged to provide information sufficient to identify their account and describe the nature of their request.

9.4. The Operators may request additional information to verify the identity or authority of the requester and prevent unauthorized disclosure of personal data.

9.5. Requests are reviewed within the timeframes established by applicable legislation.

10. Use of Cookies

10.1. The POTOK VPN website and user dashboard may use cookies and similar technologies for the following purposes:

10.2. Users may restrict or disable cookies through their browser settings.

10.3. Disabling certain cookies may affect the functionality of the website or user dashboard.

10.4. If the Service uses optional analytics or advertising technologies that require consent, such consent will be obtained separately where required by law.

11. Changes to This Policy

11.1. The Operators reserve the right to update this Policy in response to changes in the Service, personal data processing procedures, or applicable legal requirements.

11.2. An updated version of this Policy becomes effective upon publication unless otherwise specified.

11.3. The current version of this Policy is made available on the official website: https://potokservice.com/

11.4. Users are encouraged to review this Policy periodically to stay informed about changes.

12. Contact Information and Final Provisions

12.1. For questions regarding personal data processing, protection, correction, or deletion, Users may contact POTOK VPN support.

12.2. Matters not expressly addressed in this Policy are governed by applicable legislation.

12.3. This Policy is a publicly available document and applies to Users of all official POTOK VPN / Potok Service interfaces.

Related Documents

• Public Offer
• Refund Policy