Privacy Policy

1. Data Controller

The data controller responsible for your personal data is:

NakibVPS, LLC 30 N Gould St Ste N Sheridan, WY 82801 United States Email: privacy@nakibvps.com

2. Information We Collect

We collect information in several ways when you interact with our Website and Services.

2.1 Information You Provide to Us

We collect information you voluntarily provide when you:

• Create an account or register for our Services

• Make a purchase or payment

• Contact our support team

• Subscribe to our newsletter

• Participate in surveys or promotions

This information may include:

• Identity Data: First name, last name, username

• Contact Data: Email address, phone number, billing address

• Financial Data: Payment card details, billing information (processed by our payment processors)

• Account Data: Username, password, account preferences

• Communication Data: Support tickets, emails, chat transcripts

• Identity Verification Data: Government-issued identification documents (passport, national ID card, driver's license) and selfie photographs, when required for fraud prevention and account verification purposes

2.2 Information Collected Automatically

When you access our Services, we automatically collect certain information, including:

• Device Data: IP address, browser type and version, operating system, device type

• Usage Data: Pages visited, time spent on pages, click patterns, referring URLs

• Location Data: Approximate geographic location based on IP address

• Log Data: Server logs, error logs, access timestamps

2.3 Information from Third Parties

We may receive information about you from third parties, including payment processors (transaction confirmations), analytics providers, and marketing partners. We may combine this information with other data we collect about you.

3. How We Use Your Information

We use your personal data for the following purposes:

3.1 Service Delivery

• To create and manage your account

• To provide, operate, and maintain our Services

• To process transactions and send related information

• To respond to your inquiries and provide customer support

• To send administrative information (service updates, security alerts)

3.2 Service Improvement

• To analyze usage patterns and improve our Services

• To develop new products, services, and features

• To conduct research and analysis

3.3 Marketing and Communications

• To send promotional communications (with your consent)

• To provide information about products and services that may interest you

• To personalize your experience on our Website

3.4 Security and Compliance

• To detect, prevent, and address fraud and abuse

• To verify customer identity through document verification (passport, national ID, selfie) for fraud prevention

• To enforce our Terms of Service and other policies

• To comply with legal obligations

• To protect the rights, property, and safety of NakibVPS and others

4. Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to fulfill our contractual obligations to you (e.g., providing hosting services)

• Legitimate Interests: Processing necessary for our legitimate business interests (e.g., fraud prevention, service improvement, marketing), provided these interests do not override your rights

• Consent: Where you have given explicit consent (e.g., marketing emails). You may withdraw consent at any time

• Legal Obligation: Processing necessary to comply with applicable laws and regulations

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and track information about your browsing activity. For detailed information about the cookies we use and your choices, please see our Cookie Policy.

5.1 Types of Cookies We Use

• Essential Cookies: Required for the Website to function properly (authentication, security)

• Functional Cookies: Remember your preferences and settings

• Analytics Cookies: Help us understand how visitors interact with our Website

• Payment Cookies: Used by payment processors (Stripe) to process transactions securely

5.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent. Note that disabling certain cookies may affect the functionality of our Services.

6. Disclosure of Your Information

We may share your personal data in the following circumstances:

6.1 Service Providers

We share information with third-party vendors who perform services on our behalf, such as payment processing, data analysis, email delivery, hosting, and customer service. These providers are contractually obligated to protect your data and use it only for the purposes we specify.

6.2 Business Transfers

If NakibVPS is involved in a merger, acquisition, asset sale, or bankruptcy, your personal data may be transferred. We will provide notice before your data is transferred and becomes subject to a different privacy policy.

6.3 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Valid legal processes (subpoenas, court orders)

• Requests from government authorities

• To protect our rights, privacy, safety, or property

• To investigate potential violations of our Terms of Service

6.4 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so.

7. Sub-Processors and Third-Party Services

We use the following categories of third-party service providers (sub-processors) to help deliver our Services:

• Payment Processors: Stripe, PayPal — to securely process payments

• Infrastructure Providers: Data center and server infrastructure providers

• Email Services: Transactional and marketing email delivery services

• Analytics Services: Website analytics and performance monitoring

• Customer Support Tools: Help desk and ticketing systems

All sub-processors are bound by data processing agreements that require them to protect your personal data in accordance with applicable law.

8. International Data Transfers

NakibVPS is based in the United States. If you access our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States and other countries where our servers or service providers are located.

For EEA/UK/Swiss Users: When we transfer personal data outside the EEA, UK, or Switzerland, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission

• Data processing agreements with our service providers

• Where applicable, reliance on adequacy decisions

By using our Services, you consent to the transfer of your information to the United States and other jurisdictions as described in this Policy.

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. The specific retention periods depend on the type of data:

When retention periods expire, we securely delete or anonymize your personal data.

10. Your Privacy Rights

10.1 Rights for All Users

Regardless of your location, you have the right to:

• Access the personal data we hold about you

• Request correction of inaccurate data

• Request deletion of your data (subject to legal retention requirements)

• Opt out of marketing communications

• Close your account

10.2 Additional Rights for EEA/UK/Swiss Residents (GDPR)

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR) and equivalent laws:

• Right of Access: Request a copy of the personal data we hold about you

• Right to Rectification: Request correction of inaccurate or incomplete data

• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data in certain circumstances

• Right to Restrict Processing: Request that we limit how we use your data

• Right to Data Portability: Receive your data in a structured, machine-readable format

• Right to Object: Object to processing based on legitimate interests or for direct marketing

• Right to Withdraw Consent: Withdraw consent at any time where we rely on consent for processing

• Right to Lodge a Complaint: File a complaint with your local data protection authority

10.3 California Residents (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with additional rights:

• Right to know what personal information we collect, use, and disclose

• Right to delete your personal information

• Right to opt out of the sale of personal information (we do not sell personal information)

• Right to non-discrimination for exercising your privacy rights

10.4 Exercising Your Rights

To exercise any of these rights, please contact us at privacy@nakibvps.com. We will respond to your request within 30 days (or sooner if required by law). We may need to verify your identity before processing your request. There is no fee for making a request, but we may charge a reasonable fee for repetitive, excessive, or unfounded requests.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (TLS/SSL) and at rest

• Firewalls and intrusion detection systems

• Access controls and authentication measures

• Regular security assessments and updates

• Employee training on data protection

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials.

12. Data Breach Notification

In the event of a data breach affecting your personal data, we will notify you and the relevant supervisory authorities as required by applicable law. For breaches affecting EEA/UK residents, we will notify the appropriate data protection authority within 72 hours of becoming aware of the breach, where feasible. We will also notify affected individuals without undue delay if the breach is likely to result in a high risk to their rights and freedoms.

13. Identity Verification

Why We May Request Identity Documents: To prevent fraud, comply with anti-money laundering regulations, and protect both our customers and our services, we may request identity verification from new customers or when suspicious activity is detected.

13.1 Documents We May Request

• Government-issued photo identification (passport, national ID card, or driver's license)

• A selfie photograph holding your ID document

• Proof of address (utility bill, bank statement) in certain cases

13.2 How We Handle Identity Documents

• Purpose Limitation: Documents are used solely for identity verification and fraud prevention

• Secure Transmission: All documents must be submitted through our secure client portal

• Encryption: Documents are encrypted in transit and at rest

• Limited Access: Only authorized personnel involved in fraud prevention can access these documents

• Retention: Successfully verified documents are deleted within 30 days; documents for flagged accounts are retained for up to 1 year

• No Third-Party Sharing: Identity documents are never shared with third parties except as required by law enforcement or legal process

13.3 Your Rights Regarding Identity Documents

You may request deletion of your identity documents at any time after successful account verification by contacting privacy@nakibvps.com. Please note that requesting deletion before verification may result in account suspension or order cancellation.

14. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@nakibvps.com. If we discover that we have collected personal information from a child under 18, we will promptly delete that information.

15. Third-Party Websites and Links

Our Website may contain links to third-party websites, services, or applications that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites. We encourage you to review the privacy policy of every site you visit.

16. Do Not Track Signals

Some browsers have a "Do Not Track" (DNT) feature that sends a signal to websites requesting that your browsing not be tracked. Our Website does not currently respond to DNT signals. However, you can manage your cookie preferences as described in our Cookie Policy and Section 5 of this Privacy Policy.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated Privacy Policy on our Website and updating the "Last Updated" date. For significant changes, we may also notify you via email. Your continued use of the Services after any changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically.

18. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

NakibVPS, LLC 30 N Gould St Ste N Sheridan, WY 82801 United States

Privacy Inquiries: privacy@nakibvps.com General Contact: contact@nakibvps.com Website: https://nakibvps.com

For EEA/UK Residents: You also have the right to lodge a complaint with your local data protection supervisory authority if you believe we have not complied with applicable data protection laws.