Cobalt Wolf VPN — Privacy Policy

Your privacy and data security are extremely important to us. We are committed to the responsible management, protection, and use of your personal information.

This Privacy Policy (the “Policy”) serves to explain what information Trinoxa Inc and its affiliates and subsidiaries (collectively, “we”, “us”, or “our”) collect, and how we use and protect your information when you use any mobile applications that we develop and are available for download in the Google Play Store (including Cobalt Wolf VPN).

1. What Information Do We Collect?

i. Device Information

We collect your device and network connection information in order to provide you better experience when you use our app.

This information depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use, and may include:

• SDK/API/JS code version, IP address, Network operator, system language, battery, device model, screen size, time zone, OS version, sim operator, Wi-Fi connection info.

ii. Data About Your Use of the Services

Information automatically recorded during your active use of the application, including:

• Permissions status.
• Whether the function is running normally, such as whether an issue is detected.
• Number of apps installed by users.
• Package name, first open timestamp, app brand, app network status, firebase_device_id, app model, SIM country, system language, etc.
• Advertisers may store or read cookies.

iii. Monetization and Analytical Information from Other Sources

Third-party SDKs integrated in our app may access your information, including:

• Google Advertising ID (GAID / AAID)
• Demographic data (e.g., determination of your IP address location)
• Data to fight against fraud (e.g., click fraud in advertising)
• Data to do advertising, marketing and performance analysis
• Advertisers may store or read cookies

iv. Android Advertising ID

We or our monetization partners may use the Google Advertising ID to serve relevant advertisements according to Google Play Developer policies.

v. Other Information

We may also collect other information which is not capable of identifying you personally, such as the date and time you open the app, network connection speed indicators, and anonymized interaction events.

vi. Designated Countries (EU / UK)

For individuals in the European Economic Area (EEA), the United Kingdom, or Switzerland, all data processing complies strictly with General Data Protection Regulation (GDPR) mandates.

2. How Do We Use the Information?

i. To Improve and Optimize the Services

• Update and develop the Services.
• Develop and improve user experience.
• Manage the technical relationship with you.
• Customize your service experience.
• Respond to your comments and questions and provide customer support.
• Provide relevant offers within the Services as well as in other websites and services.

ii. To Provide the Services

To deliver our core proxy connectivity, we process data necessary to:

• Allow you to use apps and the Services seamlessly.
• Operate the routing tunnel and maintain node connections.
• Provide and deliver products and services that you request.

iii. To Carry Out Activities Related to Advertisements and Marketing

We have a legitimate interest in processing necessary telemetry to:

• Deliver, target and improve our advertising and marketing materials.
• Measure the performance of ad impressions and installations.

iv. To Secure the Services

• Analyze and monitor the use of the Services to detect anomalies.
• Prevent cheating, crime, or malicious exploitation.
• Take action against fraudulent or misbehaving users.

3. What Information Do We Share?

As a general rule, we do not share, sell, or rent your personal information to third parties, except in the limited circumstances described below:

• With Service Providers: Trusted third-party vendors and analytical partners who assist us in operating our application, processing payments, or analyzing performance, subject to confidentiality agreements.
• For Legal Requirements: When required by valid legal process, subpoena, or applicable statutory mandates, or to protect our legal rights, property, or user safety.
• Business Transfers: In connection with any merger, sale of company assets, or acquisition, subject to the successor adhering to this Policy.

4. Important Permissions Requested

Depending on the device Android version and specific features you activate, Cobalt Wolf VPN may request access to:

• Storage / Media: Read and modify contents of storage for caching runtime configuration.
• Location: Approximate location (network-based) or precise location to recommend the geographically optimal proxy node.
• Device ID & Call Information / Phone Status: Read phone status and network identity to maintain connection stability across cellular cells.
• Wi-Fi Connection Information: View Wi-Fi connections to automatically safeguard your tunnel when untrusted networks are detected.
• Network Access & Wi-Fi Management: Full network access, view network connections, connect and disconnect from Wi-Fi.
• Notifications & Startup: Show active VPN status notification, run at startup if enabled, and prevent device from sleeping during active transfers.

5. Legal Basis of Personal Information Processing

We process Personal Data for the purposes set out in this Privacy Policy based on the following legal grounds:

• Consent: Where you have given specific consent for particular processing operations.
• Contractual Necessity: Where processing is required to deliver the core VPN connectivity requested by you.
• Legitimate Interests: To improve security, prevent fraud, optimize network routing, and sustain our business operations.
• Legal Compliance: To comply with mandatory obligations under applicable international and local laws.

6. Your Rights (GDPR & Global)

Under applicable data protection laws (including the EU General Data Protection Regulation), you enjoy the following rights:

1. Right to Withdraw Consent: Where processing relies on consent, you may withdraw it at any time.
2. Right of Access and Rectification: Request a copy of your personal data and demand correction of inaccuracies.
3. Right to Erasure (“Right to be Forgotten”): Request deletion of your personal data where retention is no longer necessary.
4. Right to Restriction: Request suspension of data processing under certain statutory circumstances.
5. Right to Object to Processing: Object to processing carried out under legitimate interests or direct marketing.
6. Right to Data Portability: Receive your provided data in a structured, commonly used, machine-readable format.
7. Notification to Third Parties: We will notify downstream processors of any rectification, erasure, or restriction requests.
8. Automated Decision-Making: You will not be subject to decisions based solely on automated profiling that produce legal consequences.
9. Right to Lodge a Complaint: Contact us directly at rayknows20226@gmail.com or lodge a grievance with your local supervisory authority.

7. Third-Party Partners’ Privacy Policy

Here we list the links to our third-party SDK and advertising partners’ privacy policies. These policies are governed by the respective third parties:

8. California Residents’ Privacy Rights (CCPA)

This separate notice applies solely to California consumers pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).

• Right to Request Information: You have the right to request disclosure of categories and specific pieces of personal information collected, sources, and commercial purposes over the prior 12 months.
• Right to Request Deletion: You have the right to request erasure of your personal information held by us, subject to statutory exemptions.
• How to Exercise Your Rights: Contact us via email at rayknows20226@gmail.com. We will verify your identity before fulfilling substantive requests.
• Non-Discrimination: We will not discriminate against you in terms of pricing, service quality, or availability for exercising your CCPA rights.
• Minors’ Data: We do not sell personal information of consumers, including those under 16 years of age.

9. Children’s Privacy

Our Services are not directed to children under 13 years of age. We do not knowingly collect personal identifiable information from children under 13. If we discover that a child under 13 has provided personal data, we immediately purge this data from our servers. Parents or guardians may contact us to request prompt removal.

10. Changes to This Policy

We may modify this Privacy Policy from time to time. When changes occur, we will update the "Effective Date" at the top of this document. Continued use of the application after changes constitute acceptance of the updated terms.

11. Contact Us

If you have any questions, comments, or concerns regarding this Privacy Policy or your data protection rights, please contact our privacy compliance team: