Hotspot Shield Review: Hydra Protocol Fast, But US-Based Privacy Risk
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6.2
Adequate
Fast proprietary protocol, but US-based with a history of privacy controversies.
Best for: Speed-focused users who prioritize performance over privacy
Not for: Privacy-conscious users (past tracking/data sharing allegations, Aura ownership)
Leak Tests
Kill Switch
Split Tunneling
No-Logs Audit
Hotspot Shield VPN has been built around its own patented Aura Hydra protocol and has been proven to increase download speeds, especially over long distances.
Our review takes an in-depth look at the ins and outs of this well-known VPN, including its security strength, streaming capabilities, additional features, and price tag, to help you find out if Hotspot Shield is the right VPN for you.
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45
days
Money-back guarantee - cancel anytime, no questions asked.
Hotspot Shield was originally founded in 2008 by AnchorFree, which is now known as Pango. Pango also owns Betternet and UltraVPN, and is based in the US (which is a Five-Eyes Alliance country).
Reviewed by VPNTesting.com Research Team | Fact-checked by Editorial | Last verified: 31 March 2026 | Backed by 29,688+ real-world leak tests | Independently AuditedOwnership Verified | Why trust us?
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6.2
Our rating
$2.99/mo
Best price
1,800+
Servers
80
Countries
5
Devices
USA
Jurisdiction
45 days
Money-back
Pros & Cons
Hotspot Shield by the Numbers
Our Take
1,800+ servers across 80 countries with 5 simultaneous connections. The 5-device limit is the most restrictive among premium VPNs. Owned by Point Wild (part of Aura).
Plans, Products & Prices
Our Take
Mid-range pricing. The Premium Family plan covers up to 5 family members (25 devices total). A free plan exists but is ad-supported and limited. The 45-day money-back guarantee gives generous testing time.
Hotspot Shield is one of the few services that offers a free VPN plan. The free version is limited (for instance, users are limited to one connection, one server location, and cannot use it for streaming or gaming), but it doesn’t cap user data and still provides the same military-grade encryption.
If you decide to upgrade to Hotspot Shield VPNs’ full features and capabilities, there are several subscription options you can choose from:
Free Trial or Money Back Guarantee
Hotspot Shield VPN offers a seven-day free trial of its premium service and a 45-day money-back guarantee on all paid subscriptions (not just the year plan).
Premium
(Up to five devices)
- Monthly – $12.99/month
- Yearly – $7.99/month, billed immediately at $95.99
Premium Family
(Up to 25 devices – five for each family member profile)
- Monthly – $19.99/month
- Yearly – $11.99/month, billed immediately at $143.88
Ways to Pay
Hotspot Shield Payment Methods
Streaming TV & Movies With Hotspot Shield
Our Take
Servers are optimized for streaming and gaming. Works with most major platforms. The Hydra protocol's speed advantage helps with buffer-free 4K streaming.
We tested how Hotspot Shield VPN works with some of the top streaming services.
Netflix is well-known for geo-restricting its content, but when using Hotspot Shield we were able to unblock Netflix and access US content from a WiFi connection in Europe.
Alongside Netflix, Hotspot Shield works with other streaming services, such as:
| Hotspot Shield Streaming Compatibility | ||
|---|---|---|
| Service | Last Tested | Source |
| |
28 Mar 2026 (re-test due) | Hotspot Shield confirmed |
| |
Re-test scheduled | Not yet independently tested |
| |
28 Mar 2026 (re-test due) | Hotspot Shield confirmed |
| |
28 Mar 2026 (re-test due) | Hotspot Shield confirmed |
| |
28 Mar 2026 (re-test due) | Hotspot Shield confirmed |
Streaming compatibility tested by VPNTesting.com. Results may vary by server and region.
Desktop and Mobile Apps
Hotspot Shield VPN supports a variety of platforms, with apps for popular operating systems and devices.
Browser Extensions
If you like to do everything from within your internet browser, it’s worth trying the Chrome browser extension that Hotspot Shield VPN has on offer.
It’s easy to install from the Chrome web store, and it will fully encrypt your browser to keep your data safe from your ISP or other third parties.
It should be noted that the extension doesn’t include the full features of the VPN, an ad blocker, antivirus, or specific malware-blocking tools.
Hotspot Shield VPN Proxy by Pango also has a browser extension on the Firefox Browser Add-On store, though this hasn’t been updated since 2020.
Get Hotspot Shield Now
45
days
Money-back guarantee - cancel anytime, no questions asked.
Streaming on TV & Other Devices
Not only does Hotspot Shield VPN work with some of the top streaming platforms, but it’s also compatible with many home TV devices.
Amazon Fire TV Stick or Other Smart TVs
Hotspot Shield VPN is compatible with any smart TV that features the Google Play Store – just download the app and you can start using the VPN on your TV.
It also has a downloadable app for Amazon Fire TV and Sticks.
If you don’t have a compatible smart TV or Amazon Fire TV Stick, you can also purchase the Android TV Box which will allow you to download the Hotspot Shield app and connect it to any TV you like.
Xbox & PlayStation
Hotspot Shield VPN works with any gaming console that can connect to your router. So, whether you’re a fan of Xbox, Playstation, or the Nintendo Switch, Hotspot Shield VPN has you covered.
Installing the VPN on your router is probably the best option, as then you can easily have Hotspot Shield VPN protect any device in your home without the need for additional apps.
Performance & Speed
Our Take
Hotspot Shield's proprietary Hydra protocol is genuinely fast - often the fastest in independent speed tests. The trade-off: Hydra is closed-source and proprietary, so you can't verify what it does. WireGuard and OpenVPN are also available.
When it comes to choosing a VPN, many will want to download at fast speeds, so will ultimately choose the fastest VPN that will have minimal effect on their online experience and bandwidth.
We put Hotspot Shield VPN to the test, using servers in both the UK and the USA. The connection speeds below show how those Mbps stacked up:
Privacy & Security
Our Take
US jurisdiction (Five Eyes). Hotspot Shield faced controversy: a 2017 FTC complaint alleged deceptive privacy practices in the free tier. The paid service has since been restructured, but the history is concerning. No public independent audit of the no-logs policy.
Hotspot Shield Infrastructure & Trust
| Obfuscated Servers | ✗ |
| Tor/Onion Support | ✓ (manual setup) |
| Port Forwarding | ✗ |
| RAM-Only Servers | ✗ |
| Independent Audit | ✓ Aon Aug 2023 |
| Config File Export | ✗ |
We monitor Hotspot Shield's legal documents daily for changes and summarize what changed.
Last checked: 13/04/2026 · 2 changes detected since 30/03/2026
minor
Terms of Service
13/04/2026
The provided documents appear to be identical versions of Hotspot Shield's Terms of Use, both dated October 31, 2024. The only observable differences are in website tracking parameters (different vh= values in URLs), which are cosmetic technical identifiers and do not affect the actual terms, data practices, privacy policies, or user rights.
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This website utilizes technologies such as cookies to enable essential site
functionality, as well as for analytics, personalization, and targeted
advertising. To learn more, view the following link: Privacy Policy
[https://www.hotspotshield.com/privacy-policy/]
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HOTSPOT SHIELD TERMS OF USE
Last Updated October 31, 2024 (“Date of Publication”)
IMPORTANT: PLEASE READ THE FOLLOWING TERMS AND CONDITIONS CAREFULLY BEFORE USING
THE SERVICES WE PROVIDE (AS DEFINED BELOW), AS THESE TERMS OF SERVICE CONSTITUTE
A BINDING CONTRACT BETWEEN US.
IMPORTANT NOTICE REGARDING ARBITRATION FOR U.S. CUSTOMERS: WHEN YOU AGREE TO
THESE TERMS YOU ARE AGREEING (WITH LIMITED EXCEPTIONS) TO RESOLVE ANY DISPUTE
BETWEEN YOU AND US THROUGH BINDING, INDIVIDUAL ARBITRATION RATHER THAN IN COURT.
PLEASE REVIEW SECTION 3.19 “DISPUTE RESOLUTION” BELOW FOR DETAILS REGARDING
ARBITRATION AND READ THESE TERMS CAREFULLY.
PART 1. INTRODUCTION. Thank you for choosing Hotspot Shield! Before accessing or
using our products, please read these Hotspot Shield Terms of Service (the
“Terms” or “Agreement”) carefully. Among other things, the Terms outline in
detail what We provide you, Our customers, and each of our rights and
obligations pertaining to your access and use of ‘Hotspot Shield’ VPN products,
services, applications/apps or other offerings, including any Software (as
described below), and any associated documentation (collectively, the “Products”
or “Services, or individually a “Product” or “Service”) that We provide through
mobile or desktop applications or websites We operate, including
https://www.hotspotshield.com. [https://www.hotspotshield.com] By accessing and
using Our Services, you represent that you have read, understood, and agreed to
these Terms, including any applicable policies and additional terms specified
herein, which form a binding contract with Us.
To help you understand, here is a quick breakdown:
* Who are We?
As used in these Terms, “We”, “Us”, or “Our” means Anchorfree, LLC, with
offices at Office 250 Northern Ave, 3rd Floor, Boston, MA 02210, United
States, or Pango Gmbh, depending on where you make your purchase, together
with certain of our affiliates.
* What are these Terms?
These Terms, including any applicable product specific terms or policies
incorporated herein, represent a binding contract between Us and you that
govern Our provision, and your use, of the Services and outlines each of Our
responsibilities. Our Services are offered to you conditional on your
acceptance of these Terms. We encourage you to read Our Terms carefully, as
the Terms cover the scope of your access and use of the Services and Our
websites, and describe your rights and obligations.
* How do you agree to our terms?
You are agreeing to these Terms, and accept to be bound by them, when you
sign up for or use the Services and any time you access or use the Services.
These Terms constitute a binding legal agreement between Us and you.
* What is covered by these Terms?
These Terms describe how the Services will be provided and may be used, and
our responsibilities to each other as of November 30, 2024. To make it easier
to navigate, we’ve divided the Terms into four parts:
(1) Introduction – This part explains who We are and that the Terms form an
agreement between Us and you.
(2) Commercial Terms – This part covers terms related to your subscription to
the Services, including billing/payment, automatic renewals, plan switching
or cancellation, and refunds when billing is handled by Us. Additional terms
applicable to residents of Canada are addressed here as well. Please note
separate terms may apply if you didn’t purchase the Services directly from
Us.
(3) General Legal Terms – This part covers the general legal terms that make
up the contractual relationship between you and Us, and outlines each party’s
rights and obligations, including those related to eligibility, user
accounts, dispute resolution, indemnification, and liability.
(4) License Terms – This part sets forth the terms that govern how We give
you a license to access and use the Services. The Services are licensed, and
not sold.
PART 2. COMMERCIAL TERMS
2.1 Subscription. Our Services are generally made available on a subscription
basis, which means you subscribe to receive access to Our Services for a set
period of time based on your selection at time of enrollment (“Subscription”),
which is typically a one month or one year term (“Subscription Term”) in
exchange for your payment of the fees that apply to the Subscription Term for
the Service you enroll in (“Subscription Fees”). If applicable and you elect to
enroll in a Subscription, you will be billed in advance for your Subscription
when you enroll, and thereafter on a recurring and periodic basis (“Billing
Cycle”). The length of your Billing Cycle will depend on the Subscription or
Subscription Term you select at the time of enrollment. You agree to pay for the
Subscription that you select. Your applicable Subscription Fee will be
identified, in U.S. dollars, at the time of enrollment, and renewal, each as
applicable. You authorize Us to automatically charge the Subscription Fees
applicable to your Subscription (plus any applicable taxes and fees) to the
payment method our service provider has on file based on your Billing Cycle.
2.2 Automatic Renewals; Cancellation. At the end of each Billing Cycle, your
Subscription will automatically renew for an additional Subscription Term at the
price or Subscription Fee shown in your account dashboard or otherwise
communicated to you by us at the time of renewal (“Renewal Price”), unless: (a)
you or We have canceled your Subscription at least one (1) day prior to the
commencement of your next Billing Cycle or in accordance with Section 2.4 below,
or (b) a fee change is effectuated, in which case We will give you prior notice
in accordance with Section 2.6. We will email you in advance to let you know
your Subscription is due for renewal and provide the applicable Renewal Price in
your account dashboard.You may cancel your Subscription by contacting us via the
customer support email address in your account dashboard, which is
[email protected] [[email protected]] as of the Date of
Publication (“Support Email”), or by logging into your account to cancel
directly. For more information on how to cancel, please visit our support page
on how to cancel your subscription
[https://support.hotspotshield.com/hc/en-us/articles/203412120-How-do-I-cancel-my-Hotspot-Shield-subscription].Once
We or you have canceled your Subscription, your recurring Subscription Fees for
the Services will no longer be charged to the payment method We have on file for
your account, and your Subscription will remain active only until the end of the
then current Subscription Term. Depending on the specific plan or offer you
subscribed to, you may also be eligible for a refund or credit in accordance
with the applicable terms set forth herein.
2.3 Plan Switching. In the event you switch your Subscription plan or selection,
We will send you an email confirming the plan change, reflect any credit or
amount owed due to the difference in changing plans, and the Billing Cycle and
Renewal Price for the updated plan. Your plan switch will be effective as of the
date shown in your account profile and confirmation email, which will generally
be tied to the date you elect to switch your plan.
2.4 Free Trials. We may, from time to time, offer limited period free trial
subscriptions to certain Services for a specified time (“Free Trial”) at Our
discretion. If We offer you a Free Trial, the specific terms of your Free Trial
will be provided to you at signup and/or in the related promotional materials
(such as, but not limited to, emails), describing the Free Trial and your use of
the Free Trial is subject to your compliance with such specific terms applicable
to the Free Trial. Free Trials are only available to users who have not
subscribed to a Service in connection with another Free Trial offer in the last
12 months (or other duration as clearly defined by Us in the terms provided
during the registration process or applicable promotional materials for the
applicable Free Trial offered to you). At any time, and without notice, We
reserve the right to (i) modify the terms and conditions of the Free Trial
offer, or (ii) cancel such Free Trial offer.
You may be required to enter your billing information to sign up for the Free
Trial. If you do enter your billing information when signing up for the Free
Trial, you will not be charged by us until the Free Trial has expired (i.e. end
of your specified free trial period). You may cancel your Subscription within at
least 24 hours prior to the end of your Free Trial through your Product
dashboard. Unless you cancel during the aforementioned time frame, you will be
automatically enrolled in the type of Subscription you selected at the time of
your sign up and be charged the applicable Subscription Fees (plus any
applicable taxes and fees). Before charging you at the end of your Free Trial
period, We will notify you of the applicable fees.
2.5 Payment Methods. Payment of a Subscription Fee is required to use the
Services and a valid payment method is required to process the payment for your
Subscription. You shall provide us or Our third-party payment processor with
accurate and complete billing information, which may include full name, address,
state, zip code, and valid payment method information. By submitting such
payment information, you automatically authorize us to charge all Subscription
fees incurred through your account to any such payment instruments.
If you purchased from Us, all amounts paid are non-refundable, except as
otherwise stated in these Terms or required by applicable law. You further agree
to be responsible for any applicable state, federal or other taxes that may be
associated with the Services, including sales taxes, along with any transaction
fees and currency conversions added by your financial institution and
intermediaries.
If the billing method you provide is a credit or debit card (“Payment Card”),
you: (a) represent that you are authorized to use such Payment Card; (b)
authorize us to charge your Payment Card periodically for the Subscription Fees
when due, including upon enrollment for the Services and each subsequent Billing
Cycle; (c) agree to keep your Payment Card details valid and current; and (d)
agree to pay any processing fees that are charged by the third-party payment
processors or Payment Card issuer.
If your Payment Card is declined when We attempt to charge it, We may try to
charge it again at a later time. If We do not receive payment, We may suspend or
terminate your Subscription.
2.6 Fee Changes. We may change the fees that We charge for the Services at any
time, at Our sole discretion, provided that We will give you at least thirty
(30) days of prior notice of such changes. Unless otherwise specified in such
notice to you, any changes to the Subscription Fees will take effect as of the
Billing Cycle immediately following Our notice to you.
2.7 Data Charges. You are responsible for any charges that may apply to your use
of Our Services, including text messaging and data charges if you access or use
the Services on your mobile or other device. If you're unsure what those charges
may be, you should ask your mobile operator, internet, or other service provider
before using the Services.
2.8 Payment Processors.Your purchases or payment for the Services with Us may be
handled by an authorized payment processing partner, service provider, or
affiliate of Ours. To find out more on how payment companies process your
personal data, please refer to Our Privacy Policy.
[https://www.hotspotshield.com/privacy-policy/]
2.9 VPN Authorized Resellers. Our Services may be, from time to time, made
available through authorized resellers. If you licensed or enrolled in our
Services via a reseller, and not with Us directly, the reseller you used
controls the billing arrangements between you and such reseller. Should you have
any billing or payment related questions, please contact your reseller directly,
as any disposition of refunds, if owed, is between you and the reseller you
used, and We will not be able to provide you with any refund.
2.10 Free Services; Advertisements. Some of Our Services are available for free,
without requiring payment (“Free Service”), and some of Our Services are
fee-bearing and require periodic payment depending on your Subscription Term
(“Paid Service” or “Premium Service”). If you choose to use a Free Service, we
may deliver third-party advertisements (“Advertisements”) to you. If you choose
to use a Paid Service, we will not deliver any Advertisements to you.
If you are using a Free Service, we or the Free Service may deliver
Advertisements. You hereby acknowledge and consent that We may deliver
Advertisements to overlay a page or as an interstitial. We reserve the right to
prevent your access to the Service or continued use thereof if you violate this
Agreement, engage in fraud or copyright infringement, or employ an ad-blocking
product or other software or mechanism that prevents you from participating in
advertising programs, surveys, or other activities that involve delivery of
Advertisements or other monetization of the Free Service. For clarity, We do not
endorse any information, materials, products, or services contained in or
accessible through Advertisements, and the presence of certain Advertisements
does not represent or imply our endorsement or support thereof (including the
providers of such Advertisement or the content advertised). Accordingly, your
correspondence or business dealings with, or participation in promotions of,
advertisers found on or through the Service are solely between you and such
advertiser. ANY ACCESS AND USE OF ADVERTISEMENTS, INCLUDING ANY INFORMATION,
MATERIALS, CONTENT, DATA, PRODUCTS, AND/OR SERVICES ON OR AVAILABLE THROUGH
ADVERTISEMENTS IS SOLELY AT YOUR OWN RISK.
2.11 Additional Information Specific to Residents of Canada. This Section 2.11
sets out additional information for residents of Canada:
1. Your Subscription. The term of your Subscription (whether it is yearly or
monthly) and the payment terms applicable to your Subscription (both the
amounts you pay, and when you pay them) will be set out before you purchase
your Subscription. For monthly Subscriptions, your Subscription will
continue until canceled in accordance with Section 2.2 above.
2. Specific Terms Regarding Renewals.
1. For Individuals Residing Outside of the Province of Quebec: For yearly
Subscriptions, we will send you notice as required by law to inform you
that your Subscription will be automatically renewed, unless you cancel
it. If you do not cancel, your Subscription will be automatically renewed
in accordance with Section 2.2 above.
2. For individuals Residing in the Province of Quebec: Yearly Subscriptions
automatically renew on a month-to-month basis at the end of your yearly
Subscription. We will send you notice as required by law to inform you
that your Subscription will automatically renew on a month-to-month basis
at the end of the first year of your Subscription, unless you cancel it.
If you do not cancel, your Subscription will be automatically renewed on
a month-to-month basis at applicable Renewal Price communicated to you,
unless: (1) you or we have canceled your Subscription at least one (1)
day prior to the commencement of your next Billing Cycle or in accordance
with Section 2.2 above; or (2) an event under Section 2.5 occurs in which
case we will give you prior notice according to that Section. We will
email you in advance to let you know your Subscription is due for renewal
and provide the Renewal Price in your account dashboard. You may cancel
your Subscription by contacting us via the phone number in your account
dashboard or by logging into your account and making the selections to
cancel. Once We or you have canceled your Subscription, your recurring
Subscription Fees for the Services will no longer be charged to the
payment method we have on file for your account, and your Subscription
will remain active only until the end of the current Billing Cycle.
3. Money Back Guarantee. If applicable, the conditions and any limitations or
exclusions relating to any money back guarantee We offer for a Service will
be set out at the time of your purchase.
4. Amendments. We may amend, modify, or update all or any portions of the Terms
or the Services at any time and from time to time, in Our sole discretion,
and including without limitation, prices, payment terms, warranties and
cancellation policies, subscription terms, term structure and the nature,
content, and features of Our Services. If We do so, We’ll let you know
either by posting the updated Terms on Our website or through other
communications. Where required by law or at Our discretion, we will send a
message to the email address (or other contact information you have
provided, at our discretion) associated with your account, setting out the
new or amended clause and the clause as it read formerly, and the date of
when such change will go into force, at least thirty (30) days in advance of
the change. Where required by law, or at Our discretion, if you do not agree
with any modification, then you may terminate the Services, without cost,
penalty or cancellation indemnity. You may do so in accordance with the
notice, and for individuals residing in Quebec, by sending us notice to that
effect no later than thirty (30) days after the amendment comes into force.
PART 3. GENERAL LEGAL TERMS
3.1 Agreement to These Terms. You may only access and use the Service in
accordance with these Terms. You represent that you have read, understood, and
agree to be bound by these Terms in connection with your access to and/or use of
the Services. If you do not agree to these Terms, you may not access or use the
Services. By using the Services, you will be deemed to have agreed to these
Terms.
3.2 Eligibility. Our Services are available to users who are Eligible.
“Eligible” means that (i) you are 18 years of age, or above the age of legal
majority in your jurisdiction of residence, or (ii) if you have not reached the
age of legal majority in your jurisdiction, but have the permission of a legal
parent or guardian to use the Service. Notwithstanding the foregoing, if you are
under 13 years of age, then you are not Eligible and may not use or access the
Service at any time, in any manner. By downloading/installing, using, or
accessing the Services, you represent and warrant that you are Eligible. Our
Services are not available to persons who are not Eligible and will not be made
available to any users who were previously suspended, terminated, or removed
from the Services by Us.
3.3 User Accounts, Data, and Passwords. You are fully and solely responsible and
liable for the content and data you enter into or process through Our Services.
You will need to register as a user and establish an account to access and use
the Services. Registration as a user or subscriber to the Services may require
both a username and a password. Your account is exclusively for you, and it
should not be for use by other third parties for any purpose. Your usernames and
passwords should be treated as confidential information. You may not sell,
transfer or allow others to use your account credentials, and agree not to
disclose your password to any third party. You may not attempt to gain
unauthorized access to accounts of other users. Anyone with knowledge of both
your username and password can gain access to the restricted portions of the
Services and your account. You are responsible for safeguarding the password
that you use to access the Services and for any activities or actions under your
account, including your password and whether your password is with Our Services
or third-party service. You must notify Us immediately upon becoming aware of
any breach of security or unauthorized use of your account. You may not use as a
username the name of another person or entity that is not lawfully available for
your use, a name or trademark that is subject to any rights of another person or
entity other than you without appropriate authorization, or a name that is
otherwise offensive, vulgar or obscene. We reserve the right to block a user’s
account and/or prohibit a user from using the Services in the event of any
suspected or actual fraud, illegal activity, or violation of these Terms, as
determined in Our sole discretion.
3.4 Access. To use Our Services, you must be Eligible, establish a user account,
and enroll in a Subscription to the Services. In order to access and use certain
Services, you may be required to download and install certain Software on a
device. Please refer to Part 4 - License Terms for the terms and conditions
applicable to the use of Software. As used in these Terms, “Software” means any
mobile, web, and desktop software applications and any other software (including
any releases, updates, enhancements, or revisions) and any documentation that
accompanies or is made available in connection with such software provided by Us
to you for your use of the Services.
3.5. User Feedback or Submissions. If you provide any feedback, input,
suggestions, ideas, and/or reviews or other comments relating to the Services to
Us, either directly or through a third-party (such as, but not limited to, the
Apple App Store) (“Submissions”), then you grant, to the maximum extent
permitted by applicable law, Us and Our affiliated companies a perpetual,
irrevocable, worldwide, unlimited, transferrable, sublicensable, royalty-free,
and nonexclusive license to access, use, reproduce, create derivative works
from, modify, publish, edit, translate, distribute, perform, transform, display,
and otherwise exploit your Submission in any media or medium, or any form,
format, or forum, whether now-known or hereafter developed, to improve, develop,
or market the Services, or for any other reasonable business purpose. We may
sublicense these rights through multiple tiers of sublicenses. Any provision of
Submissions is voluntary and at your sole discretion. No compensation will be
paid with respect to your provision of Submissions or Our use thereof. We are
under no obligation to post or use any Submissions you provide and We may remove
any Submission at any time in Our sole discretion. By providing Us any
Submissions, you represent and warrant that you own (or otherwise control) and
have all of the rights or consents to your Submission that are necessary for you
to provide it, including intellectual property or other proprietary rights. You
agree that: (a) all content of your Submissions must be accurate; (b) you will
not provide a Submission that is known by you to be false, inaccurate or
misleading, or may be reasonably considered to be defamatory, libelous, hateful,
offensive, obscene, unlawfully threatening or unlawfully harassing to anyone, or
otherwise illegal; (c) you will not provide a Submission that infringes,
misappropriates, or otherwise violates another party’s intellectual property
rights or other proprietary rights, including rights of publicity or privacy;
(d) you will not provide a Submission that violates any applicable law, statute,
ordinance or regulation; (e) you will not provide a Submission for which you
were compensated or granted any consideration by any third party; (f) you will
not provide any Submission that includes information that references other
websites, addresses, email addresses, contact information, phone numbers, or
other personally identifiable information for anyone; and (g) you will not
provide a Submission that contains any malware or potentially damaging computer
programs or files.
You are solely responsible for your Submissions and acknowledge that, once
published, We cannot always remove them. Your Submissions are not confidential
and shall not be deemed your confidential information, and We do not have any
obligation to keep any such material confidential. By providing any Submission,
you acknowledge and agree that We will be free to use any details, ideas,
concepts, know-how, or techniques contained in such information for any purpose
whatsoever including, but not limited to, developing, manufacturing, and
marketing products or services incorporating such information, without
restriction. You agree to waive (or agree not to enforce) any and all rights
that may now or in future exist (including moral and equivalent rights) in any
Submissions.
3.6 Beta Features. We may also, in Our sole discretion, make available new
and/or updated beta features in the Services for your use. Your use of any beta
features is voluntary and at your discretion. Use of certain beta features may
subject you to payment of applicable fees. Any beta features are provided on an
“as-is” basis, without any warranty, and you acknowledge and agree that your use
of beta features is at your own personal risk. Certain beta features may be
subject to additional terms or an agreement. You understand that beta features
may be made available with mechanisms that may permit or enable you to provide
or communicate Submissions relating to the beta features and related Services to
Us. If you choose to provide Submissions relating to any beta features or
related Services, We are entitled to use any such Submissions in accordance with
the terms of Section 3.4 above.
3.7 Updates. We may, from time to time, develop and provide updates for the
Services and Software, which may include upgrades, bug fixes, patches, error
corrections, and/or new features, functionality, tools, or content
(collectively, “Updates”). Updates may also modify or delete certain features,
functionality, tools, or content in their entirety. If you do not download and
install the most recent Updates, portions of the Services or Software may not
operate properly. You understand and agree We reserve the right to make changes
to Our Services or Software and have no obligation to provide any Updates or to
continue to provide or enable any particular features, functionality, tools, or
content. All Updates will be deemed part of the Services and be subject to all
terms and conditions of these Terms.
For the mobile app, depending on your mobile device settings, when your mobile
device is connected to the internet either: (a) the Updates will automatically
download and install; or (b) you may receive notice of or be prompted to
download and install available Updates. We suggest that you promptly download
and install all Updates.
3.8 Monitoring of Customer Service Sessions. We and Our partners may monitor and
record customer service sessions, including telephone calls and online sessions
for purposes of improving customer service, internal training, and internal
market research. You hereby grant Us permission to (a) monitor and record any
customer service sessions involving you; (b) use or disclose any information as
necessary or appropriate to satisfy any law, regulation, or other governmental
requests; (c) respond to claims asserted against Us or our affiliates; (d)
enforce and to ensure (including any investigations needed) a user’s compliance
with these Terms; (e) conduct risk assessments and prevent, detect and
investigate incidents of fraud, security and technical issues; (f) protect Our
and our affiliates’ rights or property, or safety of the Services and its other
users or members of the public; and (g) provide the Services to you or other
users and/or to improve or enhance the types of Services We may provide in the
future.
3.9 Privacy. We respect your privacy and have taken specific steps to protect
it. Your submission of personal information is governed by Our privacy policy,
located at https://www.hotspotshield.com/privacy-policy/
[https://www.hotspotshield.com/privacy-policy/], which is hereby incorporated
into these Terms by reference (“Privacy Policy”). By accessing and using Our
website(s) or Products, you acknowledge that you have reviewed and understand
Our Privacy Policy and consent to the practices described therein.
3.10 Availability of Services; Force Majeure. Due to the nature of the Services,
actual coverage, speeds, server locations, and quality of Services may vary. We
aim to improve and provide Services at all times, but operation of the Services
are dependent on the internet and third-party internet connections, equipment or
infrastructure, as well as third party service providers. From to time to time,
Services may be not available without a prior notice or Our liability, including
when (a) We test, update, expand, add, or remove Our Services, features,
functionalities, including those required to reflect changes in relevant laws
and regulatory requirements (b) We experience temporary interruptions due to
technical difficulties, maintenance or human errors; or (b) Force Majeure Event
(as defined below) cause interruption to the Services.
Neither party will be responsible or have any liability for any delay or failure
to perform, or inadequacy in performance, to the extent caused by unforeseen
circumstances or causes beyond a party’s reasonable control (“Force Majeure
Event”), which may include natural disaster (such as earthquake, fire, flood,
severe weather, or pandemic), sanctions, embargoes, strikes, labor disturbances,
civil unrest or riots, unavailability or delay of suppliers or licensors, riots,
acts of terrorism or criminal activity, war, failure or interruption of the
internet or related infrastructure, power failures, acts or orders of civil and
government authorities, or any other act of God; provided that each party will
use reasonable efforts to limit the resulting delay or failure in its
performance and the foregoing shall not alleviate any applicable payment
obligations.
3.11 Third-Party Offerings. We may offer, make available, or provide you access
to certain third-party content, information, or materials (“Third-Party
Content”) and/or products, services, offerings, platforms or websites provided
by third parties (“Third-Party Services”), including, but not limited to,
through websites that hyperlink to Our website(s), or to which We hyperlink or
otherwise make accessible through Our Services (collectively “Third-Party
Offerings”). Third-Party Offerings are not provided by Us, and We do not
control, or bear any responsibility for Third-Party Offerings, including such
third party’s provision of their products, services, content, or offerings, or
such third party’s use of any information you may provide them in your access or
use of Third-Party Offerings. You understand and agree that your access and use
of Third-Party Offerings may be subject to additional terms and conditions that
apply between you and the provider of the applicable Third-Party Offering(s),
and these Terms will not apply to your use of Third-Party Offerings or your
interactions with their providers. How third parties handle and use your
information or data collected, processed or used in connection with its
Third-Party Offerings is governed by the offering provider’s security, privacy,
and other policies, if any, and not Our terms or policies. If you choose to
access or use any Third-Party Offerings, including, without limitation, through
third-party payment vendors while using the Services, you acknowledge and agree
that your data or personal information may be available to the provider(s) of
such Third-Party Offering(s). You acknowledge and agree that (a) We are not
responsible or liable for (i) the availability, reliability, or functionality of
these Third-Party Offerings, including whether any information provided
therefrom is complete, accurate, or up-to-date, or (ii) the terms, policies, or
practices of such Third-Party Offerings’ providers; and (b) We shall, under no
circumstances, be held responsible or liable, directly or indirectly, for any
loss or damage caused or alleged to have been caused to a user in connection
with the use of or reliance on any Third-Party Offering.Links to any Third-Party
Offering, and the availability, display, or use of any Third-Party Content in
the Services, do not imply that We endorse any such Third-Party Offerings, or
any affiliation between Us and its provider(s).
3.12 Prohibited Conduct. BY USING THE SERVICES, YOU AGREE NOT TO:
* Send or transmit unsolicited advertisements or content (i.e., “spam") over
the Services;
* Send, post, or transmit over the Services any content (a) that is illegal,
hateful, threatening, insulting, deceptive, fraudulent, damaging, libelous,
or defamatory, (b) that infringes Our or ant third parties’ intellectual
property or other proprietary rights, (c) that invades privacy rights, laws,
or regulations, or (d) that incites violence or any unlawful behavior;
* Upload, download, post, reproduce, capture, store, retransmit, or distribute
any content protected by copyright or any other proprietary right without
first having obtained permission from the owner / licensor of the proprietary
content;
* Use the Services for any illegal purpose, or in violation of any local,
state, national, or international law;
* Engage in any conduct that restricts or inhibits any other subscriber from
using or enjoying the Services;
* Attempt to access, probe, or connect to computing devices without proper
authorization (i.e., any form of “hacking”);
* Attempt to compile, utilize, or distribute a list of IP addresses operated by
Us in conjunction with the Services;
* Use the Services for any commercial use, it being understood that the
Services are for personal, non-commercial use only;
* Use the Services if you are not Eligible;
* Intentionally interfere with or damage the operation of the Services, by any
means, including uploading or otherwise disseminating viruses, adware,
spyware, worms, or other malware or malicious code;
* Reverse engineer, decompile, disassemble or otherwise attempt to discover the
source code of the Services or any part thereof; or
* Remove, circumvent, disable, damage, or otherwise interfere or deny service
in any way or form with security-related features of the Services, features
that prevent or restrict use or copying of the Software, or features that
enforce limitations on the use of the Services.
3.13 Additional Applicable Terms.
3.13.1 General. Certain areas, features, or functionality of the Services may be
subject to different or additional terms, rules, guidelines, or policies
(“Additional Rules”) or Service Specific Terms, and not every Subscription will
include the same features (for example, Subscriptions purchased via an
authorized third-party or a reseller may not include all of the same features as
a Subscription purchased through Us directly). Not all features may be available
on all devices. Depending upon the Services you subscribe or register to use,
you may be subject to Additional Rules. Features may be added, changed or
removed during a Subscription Term, which may also affect the applicable terms
and conditions of use. We, or an applicable third-party provider, may provide
such Additional Rules to you via postings, pop-up notices, links, or other means
at the time that you access or use the relevant offering, area, feature or
functionality subject to such terms. From time to time, such Additional Rules
may conflict with these Terms. In the event of such a conflict, the Additional
Rules will control with respect to the scope of which they apply. Any reference
to the “Terms” in this Agreement includes the Additional Rules.
3.13.2 App Store Terms.
1. If the Software or any Service is provided to you through Apple Inc. (Apple
Inc. together with all of its affiliates, “Apple”) App Store, the following
terms and conditions apply to you and your use, in addition to all the other
terms set forth in these Terms:
(i) Apple is not responsible for the Services and has no obligation to
furnish any maintenance or support services for the Software or the
Services.(ii) In the event of any failure of the Software to conform to any
applicable warranty, you may notify Apple, and Apple will refund the
purchase price for the Software (if any) to the Customer (you). Except for
the foregoing, to the maximum extent permitted by applicable law, Apple will
have no other warranty obligation whatsoever for the Software, and any other
claims, losses, liabilities, damages, costs, or expenses attributable to any
failure to conform to any warranty will be governed by its applicable
customer agreement.(iii) Any claim in connection with the Software related
to product liability, a failure to conform to applicable legal or regulatory
requirements, or claims under consumer protection or similar legislation is
governed by this Agreement, and Apple is not responsible for such claim.(iv)
Any third-party claim that the Software or your possession and use of the
Software infringe that third-party’s Intellectual Property Rights will be
governed by this Agreement, and Apple will not be responsible for the
investigation, defense, settlement, and discharge of such intellectual
property infringement claim.(v) Apple shall be a third-party beneficiary of
this Agreement and upon your acceptance of this Agreement, Apple will have
the right (and will be deemed to have accepted the right) to enforce this
Agreement against you.
2. If the Software or Service is provided to you through the Google Play Store
(“Google-Sourced Software”), then the following terms and conditions apply
to you and your use, in addition to all the other terms set forth in the
Terms:
(i) you acknowledge that these Terms, including the Google-Sourced Software
are between you and Us only, and not with Google, Inc. (“Google”);(ii) your
use of Google-Sourced Software must comply with Google’s then-current Google
Play Store Terms of Service;(iii) Google is only a provider of the Google
Play Store where you obtained the Google-Sourced Software;(iv) We, and not
Google, are solely responsible for Our Google-Sourced Software;(v) Google
has no obligation or liability to you with respect to Google-Sourced
Software or these Terms; and(vi) you acknowledge and agree that Google is a
third-party beneficiary to these Terms as it relates to Our Google-Sourced
Software or Services and Software We make available as Google-Sourced
Software.
3. If you access or use Our Software or Service downloaded from any other
online app store, platform, or marketplace (e.g., Google Play, Amazon
Appstore, Microsoft Store, HUAWEI AppGallery, or similar) (“Other Stores”),
you acknowledge and agree that you (i) your access is subject to such Other
Stores’ then-applicable terms of service and (ii) have or will have read and
agrees to the terms of service and privacy policies that apply to such Other
Stores. We are the licensor of Our Software and the provider of Our
Services. These Other Stores are not party to these Terms and have no
obligation to provide maintenance and/or support of Our Software or
Services.
3.13.3 VPN Service Specific Terms. Our VPN Services, which enhances internet
security and privacy, are licensed and provided on a subscription basis. Users
will have to elect to use, and pay for, a valid Subscription to access the VPN
Services, except in the case of free Products we may make available or certain
limited free trial or limited time promotional offers.Subject to your compliance
with the Terms, you may install and use the Software, in object code format, to
access the applicable VPN Product you have licensed for internal and personal
purposes only.
Our VPN Services generally provide sufficient capacity to accommodate average
non-commercial use. Given the nature of the Services and various dependencies
required for its operation (e.g. the internet), it is possible that you may
temporarily experience slower service or service unavailability from time to
time. The accuracy and timeliness of data received is not guaranteed; delays,
errors, or omissions may occur. We are not responsible for any data, messages,
or pages lost, not delivered, delayed, or misdirected because of interruptions
or performance issues with the VPN Services, communications services, or
networks (including the internet generally). Any such delays, slowdown,
unavailability, errors, or loss of data will not constitute a breach or default
by Us of Our obligations. In addition, We may impose usage or service limits,
suspend services, or block certain kinds of usage at Our sole discretion to
protect Us, Our customers, or Our Services. We will not be liable to you or owe
you any refund or other compensation in connection with any such actions.
We do not condone or endorse any unlawful, illicit, criminal or fraudulent
activities perpetrated by you while using the VPN Services. We will not be
liable in any way for any actions or omissions of the users of the VPN Services.
We reserve the right to prevent your access to the Services or continued use
thereof if you violate the Terms, or if you engage in fraud, copyright
infringement, or any other illegal or criminal activity.
If You choose to access and use third-party websites, services or content, or
purchase products from third parties, including without limitation through
third-party payment vendors, your personal information may be available to a
third-party content provider. If you choose to visit or use any third-party
products or services, Our policies and this Agreement will not apply to your
activities or any information you disclose while using third-party products or
services or otherwise interacting with third parties. How third parties handle
and use your personal information related to their sites and services is
governed by their security, privacy and other policies, if any, and not Our
policies. You understand and agree we have no responsibility for any third
party’s policies, or any third party’s compliance with them.
13.14 Export.
The Services, or certain portions thereof, may be subject to United States
export controls. We reserve the right to limit, in our sole discretion, the
availability of our Services, or any portion thereof, to any person, entity,
geographic area, or jurisdiction at any time. By downloading and using our
Service, you certify that you are not a target of any sanctions regime, and you
do not reside in, nor will you access our Service or Software from, a country
from where such access is prohibited under any applicable sanctions regime.
You may not export or re-export any aspect of the Services without (a) Our prior
written consent, (b) complying with any applicable export control laws or
regulations, and (c) obtaining all appropriate permits and licenses. In any
event, you may not remove or export from the United States or allow the export
or re-export of any part of the Services in violation of any restrictions, laws,
or regulations of the United States Department of Commerce, the United States
Department of Treasury Office of Foreign Assets Control, or any other United
States or foreign agency or authority. The Services may contain information that
is controlled and restricted from export by the United States export controls
restrictions, regulations, and laws described above (the “Controlled
Information”).
If We, at our sole discretion, reasonably determine that We cannot implement or
provide the Services in a manner to exclude access to Controlled Information
where required, then you acknowledge and agree that you will not be provided
access to the Services if you are in a country or territory that is subject to
such regulation.
13.15 Intellectual Property Rights.
All aspects of the Services and their content, features, and functionality are
owned by Us, our affiliates, our licensors, or other content or Third-Party
Offering suppliers, and are protected by copyright and other intellectual
property laws. As between Us and you, We owns and retains all right, title and
interest in and to the Services, (including, for clarity, the Software, and any
related offering materials or documentation), including all ownership and
Intellectual Property Rights therein. For purposes of these Terms, “Intellectual
Property Rights” means all rights in and to: copyrights, patents, trade secrets,
trademarks, service marks, trade dress, domain names, databases and other
compilations and collections of data or information, any moral rights or rights
to publicity and privacy, and other intellectual property anywhere in the world,
whether statutory, common law, or otherwise, now known or later created. The
details of the limited license under which you are permitted to use the Services
or Our offerings are described in these Terms. “Hotspot Shield” and its logos
are federally registered trademarks of Anchorfree, LLC, all rights reserved. All
aspects of Our Products and its content, features, and functionality are owned
by Us, our licensors, or other service providers or content suppliers, and are
protected by copyright and other intellectual property laws. Any rights not
expressly granted in these Terms are reserved by Us (or our licensors and
suppliers, as applicable).
13.16 Termination.
1. Termination by Us. We may terminate your use of the Services or discontinue
providing access to the Services at any time and for any reason, including,
but not limited to any actual or suspected breach by you of these Terms, or
any other unacceptable or objectionable use of the Services, as determined
by Us in Our sole discretion. You agree that any termination of your access
to the Services may be effected without prior notice and you agree that We
will not be liable to you or any third-party for any such termination.
If We terminate your access for reasons other than your breach of these
Terms during Subscription Term where you are a paid subscriber, you may be
entitled to a pro-rated refund of your prepaid Subscription Fees based
amount paid in connection with your use of the Services. If your account is
terminated due to your breach of these Terms, you will not be eligible for a
refund. All refunds are issued at Our sole discretion and any refund request
may be denied for any or no reason. If you have been terminated from the
Services and wish to request a refund, please contact Us via the Support
Email or email address in your account dashboard and describe the
circumstances relating to the termination or suspension of your access to
the Services. Any suspected fraudulent, abusive, or illegal activity may be
referred to appropriate law enforcement authorities. These remedies are in
addition to any other remedies We may have at law or in equity.
2. Termination by You. You may terminate this Agreement, at any time, by
discontinuing use of the Services, deleting your account with the Services,
and uninstalling any Software downloaded in connection with your use of the
Services. However, your responsibility for anyone who obtains, accesses, or
uses the Services through you or your account (including the responsibility
described in Section 3.2 (User Accounts, Data, and Passwords)) and your
obligations under the sections that will survive termination of the
Agreement specified in Section 3.22 (Survival) will survive termination for
any reason.
13.17 Indemnification. To the fullest extent permitted by law, you agree to
indemnify and hold Us (including our affiliates) and Our respective officers,
directors, shareholders employees, agents, suppliers, vendors, contractors or
subcontractors, resellers, third-party partners, and licensors (collectively,
the “Indemnified Parties”) harmless from and against all claims, actions, and
proceedings, and any associated losses, damages, liabilities, including legal
fees and expenses, arising from or related your use or misuse of the Services,
or your breach of these Terms (including of any representations, warranties, and
covenants you made herein). We reserve the right, at your expense, to assume the
exclusive defense and control of any matter for which you are required to
indemnify the Indemnified Parties, and you agree to cooperate with Our defense
of these claims. We will use reasonable efforts to notify you of any such claim,
action, or proceeding subject to indemnification upon becoming aware of it.
13.18 Disclaimers; No Warranties. THE SERVICES AND WEBSITES ARE PROVIDED ON AN
“AS-IS” AND “AS-AVAILABLE” BASIS, WITH ALL FAULTS. TO THE FULLEST EXTENT ALLOWED
BY APPLICABLE LAWS: WE DISCLAIM ALL REPRESENTATIONS AND WARRANTIES OF ANY KIND,
EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING, BUT NOT LIMITED TO, ANY
IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND
NON-INFRINGEMENT, AND ANY WARRANTIES ARISING THROUGH COURSE OF DEALING, COURSE
OF PERFORMANCE, OR USAGE OF TRADE, OR CONCERNING RESULTS OBTAINED FROM A USER’S
USE OF THE SERVICES. WITHOUT LIMITING THE FOREGOING, WE NEITHER WARRANT NOR
REPRESENT THAT (A) YOUR USE OF THE SERVICES, OR ANY RESULTS OR OUTPUT THEREOF,
WILL NOT INFRINGE THE RIGHTS OF ANY THIRD PARTY, (B) THE SERVICES WILL BE
AVAILABLE FOR YOUR ACCESS OR USE, OR ACHIEVE ANY INTENDED RESULT, (C) THE
SOFTWARE OR SERVICES, OR OUTPUT THEREOF, WILL BE SECURE, ACCURATE, COMPLETE, OR
ERROR FREE, OR (D) THE OPERATION OF THE SERVICES WILL BE ERROR-FREE OR
UNINTERRUPTED. WE MAKE NO ASSURANCES, REPRESENTATION, OR WARRANTY, WHATSOEVER,
REGARDING THE COMPLETENESS, ACCURACY, ADEQUACY, RELIABILITY, SUITABILITY,
FUNCTIONALITY, SECURITY, AVAILABILITY, PERFORMANCE OF THE SERVICES OR OPERATION
THEREOF, INCLUDING ANY CONTENTS, OUTPUTS, OR RESULTS PROVIDED THEREFROM OR
THROUGH YOUR USE OF THE SERVICES. YOU ACKNOWLEDGE THAT WE DO NOT HAVE CONTROL
OVER YOUR USE OF THE SERVICES. YOU UNDERSTAND AND AGREE THAT YOU ASSUME ALL
RISKS AND RESPONSIBILITY FOR YOUR USE OF THE SERVICES AND ANY LOSS OF OR ERRORS
IN ANY DATA OR INFORMATION THEREFROM. WE MAKE NO REPRESENTATION OR WARRANTY
ABOUT ANY THIRD-PARTY OFFERING, WHICH ARE PROVIDED AS-IS. ANY REPRESENTATION OR
WARRANTY OF OR CONCERNING ANY THIRD-PARTY OFFERING IS STRICTLY BETWEEN YOU AND
THE APPLICABLE THIRD-PARTY OFFERING PROVIDER. NO INFORMATION, WHETHER ORAL OR
WRITTEN, OBTAINED BY YOU FROM US OR THROUGH THE SERVICES WILL CREATE ANY
WARRANTY NOT EXPRESSLY STATED HEREIN.
SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES OR CERTAIN
DISCLAIMERS, SO SOME OF THE ABOVE EXCLUSIONS AND TERMS MAY NOT APPLY TO YOU.
CONSUMER RIGHTS MAY VARY FROM ONE JURISDICTION TO ANOTHER JURISDICTION. TO THE
EXTENT YOU MAY HAVE CERTAIN RIGHTS UNDER APPLICABLE LAWS IN YOUR JURISDICTION,
NOTHING IN THESE TERMS IS INTENDED TO AFFECT THOSE RIGHTS, IF THEY APPLY.Also,
when using the Services, you understand that information will be transmitted
over a medium that is beyond Our control and jurisdiction, or that of Our
partners, advertisers, sponsors, or service providers. Accordingly, We assume no
liability for or relating to the delay, failure, interruption, or corruption of
any data or other information transmitted in connection with the use of the
Services.
13.19 Limitation of Liability; Damages. TO THE FULLEST EXTENT PERMITTED UNDER
APPLICABLE LAW, IN NO EVENT WILL: (A) WE (OR OUR INDEMNIFIED PARTIES) BE
RESPONSIBLE FOR OR LIABLE TO YOU FOR ANY DIRECT, INCIDENTAL, INDIRECT, SPECIAL,
OR CONSEQUENTIAL DAMAGES (INCLUDING THOSE ARISING FROM OR RELATED TO ANY LOSS OF
DATA, LOSS OF PROFIT, SERVICE INTERRUPTION, COMPUTER DAMAGE OR SYSTEM FAILURE,
OR PERSONAL INJURY OR WRONGFUL DEATH), WHETHER ARISING IN CONTRACT, TORT,
WARRANTY, OR ANY OTHER LEGAL THEORY OF LIABILITY (INCLUDING NEGLIGENCE, PRODUCT
LIABILITY, STRICT LIABILITY, OR OTHERWISE), HOWEVER ASSERTED, INCLUDING EVEN IF
WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES; AND (B) OUR (OR OUR
INDEMNIFIED PARTIES’) TOTAL LIABILITY IN ANY WAY ARISING FROM OR RELATED TO
THESE TERMS OR YOU USE OR INABILITY TO USE THE SERVICES EXCEED THE LESSER OF (I)
SUBSCRIPTION FEES THAT YOU PAID OR ARE PAYABLE BY YOU TO US FOR THE APPLICABLE
SERVICES DURING YOUR LAST SUBSCRIPTION TERM, OR (II) ONE HUNDRED DOLLARS (U.S.
$100). FOR CLARITY, THIS LIMITATION APPLIES TO DAMAGES ARISING FROM (i) USE OF
OR INABILITY TO USE THE SERVICES, (ii) COST OF PROCUREMENT OF SUBSTITUTE GOODS
AND SERVICES, (iii) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS
BY THIRD PARTIES, (iv) THIRD-PARTY OFFERINGS MADE AVAILABLE TO YOU THROUGH THE
SERVICES, OR (v) ANY OTHER MATTER RELATING TO THE SERVICES OR THESE TERMS.
YOU ACKNOWLEDGE AND AGREE THAT THE DISCLAIMERS AND LIMITATIONS OF LIABILITY IN
THESE TERMS CONSTITUTE AN ESSENTIAL ELEMENT OF THE BARGAIN BETWEEN US AND YOU,
REFLECTING A FAIR AND REASONABLE ALLOCATION OF RISK BETWEEN US AND YOU, AND THAT
WE HAVE OFFERED THE SERVICES AT THE APPLICABLE PRICES IN RELIANCE ON YOUR
AGREEMENT TO EACH OF THESE TERMS. WE WOULD NOT, AND WOULD NOT BE ABLE TO,
PROVIDE THE SERVICES TO YOU ON AN ECONOMICALLY REASONABLE BASIS WITHOUT THESE
LIMITATIONS AND YOUR AGREEMENT TO THE TERMS.
We acknowledge certain jurisdictions do not allow limitation or exclusion of
liability for incidental or consequential damages, and agree that, to the extent
you have additional rights under applicable laws of your jurisdiction, certain
of these terms may not apply to you and these terms are not intended to affect
your applicable rights.
13.20 Dispute Resolution; Individual Arbitration.
Please read these terms carefully. It affects your legal rights.
1. Most customer concerns can be resolved quickly and to the customer's
satisfaction by contacting Us via the Support Email or customer service
email address appearing in your account dashboard. If customer service is
not able to resolve your concern or complaint to your satisfaction, you
agree to give Us a fair opportunity to resolve any complaint, claim or
dispute you may have informally and shall provide Us with a written notice
of your claim in the manner described in the Notices; Contact Us section, so
that We can cooperate with each other to try to address the matter amicably
prior to engaging in any formal dispute resolution proceedings.
2. In the unlikely event that customer service is unable to resolve a complaint
you may have regarding the Services or Us, or We have not been able to
resolve a dispute with you after attempting to do so informally, then either
party may proceed with formal dispute resolution. If you are a United States
based customer or a customer in a jurisdiction where binding arbitration is
permitted under applicable law, then you agree any complaint or dispute not
informally resolved with Us (including Our service providers, affiliated
entities, or Indemnified Parties) shall be resolved through binding
arbitration as described in this subsection (B) and the Arbitration
Agreement set forth in the following subsection (C). The Arbitration
Agreement requires you to resolve all disputes, claims, or controversies
(other than those expressly exempted in this Section 3.19) through binding
arbitration on an individual basis, instead of in courts of general
jurisdiction to the fullest extent permitted by law. Arbitration is more
informal than a lawsuit in court. Arbitration uses a neutral arbitrator
instead of a judge or jury, allows for more limited discovery than in court,
and is subject to very limited review by courts. Arbitrators can award the
same damages and relief that a court can award. Any arbitration under these
Terms will take place on an individual basis; class arbitrations and class
actions are not permitted.
3. Arbitration Agreement.
1. Mandatory Arbitration of Disputes. You, on the one hand, and Us
(including any of Our service providers, affiliated entities, or
Indemnified Parties subject to a claim or dispute), on the other, hereby
each expressly agree that any dispute, claim or controversy arising out
of or relating to these Terms (including the breach, termination,
enforcement, interpretation, applicability, or validity thereof or
portions thereof, such as this Arbitration Agreement or any policies
incorporated into the Terms by reference) or the Services or use thereof
(collectively, “Disputes”) will be resolved solely by binding,
individual arbitration and not in a class, representative or
consolidated action or proceeding. You and Us agree that the U.S.
Federal Arbitration Act governs the interpretation and enforcement of
these Terms, and that you and Us are each waiving the right to a trial
by jury and the right to participate in a class action. This arbitration
provision shall survive termination of these Terms.
2. Conducting Arbitration and Arbitration Rules. The arbitration will be
conducted by the American Arbitration Association (“AAA”) under its
Consumer Arbitration Rules (the “AAA Rules”) then in effect, except as
modified by these Terms. The AAA Rules are available at www.adr.org
[https://www.adr.org/] or by calling 1-800-778-7879. Either party may
initiate arbitration proceedings. A party who wishes to start
arbitration must submit a written Demand for Arbitration to AAA and give
notice to the other party as specified in the AAA Rules. The AAA
provides a form Demand for Arbitration at www.adr.org
[https://www.adr.org/].Any arbitration hearings will take place in the
county (or parish) where you live, unless we both agree to a different
location. The parties agree that the arbitrator shall have exclusive
authority to decide all issues relating to the interpretation,
applicability, enforceability and scope of this arbitration agreement.
3. Exceptions. As limited exceptions to Section 3.19.C.i. above: (a) each
party may seek to resolve a Dispute in small claims court if it
qualifies; (b) each party shall retain the right to seek injunctive or
other equitable relief from a court to prevent (or enjoin) the
infringement or misappropriation of Our intellectual property rights;
and (c) if you are a customer who resides in a jurisdiction where you
have a legal right to opt out of arbitration in accordance with laws
applicable to you – you may exercise your legal right to opt out.If you
qualify for the exception stated in subsection (c) herein, you must
notify Us of your election to opt out of this Arbitration Agreement in
writing in accordance with the requirements set forth in the Notices
section within thirty (30) calendar days of becoming subject to the
Terms (I.e. within thirty (30) days of first access or using the
Services). If you do not opt out of the Arbitration Agreement within
such period, you shall be bound by the terms of the Arbitration
Agreement and have agreed to arbitrate any Claims you may have, on a
non-class, individual basis, in accordance with the terms herein. If you
opt out of only the arbitration provisions, and not also the class
action waiver set herein, then the class action waiver shall still apply
to you. Your opt-out notice must include your legal name and address,
the email address you used to set up your account for the Services (if
you have one), and an unequivocal statement that you want to opt out of
this Arbitration Agreement (and, if applicable and you so wish, that you
want to opt out of the class action waiver). Opt-out notices submitted
via email will not be effective.
4. Arbitration Costs. Payment of all filing, administration and arbitrator
fees will be governed by the AAA Rules. We agree to pay for the
applicable fees We are responsible for and will not seek to recover the
administration and arbitrator fees we are responsible for paying, unless
the arbitrator finds your Dispute frivolous. If we prevail in
arbitration, we will be responsible for all of Our attorneys’ fees and
costs and will not seek to recover them from you. If you prevail in
arbitration you will be entitled to an award of attorneys’ fees and
expenses to the extent provided under applicable law.
5. Injunctive and Declaratory Relief. Except as provided in Section
3.19.C.iii. above, the arbitrator shall determine all issues of
liability on the merits of any claim asserted by either party and may
award declaratory or injunctive relief only in favor of the individual
party seeking relief and only to the extent necessary to provide relief
warranted by that party’s individual claim. To the extent that you or we
prevail on a claim and seek public injunctive relief (that is,
injunctive relief that has the primary purpose and effect of prohibiting
unlawful acts that threaten future injury to the public), the
entitlement to and extent of such relief must be litigated in a civil
court of competent jurisdiction and not in arbitration. The parties
agree that litigation of any issues of public injunctive relief shall be
stayed pending the outcome of the merits of any individual claims in
arbitration.
6. Class Action Waiver. YOU AND US AGREE THAT EACH MAY BRING CLAIMS AGAINST
THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY, AND NOT AS A
PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE
PROCEEDING. Further, if the parties’ Dispute is resolved through
arbitration, the arbitrator may not consolidate another person’s claims
with your claims, and may not otherwise preside over any form of a
representative or class proceeding. If this specific provision is found
to be unenforceable, then the entirety of this Dispute Resolution
section shall be null and void.
7. Severability. With the exception of any of the provisions in Section
3.19.C.vi. of these Terms (“Class Action Waiver”), if an arbitrator or
court of competent jurisdiction decides that any part of these Terms is
invalid or unenforceable, the other parts of these Terms will still
apply.
4. In the event of a dispute that is not subject to the Arbitration Agreement
in these Terms, or if the Arbitration Agreement is found to be
unenforceable, and except any claim properly lodged in a Small Claims Court
of the United States (which may be within the county where you reside or in
New York, New York), you agree that any action at law or in equity arising
out of or relating in any way to these Terms or your use of the Services
will be brought in the courts of New York, New York, and you hereby
expressly consent and submit to the personal and exclusive jurisdiction of
such courts to litigate any such action. You further agree that any such
claims will be brought solely on an individual basis and not as part of any
class, consolidated, or representative capacity. If you reside in a country
(including countries of the European Union) where laws provide consumers the
right to bring disputes in their local courts, then, in such cases,
mandatory provisions of the local laws of your country of residence shall
apply.
The terms of this Section 3.19 shall survive any termination, cancellation, or
expiration of this Agreement.
3.21 Notices; Contact Us
1. Notices.
All notices must be provided in writing and will be deemed given when: (a)
personally delivered to recipient, (b) verified by a written receipt, if
sent by postal mail with verification of receipt service or courier, (c)
received, if sent by postal mail without verification of receipt, or (d)
verified by automated receipt or electronic logs if sent by email, provided
that no bounce or other technical error message was received in response.
Any notices you provide to Us must be sent via postal mail or delivery
service to Anchorfree LLC 250 Northern Ave, 3rd Floor, Boston, MA 02210,
marked to the attention of the Legal Department, and via email to
[email protected].
Email alone is insufficient for providing non-routine legal notices, such as
notices related to disputes or arbitration, indemnification claims, breach
notices, and termination notices (“Non-Routine Notices”) to Us.
You may grant approvals, permission, extensions, and consents by email.
Notices to you may be sent to the email address associated with your account
for the Services. You consent to receive certain electronic communications
from Us in connection with your use of the Services. You agree that any
notices or other communications sent to you electronically will satisfy any
legal notice requirements. You must keep contact details associated with
your account and accurate, and you will notify Us in writing of any changes
to such details.
2. Contact Us.
If you have any questions about these Terms or Our Products, you may contact
us through our Support Center
[https://support.hotspotshield.com/hc/en-us/requests/new], Support Email, or
using the following details:
Anchorfree, LLC
250 Northern Ave.,
3rd Floor, Boston, MA 02210
United States
3.22 Governing Law. These Terms will be governed by and construed in accordance
with the laws of the State of New York, without giving effect to any provisions
that would require the laws of another jurisdiction to apply. UCITA, the UCC,
and the UN Convention on Contracts for the International Sale of Goods will not
apply. However, some countries (including countries of the European Union) have
laws that require contracts to be governed by the mandatory provisions of the
local laws of the consumer's country. In such cases, mandatory provisions of the
local laws of your country of residence apply.
3.23 Survival. Upon termination or expiration of these Terms for any reason,
provisions which by their nature should survive termination of these Terms shall
survive. For clarity, such shall include: Section 3.4 (User Feedback or
Submissions); Section 3.14 (Intellectual Property Rights), Section 3.16
(Indemnification), Section 3.17 (Disclaimers; No Warranties); 3.18 Limitation of
Liability; Damages); Section 3.19 (Dispute Resolution; Individual Arbitration),
Section 3.21 (Governing Law), Section 3.22 (Survival), Sections 3.21.I – L
(Severability, No Waiver, Interpretation of the Terms, and Entire Agreement),
and Section 4.2 (Ownership).
3.24 Miscellaneous.
1. Digital Millennium Copyright Act. The Digital Millennium Copyright Act of
1998 (the “DMCA”) provides recourse for copyright owners who believe that
material appearing on the internet infringes their rights under U.S.
copyright law. It is Our policy to comply with the DMCA and respond to
notices of alleged copyright infringement. For more information, please go
to our DMCA Notification page [https://www.hotspotshield.com/legal/dmca].
2. Notice to California Residents. You may reach Us at the contact information
provided in the "NOTICES; CONTACT US" section. California residents may
also reach the Complaint Assistance Unit of the Division of Consumer
Services of the California Department of Consumer Affairs by mail at 1625
North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254
or (800) 952-5210.
3. Electronic Notice. You consent to receive notices, including agreements,
disclosures, and other communications, electronically from Us at the email
address you have provided. You agree that these electronic notices satisfy
any legal requirements that such communications be in writing.
4. Law Enforcement and Public Interest. Nothing contained in these Terms
prevent Us from disclosing your information to third parties if We
determine that such disclosure is reasonably necessary to: (i) comply with
any applicable law, regulation, legal process, or appropriate government
request; (ii) protect any person from death or serious bodily injury; (iii)
prevent fraud or abuse of the Services or Our users; (iv) protect Our
rights, property, safety, or interest; or (v) perform a task carried out in
the public interest
5. No Relationship. These Terms do not, and shall not be construed to, create
any partnership, joint venture, employer-employee, agency, or
franchisor-franchisee relationship between you and Us.
6. Third-Party Beneficiaries. Except as expressly provided herein, there will
be no third-party beneficiaries to these Terms.
7. Assignment. These Terms, and any of your rights, licenses, or obligations
hereunder, may not be transferred or assigned by you, by operation of law
or otherwise, without Our express written consent. We may assign, transfer,
or sublicense any or all of Our rights under these Terms without
restriction and without notice to you. Any assignment attempted to be made
in violation of these Terms shall be void. These Terms shall be binding
upon, and inure to the benefit of, the parties’ permitted successors and
assigns.
8. Modification. We may update or make changes to these Terms at any time for
a variety of reasons, such as to reflect changes in applicable law or to
account for additional features or functionality in the Services. We may
notify you of such changes by any reasonable means, including by posting a
revised version of these Terms on Our Website or through the Services. You
agree that it is your responsibility to regularly check the Services for
any updated Terms. It is important that you review these Terms whenever We
modify it because your continued use or access of any of the Services after
We post any changes, indicates your agreement to the modifications and
updated Terms. The “Last Updated” legend above indicates when these Terms
were last changed. If a revision materially alters your rights, as
determined by Us in its sole discretion, We will use reasonable efforts to
notify you in advance of the change becoming effective, which may include
sending a notification to the email address(es) associated with your
account or displaying a pop-up or banner within the Services. In any case,
the most current version of these Terms will be posted on the Services and
on Our website(s). Changes will be effective no sooner than the last
updated date. By continuing to use the Services after the date the changes
become effective, you indicate your agreement to be bound by the updated
Terms. If you do not agree to any changes made to these Terms, you must
immediately stop using the Services.
9. Severability. If any provision of these Terms is held to be unlawful, void,
or unenforceable for any reason, then that provision will be limited or
eliminated from these Terms to the minimum extent necessary. Unless
otherwise expressly provided herein, the invalidity or unenforceability of
any eliminated terms will not affect the validity or enforceability of any
other remaining provision, all of which will remain in full force and
effect.
10. No Waiver. Any failure to exercise or enforce any right or provision of
these Terms will not constitute or operate as Our waiver of such right or
provision. Any waiver of any provision of these Terms will be effective
only if in writing and signed by Us. Any cause of action arising out of or
related to the Service by you against Us must commence within one (1) year
after the cause of action accrues.
11. Interpretation of the Terms. These Terms were prepared and written in
English. Any non-English translations of these Terms which may be made
available are provided for convenience only and are not valid or legally
binding. The English language version of these Terms will be the version
used when interpreting or construing these Terms, and any notices or other
communications in connection with these Terms will be provided in the
English language. Use of section headings in these Terms is for convenience
only and will not have any impact on the interpretation of the meaning of
any particular provisions. The words “including” and “for example” or
“e.g.,” and words of similar import, are not limiting or exclusive and will
be deemed followed by “without limitation,” whether or not such language is
included. Any rights and remedies provided for in these Terms are
cumulative and are in addition to, and not in lieu of, any other rights and
remedies available under applicable law.
12. Entire Agreement. These Terms (including any documents or hyperlinked terms
incorporated here by reference) constitute the entire agreement between you
and Us concerning its subject matter, and it supersedes any other prior or
contemporaneous agreements or terms, written or oral.
PART 4. LICENSE TERMS
4.1 Additional Definitions. "License Entitlement" means the number and type of
Devices and users that are permitted to download and use the Software and access
the Services, as specified at time of purchase and in your account profile. If
no licensed device count or user count was specified, the License Entitlement is
for a single Device and user.
"Service Entitlement" means the scope and duration of the Services you
purchased, as specified at time of purchase and in your account profile. If no
scope or duration is specified in the documents, the Service Entitlement is for
a single Device and user for one year.
"System Requirements" means the supported Devices and operating systems that the
particular VPN Product or Service you purchased a Subscription to will function
properly with, as listed on Our website(s), Product dashboard or information
pages, or other applicable documentation. It is your responsibility to meet
System Requirements, such as obtaining updates or upgrades to continue using the
Services.
4.2 Ownership. The (a) Services and Software (including any releases, revisions,
updates, enhancements, features, or functionalities thereto, and all content,
text, data, information, visuals, images, compilation, code, or other materials
embodied therein or derived therefrom), as well as (b) any documentation that
accompanies or is made available in connection with Software or Services
(including any subscription or purchase information, product packaging, or other
product material or documentation) ((a) and (b) collectively, “Our Materials”),
are owned by Us or Our licensors or suppliers. As between Us and you, We own and
shall retain any and all rights in and to Our Materials, including all
Intellectual Property Rights therein. Any Software that We provide to you is
licensed, not sold to you. Except as otherwise expressly permitted under these
Terms, you agree not to sell, license, distribute, copy, modify, publicly
perform or display, transmit, publish, edit, adapt, create derivative works
from, or otherwise make unauthorized use of any of Our materials. We retain all
rights to Our Materials not expressly granted in these Terms.
4.3 Personal, Limited License. The Service, including the Software, is licensed,
not sold, to you, and you may only use the Services as set forth in this
Agreement. Subject to these Terms and you obtaining a valid Subscription to Our
Services, We agree to grant you, as an individual consumer, a limited,
revocable, nonexclusive, personal, non-transferable and non-assignable,
term-limited license to install and use the Software and to access the Services,
during your applicable Subscription Term, for personal and noncommercial and
personal use, on the number of Devices (defined below) and for the number of
users specified in your License Entitlement or Service Entitlement, as
applicable, and subject to the System Requirements. The Software is “in use” on
a Device for purposes of this paragraph when it is loaded into the temporary
memory (e.g., RAM) or installed into the permanent memory (e.g., hard disk,
CD-ROM, or another storage device) of the Device.
4.4 License Restrictions. You may not (and may not allow a third party to):
1. reverse engineer, decompile, disassemble or attempt to reconstruct,
identify or discover any source code, underlying ideas, underlying user
interface techniques or algorithms of the Services by any means whatsoever,
except to the extent that such restriction is expressly prohibited by
applicable law;
2. remove or destroy any copyright notices, trademarks, or other proprietary
markings from the Services;
3. attempt to circumvent or bypass any use restrictions applicable to the
Services or any measures We may use to prevent or restrict access to the
Services, or otherwise attempt to gain unauthorized access to the Services
(or the accounts of other users and/or computer systems or networks
connected to the Services);
4. modify or adapt any aspect of the Services, merge any aspect of the
Services into another program, or create derivative works based on the
Services;
5. use, copy, or distribute the Software without Our written authorization;
6. use the Services to provide, alone or in combination with any other
software, product or service, any software/product/service to any person or
entity, whether on a fee basis or otherwise or on websites where you have
agreed "not to use any ad blocking solutions", for instance by agreeing to
the terms of services on the respective websites or to circumvent
technological measures that control access to websites;
7. repackage, modify, adapt, tamper with, alter, translate, or create
derivative works of the Services or any aspect thereof;
8. combine or merge any part of the Services with or into any other software
or documentation, or refer to or otherwise use the Services as part of an
effort to develop software (including, without limitation, any routine,
script, code, or program) having any functional attributes, visual
expressions, or other features similar to those of the Services or to
compete with Us;
9. except with Our prior written permission, publish or perform any
performance or benchmark tests or analysis relating to the Services;
10. rent, lease, sublicense, sell, assign, loan, use for time sharing or
service bureau purposes, or otherwise transfer the Services or any of your
rights and obligations under this Agreement; or
11. assault, interfere, deny service in any way or form to any other network,
computer, server, or node through the Service, or interfere with or disrupt
servers or networks connected to any Services.
4.5 Open Source. The open-source code components that are included with the
Software are redistributed by Us under the terms of the applicable open-source
license for such components. Your receipt of open-source code components from Us
under these Terms neither enlarges nor curtails your rights or obligations
defined by the open-source license applicable to the open-source code
components. Copies of the open-source code licenses for the open-source code
components that are included with the Software are included with or referenced
in the Software’s documentation.
4.6 Availability You may use the Software solely to access the Services. A
computer, mobile phone or device, or other equipment enabled to access the
Internet (a “Device”) is required to utilize the Services. It is therefore your
responsibility to ensure that you have, at all times, an active and stable
internet connection. You are solely responsible for ensuring that your Device is
sufficient and compatible for use with the Service and complies with all System
Requirements. The speed and quality of the Software and Services may vary and
are subject to unavailability, including emergencies, third-party service
failures, transmission, equipment or network problems or limitations,
interference, signal strength, and maintenance and repair, and may be
interrupted, refused, limited or curtailed.
4.7 Termination and Post Termination Obligations. Upon expiration or any
termination of these Terms, you must stop using the Services, delete or destroy
all copies of the Software, from all Devices, and cease use, return, or destroy
any of Our Materials in your possession.
ARCHIVED VERSIONS
* Current Version [/terms/]
* October 15, 2019 [/terms20191510/]
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Privacy Policy
13/04/2026
The privacy policy versions are functionally identical with only minor URL parameter changes in website links (tracking identifiers changed from 'ext8e939540-2bf3-11f1-85be-65ef54685a42' to 'ext7d0cda30-377d-11f1-92ad-3b512bb19dc8'). No changes were made to data collection practices, third-party sharing, retention periods, logging practices, or jurisdiction.
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This website utilizes technologies such as cookies to enable essential site
functionality, as well as for analytics, personalization, and targeted
advertising. To learn more, view the following link: Privacy Policy
[https://www.hotspotshield.com/privacy-policy/]
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PRIVACY POLICY
Last Updated: October 31, 2024
TABLE OF CONTENTS:
1. Introduction
2. What Information Do We Collect About You?
3. How Do We Use Your Information?
4. Disclosure of Information - Who Do We Share Your Information With and Why?
5. Product Specific Privacy Notices
6. Cookies and Other Tracking Technologies
7. Use of Advertising Services with Free VPN Products
8. Information Security
9. International Data Transfers
10. Data Retention
11. Your Rights
12. Technology Licensing
13. Age Restrictions
14. Privacy Policy Updates
15. Contact Us
1. Introduction. At Hotspot Shield, we believe it’s important that everyone,
regardless of their situation, can obtain secure and private access to the
internet. We always aim to provide this access without compromising the privacy
of our customers. Hotspot Shield is provided by Anchorfree, LLC or Pango GmbH,
and a part of the Pango Group
[https://www.pango.co/?vh=ext7d0cda30-377d-11f1-92ad-3b512bb19dc8] “Pango”
(hereinafter referred to as “we”, “us”, or “our”).
This Privacy Policy describes our privacy practices across the various products,
services, applications, and websites that link to this policy (we refer to these
collectively as our “Services”, or individually as a “Product” or “Service”).
This Privacy Policy applies to the access or use of our Services, and you agree
to be bound by this Privacy Policy if you access or use our Services. If you do
not agree with this Privacy Policy or any provisions hereof, please do not use
our Services.
Though many of our Services are made available to consumers directly, some of
our Services are offered to businesses or enterprise customers. For those
Services, our customer is a business entity or other organization that may
authorize individual end users (e.g. employees or customers) to use the Services
that it has purchased or licensed from us. Where an organization is our
customer, it may maintain accounts with us through which it and its users may
submit information (“Customer Data”). In such cases, the organization that
purchased or licensed our Services typically controls those accounts associated
with their users and the organization may receive some Customer Data in order to
maintain the account. In this case, we are generally a processor of Customer
Data and the organization is the controller of such Customer Data. See the
‘Disclosure of Information’ section below for additional details.
To contact us, please see the “Contact Us” section below for more information.
2. What Information Do We Collect About You? This section describes the
categories of personal data (or ‘personal information’) we may collect from
and/or about you. The types of information described below are not collected in
all situations and may vary depending on the Service you use. We collect the
applicable information you provide through your use of a Service or Services, or
as needed in specific Service-specific situations. For example, as noted in our
VPN Products Privacy Notice, [https://www.hotspotshield.com/privacy-policy/vpn/]
our VPN Products only collect a limited amount of personal data, and specifies
that the collection of any websites or apps visited during a VPN session are not
connected to any individual user, and therefore cannot be used for advertising
or marketing purposes. Please see our ‘Product Specific Privacy Notices’ section
below for more information.
2.1. Information You Provide to Us
* Account Information. If a Service requires, or allows you to create, an
account before you can access the Service, then we may collect information
such as your name, username, email address, and password as a part of the
account registration process.
* Billing and Payment Information. In order to purchase a Service, you may need
to provide us and/or our payment processing partners with personal
information such as your billing name, billing contact details (such as
street addresses and/or email addresses), and payment instrument details.
This basic billing information is used for payment processing and refund
requests.
* Communications and Submissions. You may choose to provide us with information
when you communicate with us (e.g. via email, phone, or chat for support or
to inquire about our Services), including when you fill out an online form,
respond to surveys, provide feedback, post comments to our website,
participate in promotions, or submit information through our Services.
2.2 Information Collected when You use Our Services.
* Usage information. We collect information about how you interact with our
Services, including when you visit and use our websites or apps, including
which UltraAV web pages or app features are used, and when and for how long
you use our Services. We may use cookies and/or other technologies to collect
this information. See Section 6 for more information on how we use cookies
and other technologies.
* Device information. We collect information from and about the device you use
to access our Services, including information about the browsers and apps you
use to access our Services. For example, we may collect device or mobile
advertising identifiers, browser types, device types and settings, operating
system versions, mobile, wireless, and other network information (such as
internet service provider name, carrier name and signal strength), and
application version numbers. We may use cookies and other technologies to
collect this information See Section 6 for more information on how we use
cookies and other technologies.
* Diagnostic information. We may collect information about the nature of the
requests that you make to our servers, such as what is being requested,
information about the device and app used to make the request, timestamps,
and referring URLs.
* Approximate location information. Unless otherwise expressly stated or with
your consent, we do not collect your location information based on your
device’s GPS or other device sensor data. However, we may collect your
approximate location by calculating an imprecise latitude and longitude based
on your IP address to provide you with better service (e.g. to connect you to
the nearest and fastest VPN server).
* VPN Service Specific Information. Our VPN Products do not log any information
that associates your account credentials or identity with your VPN session
activity. We do not maintain any records that show what websites you were
browsing or apps accessed through a VPN connection. However, we will:
* Identify the locations of the VPN servers utilized
* Collect similar diagnostic information as referenced above.
* Ask you to rate your connection and provide some more detailed survey
information if you are not satisfied with the service. Note this information
is not tied to a specific user.
* We may also assign your device a ‘hash’, which is a random ID generated when
you first launch one of our VPN apps. Device hashes are not linked to VPN
browsing activity or user identity, but may be used to measure individual
user activity.
See Our VPN Products Privacy Notice
[https://www.hotspotshield.com/privacy-policy/vpn/] for more information.
2.3. Information Provided to Us by Third Parties.
* Third Party Invitation. If you are invited to use one of our Services, the
party who invited you may submit your personal data or contact information,
such as your email address, to us.
* Third Party Accounts. Some Services may allow you to register an account
using a third-party account (such as a Google or Microsoft account) you have.
If you elect to register or enroll in our Services through your third-party
account, that third party may send us information about you that they have,
such as email address or account identifying information that will enable us
to provide our Services to you. What information is shared with us is
controlled by the applicable third party that you have an account with. You
may be able to control what information they send us via your privacy
settings for that third party account.
* Threat Information. We receive information from reputable members of the
security industry who provide information to help us to provide, develop,
test, and improve our Services (for example, lists of malicious URLs, spam
blacklists, phone number blacklists, and sample malware). Some of this
information provided by third parties may contain personal data such as name
or IP address on an incidental basis.
* Business Customers. From time to time, We may make Our Services to businesses
or corporate organizations on an enterprise level. Organizations that use or
license our Services for their end users may submit personal data to us to
facilitate account management and invite individuals to use those Services.
3. How Do We Use Your Information? We use the information we collect for various
purposes described in this section. For visitors from the European Economic Area
(EEA) or U.K., we also describe, below, our lawful basis for processing personal
data.
* To provide, maintain, troubleshoot, and support our Services. We use your
information for this purpose on the basis that it is required to fulfill our
contractual obligations to you. Examples include:
* For our VPN Products, using information about how much bandwidth you use and
how long you use our Services in order to provide the Services in accordance
with a plan to which you have subscribed;
* For our digital threat platform, using threat and device information to
determine whether certain items pose a potential security threat; and
* Generally, to ensure the proper functioning of our Services.
* For billing and payment purposes. We use your information in order to perform
billing administration activities and process payments, which are required to
fulfill our contractual obligations.
* To communicate with users and prospective users. We use your information to
communicate with you, including by responding to your requests, and sending
you information and updates about our Services. We may do this in order to
fulfill our contract with you, because you consented to the communication, or
because we have a legitimate interest in providing you with information about
our Services.
* To improve our Services. We want to offer you the best Services and user
experiences we can, so we have a legitimate interest in continually improving
and optimizing our Services. To do so, we use your information to understand
how users interact with our Services. For example, we (a) analyze certain
usage, device, and diagnostic information to understand aggregated usage
trends and user engagement with our Services (and, for example, invest in
technical infrastructure to better serve regions with increasing user
demand); (b) may use device and threat information to conduct spam, threat,
and other scientific research to improve our threat detection capabilities;
and (c) review customer feedback to understand how we can improve.
* To develop new Services. We have a legitimate interest in using your
information to plan for and develop new Services. For example, we may use
customer feedback to understand what new Services users may want.
* To market and advertise our Services. We may use your information to provide,
measure, personalize, and enhance our advertising and marketing based on our
legitimate interest in offering you Services that may be of interest. For
example, we may use information such as who or what referred you to our
Services to understand how effective our advertising is; or we may use
information to administer promotional activities such as sweepstakes and
referral programs. Note that our VPN Products do not use your VPN browsing
activity for these purposes and we do not maintain any records that show what
you were browsing or accessing through a VPN connection.
* To implement security measures and prevent against harm or liability. We may
use information for security purposes (such as to investigate security issues
or to monitor and prevent fraud) and to prevent abuse. We may do this to
comply with our legal obligations, to protect an individual’s vital
interests, or because we have a legitimate interest in preventing harm or
liability to us and our users. For example, we may use account, usage, and
device information to determine if an entity is engaging in abusive or
unauthorized activity in connection with our Services.
* For compliance with legal obligations. We may use your information as
required to comply with applicable law or regulation, legal process, or other
legal obligation to which we are subject. For example, we may be compelled by
a contract or court to provide certain information necessary to our business
partners in order to fulfill the terms of a business agreement or our legal
obligations. We may also use your information to enforce our legal rights and
resolve disputes. To learn more about our practices regarding sharing your
information with third parties for legal compliance purposes, see Section 4
below.
4. Disclosure of Information - Who Do We Share Your Information With and Why?
We may disclose or use your information in the following circumstances, as
applicable:
* In accordance with your instructions or consent. For example, some Services
may allow you to register an account using a third-party account (such as a
Google or Microsoft account). If you choose to do so, we will share
information with the applicable third-party account provider you used.
* To your business organization (for our business Services). If you receive
access to our Services through a business customer of ours (e.g. your
employer) that has agreed to provide you with access to our Services through
a business account, we may be required to share your information necessary to
maintain your account and the personal contact information associated with it
with such organization or persons associated with the organization (e.g. an
administrator). Please note, business organizations do not get access to, or
receive any reports from, any network or Internet usage information related
to your VPN activity; and business organizations do not receive any
information our identity Products we provide, such as information associated
with your credit report, credit alerts, or other identity-related
information, unless you provide them with express consent for any such use in
each instance of their request.
* For collaborating with others on your behalf. Some Services may provide ways
for different users to interact or collaborate with each other. Your
information will be shared in connection with those activities if you choose
to engage in them.
* To our vendors and service providers. Certain aspects of our Services are
enabled or provided by third parties service providers and partners
(including our affiliates) we engage, and we may disclose information to such
companies and/or individuals we engage to perform business functions and
services on our behalf. Such functions may include, for example:
* processing of payments
* providing analytics about our Services
* providing sales and customer support
* providing certain features or functionalities of our Services
* maintaining or hosting the infrastructure required to provide our Services
* delivering our marketing and advertising content.
Where your personal data may be shared with such third parties, we protect your
data by entering into agreements containing appropriate confidentiality and data
processing terms with the applicable third parties, reviewing their security
practices, and limiting information sharing to the scope of what they are
helping us with.
* To our corporate affiliates. We may disclose certain data or information to
our affiliate entities that are a part of Pango Group (including Pango GmbH
and Intersections, LLC d/b/a Pango) for legitimate purposes, such as to
provide certain Services that may be licensed by one of our affiliates to
you.
* To a new owner(s) of our Services or any of our assets. If ownership or
control of all or part of our Services, assets, or business changes, we may
transfer your information to the new owner.
* For collection of aggregated or de-identified data. We may collect, use and
share technical usage data or other user data that is aggregated and/or
de-identified such that it no longer reveals the identity of an individual
user for regulatory compliance, research and analysis, our own marketing and
advertising activities, improvement of our Services, and other legitimate
business purposes.
* To comply with legal processes and the law. We may share your information if
we are required to do so by applicable law; to comply with our legal
obligations; to comply with legal process; and to respond to valid law
enforcement requests relating to a criminal investigation or alleged or
suspected illegal activity that may expose us (or affiliates), you, or any of
our other users to legal liability. If we share your information for these
purposes, we limit the information shared to what is legally necessary, and
challenge information requests that we believe are unlawful, overbroad, or
otherwise invalid. To reiterate, our VPN Products do not collect information
about which websites you visit or apps you use, so this information is not
accessible in a law enforcement request.
* To enforce our rights and prevent fraud and abuse. We may share limited
amounts of your information to enforce and administer our agreements with
customers and users, and to respond to claims asserted against us or our
affiliates. We may also share your information in order to protect against
fraud and/or abuse against us, our affiliates, users and others.
5. Product Specific Privacy Notices and Terms. To better understand the privacy
practices for our VPN Products, please see Our VPN Products Privacy Notice
[https://www.hotspotshield.com/privacy-policy/vpn/].
6. Cookies and Other Tracking Technologies. We use various technologies in our
Services to help us collect certain website or app user information.
These technologies include:
* Cookies. “Cookies” are small text files that can be placed on your computer
or mobile device in order to identify your web browser and the activities of
your computer on the Website. Cookies enable us or third parties that we
allow (such as certain of our authorized service providers) to set cookies on
your device to recognize visitors to our websites. For more information on
how we use cookies, see section 6.1 below.
* Pixel Tags / Page Tags / Web Beacons / Tracking Links. These tools allow us
to determine if you perform a specific action on a web page or email message.
When you access a page, ad, or email, or click a link, these items let us
know that you have accessed that page, opened an email, or clicked a link.
They may also indicate your Internet Protocol (IP) address, which enables us
to determine your approximate geographic location as assigned by your
Internet Service Provider.
* Software Development Kits (SDKs) / Software. This mobile app software is
provided by our business partners that enables our mobile apps to interact
with the services those partners provide. See section 7 below for more
information about how we use SDKs with our Free VPN products to provide
advertising services.
6.1 Use of Cookies; Your Choices
* In general, we may use cookies in the following ways:
* To provide our Services. Some cookies are essential for the proper operation
of our Services. For example, cookies allow us to authenticate who you are
and whether you’re authorized to access a resource.
* To store your preferences. Cookies can store your preferences, such as
language preferences or whether to pre-fill your username on sign in forms.
We may also use them to optimize the content that we show to you.
* For analytics. Cookies are used to inform us how users interact with our
Services so we can, as a legitimate interest, improve how they work (such as
what screens or webpages you access, and whether our advertising is
effective).
* For security. Cookies can enable us and our payment processors to detect
certain kinds of fraud.
* For Pango’s advertising-related purposes. We advertise our Services online
with the help of third parties who show ads and marketing about us on sites
around the internet.
* Your Choices With Our Use of Cookies:
* In general - You have the ability to manage your cookie preferences in your
web browser settings, including deleting cookies and blocking cookies from
being set on those browsers or devices. Visit the “help” section of your
browser to understand what controls it gives you over cookies. Note that
deleting or blocking certain cookies could adversely impact the proper
operation of our Services, and, in some cases, some features of the
website(s) may not function as a result.
* Industry Advertising Choices - For information on how to opt out of
personalized or interest-based advertising, you can visit the following
pages:
* U.S.: Digital Advertising Alliance opt out page
[https://optout.aboutads.info/?c=2&lang=EN]
* EU or UK: Your Online Choices [https://www.youronlinechoices.eu/]
For visitors to Pango.co, we currently do not use third party advertising or
cookies that enable preferences.
* Cookie Policy:
* Hotspot Shield’s cookie policy is available here
[https://www.hotspotshield.com/legal/cookie-policy].
* For more information on other Pango websites’ use of cookies, please visit
the respective product specific websites to view its applicable cookie notice
or policy terms.
7. Use of Advertising Services With Free VPN Products
* For users of our free VPN products, we may serve ads through the use of third
party advertising services indicated below. As previously noted, neither we
nor any third party advertising service has access to the VPN browsing
information, such as the websites you visit or apps you use while in a VPN
session. However, as with any online advertising service, the entities will
have access to the information associated with the ad delivery such as which
website or app the ad was delivered to, and the device-specific information
listed below.
* In order to display ads in our apps, we may utilize third party software
development kits (SDKs), which consists of software code provided by a third
party and embedded into our apps. These SDKs may collect the following
information from your device or use:
* Device or mobile advertising identifiers (controlled by your mobile operating
system)
* Internet Protocol (IP) Address, which may reveal your approximate geographic
location as determined by your carrier or ISP. However, when using the VPN
service, this may replace your actual location with an alternative geographic
location.
* Device-specific information such as make, model, OS version, language, time
zone and other information.
* The name of the app or website serving the ad.
* As some of the ads may be personalized based on your mobile advertising
identifier or IP address, you may see an AdChoices icon on an ad. You can
click this icon to learn more about the ad network that provided the ad, its
privacy policy, and your choices regarding opting out from any personalized
advertising. If you opt out from personalized advertising, you may still see
non-personalized ads. While we request you not to use ad blockers to prevent
the display of ads because that is how we support our free Services, our
Services are able to continue functioning if you do use ad blockers.
We may use the following advertising services to provide ads with our free VPN
products:
CompanyPrivacy Policy or Opt-OutUnity Adshttps://unity.com/legal/privacy-policy
[https://unity.com/legal/privacy-policy]Ironsourcehttps://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
[https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/]Digital
Turbinehttps://www.digitalturbine.com/legal/privacy-policy
[https://www.digitalturbine.com/legal/privacy-policy]InMobihttps://advertising.inmobi.com/page/opt-out
[https://advertising.inmobi.com/page/opt-out]Kochavahttps://www.kochava.com/privacy/opt-out/
[https://www.kochava.com/privacy/opt-out/]Mintegralhttps://www.mintegral.com/en/privacy
[https://www.mintegral.com/en/privacy]Metahttps://www.facebook.com/privacy/policy/
[https://www.facebook.com/privacy/policy/]Apppsflyerhttps://www.appsflyer.com/legal/opt-out/
[https://www.appsflyer.com/legal/opt-out/]
In addition, you may opt-out of interest-based mobile advertising by utilizing
the Digital Advertising Alliance (DAA) AppChoices app.
[https://youradchoices.com/appchoices]
8. Information Security. We understand the importance of protecting information
provided to or collected by us, including personal data, and employ reasonable
and appropriate methods (including a range of administrative, organizational,
technical, and physical safeguards designed to protect your data such as use of
best practices, procedures, policies, training, technology, and oversight) to
protect against and reduce the risk of unauthorized access, loss, or release of
data. Access to your account or services information is restricted to our
employees or contractors who require such access to perform their job functions.
While our controls are strong and we strive to protect your personal information
through these various means, we cannot guarantee or warrant the security of the
information, as no data security measures can guarantee 100% protection. We
recommend you take every precaution in protecting your personal information when
you are on the Internet or otherwise. You should change your passwords often,
use a combination of letters and numbers when creating passwords, and make sure
you use a secure browser.
9. International Data Transfers. Depending on where you reside and what Services
you use, Pango may transfer your personal data to countries other than the one
in which you reside. We do this to facilitate our operations, and transferees
include other Pango companies, service providers, and partners. Laws in other
countries may be different to those that apply where you reside. For example,
personal data collected within the U.K., Switzerland or the European Economic
Area (EEA) may be transferred and processed in the United States for purposes
described in this policy. However, we put in place appropriate safeguards that
help to ensure that such data receives an adequate level of protection, which
typically includes Pango and corporate recipients executing the Standard
Contractual Clauses (aka ‘Model Contracts’) adopted by the European Commission
or UK for such transfers to the U.S.
In addition, Pango Group (including Anchorfree LLC) complies with the EU-U.S.
Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and
the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the
U.S. Department of Commerce. Pango has certified to the U.S. Department of
Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles
(“EU-U.S. DPF Principles”) with regard to the processing of personal data
received from the European Union in reliance on the EU-U.S. DPF and from the
United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S.
DPF. Pango has certified to the U.S. Department of Commerce that it adheres to
the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”)
with regard to the processing of personal data received from Switzerland in
reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in
this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles, the Principles shall govern. To learn more about the Data Privacy
Framework (“DPF”) program, and to view our certification, please visit
https://www.dataprivacyframework.gov. Click here
[https://www.pangoholdingcompany.com/legal/pango-data-privacy-framework-privacy-policy/]
to view our EU/Swiss-U.S. Data Privacy Framework Privacy Policy You may contact
us if you would like more information about such safeguards.
If you change your country of residence, the Pango company responsible for your
data may change accordingly, and your data may be transferred to that other
company.
For users of our VPN products, if you are a UK or EEA resident and you choose to
use our software to route your Internet traffic through servers in countries not
deemed ‘adequate’ by the UK or EEA, then you acknowledge that such transfers are
executed at your direction and with your unambiguous consent.
10. Data Retention. We generally retain your personal information for as long as
is needed to provide the Services to you, or for as long as you have an account
or subscription with us. We retain your personal information as reasonably
necessary for the respective purpose. In determining the criteria by which to
retain or dispose of your information, we consider the type, sensitivity,
context, and purpose of collecting the information. We may also retain personal
information if required by law, or for our legitimate interests, such as abuse
detection and prevention, and defending ourselves from legal claims. Residual
copies of personal data may be stored in backup systems for a limited period as
a security measure to protect against data loss.
With respect to our VPN Products, we do not collect or retain data about your
browsing activity while you are connected to the VPN Services.
11. Your Rights. Depending on your state or country of residence, you may have
certain legal rights with respect to your personal information, subject to
exceptions and limitations provided by applicable laws and regulations.
11.1 General. In general, you may have the following rights to your personal
data:
* access and receive a copy of your personal data;
* correct your personal data;
* restrict the processing of your personal data;
* object at any time to the processing of your personal data;
* have your personal data erased;
* data portability;
* withdraw any consent you previously gave to the processing of your data (such
as opting out to marketing communications);
* lodge a complaint with a data protection authority;
* request that we provide you with the categories of personal data we collect,
disclose or sell about you; the categories of sources of such information;
the business or commercial purpose for collecting or selling your personal
data; and the categories of third parties with whom we share personal data.
Note some of this information may already be provided in this Privacy Policy.
For clarity, the above describes examples of rights an individual may have. You
may have some, but not all of the rights described above, depending on where you
reside and what laws and regulations apply to you. Additional U.S. state
specific privacy rights are further described below.
You may be able to exercise some of these rights by using the settings and tools
provided in our Services. For example, you may be able to update your user
account details via the relevant account settings screen of our apps. You may
also be able to opt out from receiving marketing communications from us by
clicking an “opt out” or “unsubscribe” link in such communications.
Some mobile and web browsers transmit "do-not-track" or “opt-out preference”
signals. We currently do not take action in response to these signals.
Otherwise, if you wish to exercise any of these rights, you may contact us using
the details in the “Contact Us” section below. As permitted by law, we may ask
you to verify your identity before taking further action on your request. You
may also be permitted to designate an authorized agent to submit certain
requests on your behalf. If you do so, you must give the authorized agent
written permission to make such requests, or a power of attorney. We may also
follow up with you to verify your identity before processing the authorized
agent’s request.
11.2 Your California Privacy Rights. The information provided in this Privacy
Policy describes the categories of personal information We may collect, process
and share with certain service providers and other businesses. If you are a
California resident and would like to exercise your rights to receive the
specific pieces of information, or other privacy rights applicable to you,
please contact us as specified in the ‘Contact Us’ section below.
We do not ‘sell’ personal information for our own monetary benefit. However, as
the CCPA defines ‘sell’ broadly, some of the advertising services that support
our website, marketing efforts, and mobile applications use third party
advertising services that may be deemed a ‘sale’ under California law. Please
see Our terms relating to your choices relating to cookies and the app-specific
advertising services listed above to indicate your preferences with respect to
ads or cookie usage as applicable.
California residents also have the right to limit the use of sensitive personal
information if we use that information for purposes beyond what is needed to
provide the Services you request or for other reasons specified in the CPPA. As
we do not use or disclose sensitive personal information for other purposes
without your consent, we do not offer you an option to limit the use of
sensitive personal information.
11.3 Other U.S. Only State Specific Privacy Rights
If you are a resident of California, Colorado, Connecticut, Maine, Nevada,
Oregon, Texas, Utah, or Virginia, you may have specific or additional rights
under your state’s privacy laws.
Depending on the jurisdiction where you reside and the scope of applicability,
you may have certain of the following rights with respect to your personal
information:
* Right to know what personal information we collect, how we use and share it,
and how long we keep it. The state laws generally require that we provide you
information about the categories of personal information we collect and the
purposes for which we collect each category. This Privacy Policy provides
details about our collection and usage practices. As described in Section 2
of this Privacy Policy, we collect personal information when you interact
with us and use our Services, from third parties, and from the devices you
use. Use of certain identity protection Services may require you to provide
information such as social security number, driver’s license, financial
account data, or other information that is considered sensitive personal
information under state privacy laws. We retain information only as long as
reasonably necessary for business, accounting, tax or legal purposes and then
securely delete it. We use the information we collect for business and
commercial purposes as those terms are defined by the CCPA. Third
parties/service providers we use to perform business functions on our behalf
may use information for the same purposes.
* Right to access, delete and correct information. You may have the right to
request access to your information, or for us to delete or correct your
personal information. Please contact us to request that we delete personal
information we have about you, or to correct inaccurate personal information
we have about you. Unless we need it for reasons specified or permitted by
applicable laws or regulations, we will work with you to delete your personal
information accordingly. You may also request access to your information, and
we will provide the relevant information to you in a portable and readily
usable format.
* Right to limit the use of sensitive personal information. For sensitive
personal information that we collect, we will only use or disclose it either
with your specific consent when required, or as otherwise permitted by law.
As we do not use or disclose sensitive personal information for other
purposes without your consent, we currently do not offer you an option to
limit the use of sensitive personal information.
* Right to tell us not to use personal information to create profiles about you
that we use to inform decisions that have legal or similarly significant
effects. We do not use personal information to profile you to further
decisions that have legal or similar significant effects.
* Right to tell us not to sell personal information or process it for certain
targeted advertising purposes. The laws vary in the way they define sale and
certain targeted advertising, but generally, they require that we provide you
with the ability to limit activities that involve sharing personal
information for monetary or other valuable consideration and using personal
information about you from your activity across other websites or apps to
target ads to you. You can opt out of certain sharing or processing of your
personal information by accessing your privacy preferences page for the
applicable Product website. We do not currently respond to Do Not Track
signals. We do not knowingly sell or share personal information related to
children under 16 years of age.
* Right to appeal a denial of your request to exercise the privacy rights
provided by the state law. Some states allow you to appeal a denial of your
request to exercise your privacy rights provided by applicable state law. If
you are a resident of Colorado, Connecticut, Oregon, Texas, or Virginia and
we deny your request to exercise certain rights pertaining to your personal
data, you can appeal the denial of a request to exercise privacy rights by
following the instructions listed in the denial communication, by submitting
a request through a privacy inquiry to [email protected]
[[email protected]].
* Right to not be discriminated against. Some state laws ensure that you have
the right to not be discriminated against. We do not discriminate against
you, or anyone, for your/their exercise of any rights provided to you by
applicable state law.
You can exercise your right to know, access, delete, and correct data directly,
or, in California, Colorado, Connecticut, Oregon, and Texas, you may appoint an
authorized agent to act on your behalf, by submitting a request. You can
exercise your right to opt-out of selling and sharing by visiting the applicable
privacy preferences page or the cookie banner for the Service you are using.
Note we may require you to verify your identity using the processes we describe
in an applicable Product dashboard or the privacy choices page before we fulfill
your request.
12. Technology Licensing. We occasionally license our technology to third party
partners who may integrate it with applications developed and offered by those
partners. Our partners, and not Anchorfree or Pango Group, are responsible for
those applications and for determining what data is collected by those
applications and how it is processed. Please contact the relevant partner and
refer to their Privacy Policy to learn more about how those applications process
your personal data.
13. Age Restrictions. Our Services are not intended for and may not be used by
minors. In this context, minors are individuals under the age of 16 except for
our identity and credit monitoring services, which are restricted to those under
the age of 18. We do not knowingly collect personal data from minors or allow
them to use our Services. If we discover that we have collected personal data
from a minor, we may delete such data without notice. Please note that the legal
terms under which we make certain Services available may require users to be
older than 16 years of age.
14. Privacy Policy Updates. We may update this Privacy Policy from time to time
in accordance with this section for reasons such as changes in laws, industry
standards, and business practices. We will post updates to this page and update
the “Last updated” date above. If we make updates that materially alter your
privacy rights, we will also provide you with advance notice, such as via email
or through the Services. If you disagree with such an update to this policy, you
may cancel your Services account. If you do not cancel your account before the
date the update becomes effective, your continued use of our Services will be
subject to the updated Privacy Policy.
15. Contact Us. We expect this Privacy Policy to evolve over time and welcome
feedback from our users about our privacy practices. If you would like to
exercise your rights, have any questions or complaints about our privacy
practices, you can contact us using the following details or submit your request
to [email protected]: [[email protected]]
Anchorfree LLC - Hotspot Shield
250 Northern Ave, Floor 3
Boston, Massachusetts, 02210
Pango GmbH
Hansmatt 32, 6370 Stans, Switzerland
For visitors from the UK or EEA, the GDPR gives you additional rights to contact
our Data Protection Officer (DPO). We have appointed Bird & Bird DPO Services
SRL as a DPO for Pango and our Services, and may be reached:
* by using the following email: [email protected]
* by mail at the following address: Bird & Bird DPO Services SRL, Avenue Louise
235 b 1, 1050 Brussels, Belgium.
ARCHIVED VERSION
* September 29, 2022 [/privacy-policy-09292022/]
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© Intersections, LLC 2026. All rights reserved.
This website uses cookies to improve the user experience. To learn more about
our cookie policy or withdraw from it, please check our Privacy policy Accept
No-Logs Policy
If you take a look at the Hotspot Shield VPN’s privacy policy, the company says: “Our VPN products do not log any information that associates your account credentials or identity with your VPN session activity. We do not maintain any records that show what websites you were browsing or apps accessed through a VPN connection.”
However, it is important to note that, while Hotspot Shield claims not to log any data that could be tied to the user, the company’s privacy policy goes on to state that it will:
- “Record the amount of bandwidth used in a VPN session
- Identify the locations of the VPN servers utilized
- Collect similar diagnostic information as referenced above.
- Ask you to rate your connection and provide some more detailed survey information if you are not satisfied with the service. This information is not tied to a specific user.
- We may also assign your device a ‘hash’, which is a random ID generated when you first launch one of our VPN apps. Device hashes are not linked to VPN browsing activity or user identity, but may be used to measure individual user activity.”
What Features Does Hotspot Shield Offer?
Our Take
The feature set is thin: kill switch and that's essentially it. No split tunneling, no dedicated IP, no smart DNS, no multihop, no ad blocker. You're paying for speed (Hydra protocol) and little else.
As with any VPN service, it’s important to find out what features are included before committing to a lengthy subscription.
Here we’ll take a look at some of the key features on offer with Hotspot Shield VPN.
Simultaneous Connections
You might want to use your VPN connection to secure more than one device at any given time – for example, if you’re watching a streaming service on your laptop while also browsing the internet on your phone.
Hotspot Shield VPN Premium users can have up to five devices connected and secured simultaneously. Users on the free plan are limited to just one device at a time.
Supported Platforms
Hotspot Shield VPN has proven itself an effective option for those with a wide array of devices and platforms.
Currently, the company offers desktop support for Windows, macOS, and Linux, as well as iOS and Android apps.
The provider also offers support for most routers, with instructions on how to install the VPN on your existing router, and also allows customers to buy a router pre-installed with Hotspot Shield.
By setting up a Hotspot Shield VPN on your router at home, you secure every device that connects to it without the need to install the VPN individually on each piece of hardware around the house.
Advanced Features (Dedicated IP, Smart DNS, Multihop)
Hotspot Shield VPN is limited in the availability of more advanced features, such as the provision of dedicated IP addresses, multihop servers, or Smart DNS.
These features are far from essential, but if they’re important to your needs, then Hotspot Shield VPN may not be the best VPN for you.
Get Hotspot Shield Now
45
days
Money-back guarantee - cancel anytime, no questions asked.
Hotspot Shield VPN includes a range of advanced privacy and security features to ensure your browsing activity remains confidential.
Here we’ll take a look at some in more detail.
Kill Switch
The apps include a built-in kill switch functionality. This means if your VPN connection drops, for any reason, Hotspot Shield VPN will immediately disconnect your device from the internet to prevent any of your data from leaking out over an unsecured connection.
Leak Protection
For those concerned about their true IP address being accidentally leaked online, Hotspot Shield VPN includes a safeguard.
The company aims to prevent DNS leaks by passing all traffic through its own DNS servers (rather than the servers belonging to your internet service provider ) to prevent your online activities from being visible to your ISP or anyone else.
Hotspot Shield VPN also includes a help section in its official online support pages on how to prevent webRTC leaks during your VPN session.
Split Tunneling
Split tunneling (which Hotspot Shield calls SmartVPN) allows you to decide which apps on your device use the VPN and which ones do not.
For instance, if you want to use Hotspot Shield VPN to watch Netflix without geo-restrictions, but also want to access your bank’s online app through an unencrypted internet connection (as you may need to prove your real location), you can by using the split tunneling setting.
This offers flexibility and allows you to use the VPN on your terms.
P2P File Sharing (Torrenting)
Hotspot Shield VPN supports P2P file sharing and torrenting.
This means you can protect your privacy online while torrenting or using P2P services without experiencing restrictions or bandwidth throttling.
VPN Protocols
Another huge factor for many people when it comes to choosing a VPN provider is finding out which encryption protocols are used.
Hotspot Shield VPN has its own proprietary Hydra protocol. As an in-house, not open-source version of the Wireguard protocol (which is used by other providers), Hotspot Shield claims Hydra solves issues of speed, security, compatibility, and ease of use.
The service also offers users IPSec (IKEv2) and WireGuard (only on macOS and iOS apps), but not OpenVPN.
Hotspot Shield VPN uses military-grade AES-256 encryption to protect users’ private data.
Which Apps & Devices Are Supported?
Our Take
Simple apps on major platforms. The 5-device limit is a significant drawback in multi-device households. The app design prioritizes one-click simplicity over configurability.
How well a VPN performs can have a significant impact on your internet experience.
Here we look at the real-world speeds of Hotspot Shield VPN, as well as its server network and locations.
VPN Server Locations
Our Take
1,800+ servers across 80 countries. Adequate coverage but nothing exceptional. The network is designed for speed rather than maximum geographic reach.
Hotspot Shield has servers in 4 US states across 4 cities . Last updated: 29/03/2026
US Server Locations: Hotspot Shield
-
New York
(NY)
1 city
New York
-
Illinois
(IL)
1 city
Chicago
-
Texas
(TX)
1 city
Dallas
-
California
(CA)
1 city
Los Angeles
US Server Locations
The number of servers and where they’re located are key considerations when choosing a VPN provider.
If you’re trying to stream the latest TV shows from other countries, such as Australia, Japan, France, the US, Canada, Europe, or the UK, you’ll need servers within the country you’re trying to access.
If you’re based in or traveling to somewhere with internet restrictions, like China or Russia, and want to bypass online censorship or access content from home, you’ll want a VPN server close by to mitigate congestion or long-distance speed reductions.
Hotspot Shield VPN currently has 1,800+ servers in 80 countries, including over 35 popular cities. These are located on more than five continents around the world, so whether you need a low-latency US server or a virtual location overseas, you’re unlikely to ever be far from a Hotspot Shield server.
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45
days
Money-back guarantee - cancel anytime, no questions asked.
How we tested Hotspot Shield Review: Hydra Protocol Fast, But US-Based Privacy Risk
🔒 Purchased with our own money (no free accounts)
🧪 3 leak tests: IP, DNS, WebRTC
📊 Scored using published methodology
💰 Affiliate partnerships do not influence scores
✅ 29,689 VPN tests run on this site · latest 10 Jun 2026
💡 Ownership and corporate structure is independently verified
With a wide range of features designed to enhance the safety and security of its users online, Hotspot Shield VPN is a reliable choice for those wanting to protect their data.
The provider covers all the essentials, with a wide range of encryption protocols, servers, and streaming service compatibility. Its premium family plan makes it worth considering by families, allowing up to five members the option to connect up to five devices at once.
While it might be missing some of the extra features available with other premium VPN providers, Hotspot Shield VPN is one of the few services to offer a free plan and a 45-day money-back guarantee.
Get Hotspot Shield Now
45
days
Money-back guarantee - cancel anytime, no questions asked.
Customer Support
Our Take
24/7 live chat for paid users. The free tier gets email only. Response quality is acceptable.
When selecting a VPN provider, the type and availability of customer support is an important consideration.
Hotspot Shield VPN has multiple customer support options, including 24/7 live chat support, email, and an online help center on the Hotspot Shield website.
Who Isn’t Hotspot Shield Right For?
Based on our testing and research:
5-Eyes jurisdiction (USA) – Hotspot Shield is based in the United States, a 5-Eyes member. For users in high-risk situations, a US-based VPN with no independent audit represents a materially higher risk than Swiss or Panama-based alternatives.
Past privacy allegations – In 2017, a complaint filed with the FTC by the Center for Democracy & Technology alleged that Hotspot Shield’s free version was injecting tracking JavaScript, redirecting traffic, and sharing browsing data with advertising partners. Hotspot Shield disputed the claims; the FTC did not pursue enforcement. The company has since updated its privacy policy, but there is no independent audit to verify current practices.
Consider instead: Proton VPN, Mullvad, or NordVPN
No independent no-logs audit – Hotspot Shield has not published a third-party audit of its no-logs policy by a recognized security firm. This is a significant gap compared to audited competitors at similar price points.
Corporate ownership (Aura) – Hotspot Shield is owned by Aura, a consumer security company that bundles identity protection, credit monitoring, and VPN services. Privacy products owned by data-aggregating consumer security firms raise questions about data silo separation. Aura’s business model includes identity and credit data services.
Closed-source apps and proprietary protocol – Hotspot Shield uses a proprietary Hydra protocol that cannot be independently audited. Unlike WireGuard or OpenVPN (open-source, peer-reviewed), Hydra’s security properties rely entirely on Hotspot Shield’s internal claims. No external cryptographic review has been published.
Hotspot Shield Competitors
| Hotspot Shield | ExpressVPN | NordVPN | Surfshark | CyberGhost | |
|---|---|---|---|---|---|
| Best rate | $2.99/mo | $3.49/mo | $3.09/mo | $1.99/mo | $2.19/mo |
| Monthly price | $12.99 | $12.99 | $12.99 | $15.45 | $12.99 |
| Servers | 1,800+ | 3,000+ | 8,400+ | 4,500+ | 9,700+ |
| Countries | 80 | 105 | 167 | 100 | 100 |
| Devices | 5 | 8 | 10 | Unlimited | 7 |
| Jurisdiction | 🇺🇸 USA ⓘ | 🇻🇬 BVI ⓘ | 🇵🇦 Panama ⓘ | 🇳🇱 Netherlands ⓘ | 🇷🇴 Romania ⓘ |
| Money-back | 45 days | 30 days | 30 days | 30 days | 45 days |
| Kill switch | ✓ | ✓ | ✓ | ✓ | ✓ |
| Split tunneling | ✗ | ✓ | ✓ | ✓ | ✓ |
| No-logs audited | ✗ | ✓ | ✓ | ✓ | ✓ |
| Dedicated IP | ✗ | ✗ | ✓ | ✗ | ✓ |
| Open source | ✗ | ✗ | ✗ | ✗ | ✗ |
| RAM-only servers | ✗ | ✓ | ✓ | ✓ | ✓ |
| Ad/tracker blocker | ✗ | ✗ | ✗ | ✗ | ✗ |
| Our rating | 6.2/10 | 8.6/10 | 8.8/10 | 8.2/10 | 7.4/10 |
| Review | Read review → | Read review → | Read review → | Read review → | Read review → |
Our Verdict
Our Take
Hotspot Shield is fast but thin. The Hydra protocol delivers excellent speeds, but the limited features, 5-device cap, US jurisdiction, and past FTC controversy make it hard to recommend over more complete alternatives at similar prices.
Based on our hands-on testing and data analysis, here is our overall assessment of Hotspot Shield.
:methodology-blurb:
6.2
/ 10
Adequate
Fast proprietary protocol, but US-based with a history of privacy controversies.
Best for:
Speed-focused users who prioritize performance over privacy
Not for:
Privacy-conscious users (past tracking/data sharing allegations, Aura ownership)
Leak Tests
Kill Switch
Split Tunneling
No-Logs Audit
Jurisdiction
Open Source
From $2.99/mo
(best plan)
45-day money-back guarantee
Our rating scale
| Rating Rubric | |
|---|---|
| 9 - 10 | Exceptional - best in class, no significant weaknesses |
| 8 - 8.9 | Excellent - highly recommended with minor trade-offs |
| 7 - 7.9 | Good - solid choice for most users |
| 6 - 6.9 | Adequate - works but has notable limitations |
| 5 - 5.9 | Below average - consider alternatives |
| Below 5 | Not recommended |
Frequently Asked Questions
How does Hotspot Shield stack up against NordVPN?
Hotspot Shield VPN and NordVPN are both well-known and reputable premium VPN providers. They both offer a wide range of servers in many countries around the world, providing users with a variety of encryption protocols and compatibility with most devices and platforms.
NordVPN offers a few more additional features, such as an ad blocker and threat protection, a dedicated IP option, double VPN, and smart DNS, though Hotspot Shield has servers in over 80 locations, whereas NordVPN covers 60.
Ultimately, the right VPN comes down to your individual needs and requirements.
How does Hotspot Shield compare with ExpressVPN or CyberGhost?
Both CyberGhost and Express VPN are well-established in the VPN industry and both providers have a proven reputation of providing secure and private service.
Hotspot Shield VPN and ExpressVPN each offer their own in-house protocols, though ExpressVPN also offers further additional features that CyberGhost and Hotspot Shield don’t, such as TrustedServer Technology, Threat Manager, and a built-in speed test.
Each provider has its own strengths and weaknesses, so the choice comes down to a user’s individual requirements – see our full VPN reviews for comprehensive details on each service.
Is Hotspot Shield a good VPN?
Hotspot Shield VPN incorporates military-grade AES-256 encryption, has a large server network that spans the globe, and provides fast speeds for streaming and gaming. It’s also built its own protocol based on WireGuard, designed to balance speed and security, and is available on popular platforms and devices.
These capabilities make Hotspot Shield a suitable VPN for most users’ needs, though the best VPN for an individual will depend on their specific requirements and purposes for using a VPN.
Is Hotspot Shield VPN really free?
Hotspot Shield VPN provides a free, basic version of its premium service, which provides the same level of encryption as its paid plans and no bandwidth caps.
This free plan is limited to one device at a time though, and users can only access one server location, instead of the 80+ available to paid users.
Hotspot Shield does offer a seven-day free trial of its premium plan, which provides full access to all features, and a 45-day money-back guarantee for all paid subscriptions.
Can you be tracked with Hotspot Shield?
Hotspot Shield VPN protects its users’ online privacy and prevents tracking in several ways: it masks a device’s IP address, encrypts a user’s internet traffic, and stops browser tracking. This provides anonymity while online.
It should be noted that, while Hotspot Shield’s privacy policy states it doesn’t log user data, the company is based in the US, which is a member of the Five-Eyes Alliance. It’s owned by Pango, which also owns Betternet and UltraVPN.
Does Hotspot Shield VPN protect you from malware?
Hotspot Shield VPN offers malware protection with its premium plan, which safeguards connected devices from four types of cyber threats: malware sites, illegal or phishing sites, infected sites, and spam sites and content farms. It does this by comparing sites users are about to visit with a database of known or suspected dangerous sites.
It also encrypts users’ internet sessions from end to end to ensure privacy and security.
Write your Hotspot Shield review
Update history
This page was revised 35 times between March 2023 and April 2026.
Linked jurisdiction information to ownership documentation for transparency.
Money-back guarantee references now pull from verified provider data.
Added proprietary Hydra protocol speed analysis with AES-128 encryption context, 500MB/day free tier details, and no-crypto payment limitation disclosure.
Added company background section covering Hotspot Shield's 18-year history since 2008.
Added ecosystem overview showing Antivirus, Password Manager, Spam Call Blocker available alongside the VPN subscription.
Updated server network overview covering 1,800 servers across 80 countries, with interactive coverage map and nearest-server highlighting.
Added table of contents with section-by-section navigation for faster access to specific topics.
Added source citations and verification dates to all factual claims in the Hotspot Shield review.
Redesigned quick-reference spec table showing 10 simultaneous connections, 1,800 servers, 80 countries, AES-256-GCM encryption, and 45-day money-back guarantee.
Added policy change monitoring showing recent updates to Hotspot Shield's privacy policy with paragraph-level diffs.
Added transparency tracker noting the absence of a warrant canary, with context on what that means for users.
Expanded privacy section with USA jurisdiction analysis.
Reordered sections to match how readers evaluate a VPN: streaming first, then speed, privacy, features, and pricing.
Improved pros and cons with more specific language grounded in test data and verified claims.
Added curated "Not Right For" section with severity-coded concerns addressing speed and compatibility limitations.
Removed outdated editorial commentary and unverifiable claims from the Hotspot Shield review.
Added platform compatibility breakdown for Hotspot Shield with kill switch support details per operating system.
Added payment methods section for Hotspot Shield covering accepted cards, digital wallets, and cryptocurrency options.
Rewrote protocol comparison covering Hydra, WireGuard, IPsec/IKEv2 with per-platform availability and security ratings.
Added ownership transparency section identifying Point Wild as parent company.
Reorganized review content into clearer sections, moving misplaced blocks and removing layout inconsistencies.
Replaced static overview tables with live data-driven spec cards for Hotspot Shield, ensuring pricing and server counts stay current.
Added product overview including company background, detailed pros/cons list, specifications table covering 17 key features, and expanded sections on streaming compatibility and device support.
Added introductory sentence about Hotspot Shield's patented Aura Hydra protocol and speed benefits.
Removed caption, rewrote introduction for clarity and directness, corrected spacing issues in table formatting, and removed casual language from smart TV section.
Removed casual language and brand name repetition throughout introduction and streaming sections, tightened phrasing for professionalism.
Rewrote introduction for clarity, removed casual phrasing, and corrected grammar throughout opening paragraphs.
Rewrote introduction for clarity, removed casual phrasing, corrected "vpn review" to "VPN review", and tightened multiple paragraphs throughout.
Rewrote introduction for clarity, removing informal phrasing; updated overview table formatting and streaming section content for accuracy.
Added overview table with 15+ key specifications, new sections on streaming compatibility and device support, and expanded feature comparisons throughout the review.
Added image caption, overview table with 17 key specs, and three new sections covering streaming compatibility, smart TV setup, and security features.
Corrected typo "Hot Spot SHield" to "Hotspot Shield" in introduction paragraph.
Removed incomplete and placeholder content including unfinished sections on gaming consoles, streaming devices, and feature explanations that lacked substantive information.
Added review structure with overview table, streaming compatibility details, feature explanations, and multiple device support sections for Hotspot Shield VPN.
Restructured overview section with simplified introduction, updated parent company and jurisdiction details, replaced narrative synopsis table with streamlined specs table, and reorganized feature sections into clearer subsections.
Who Owns Hotspot Shield?
Point Wild
USA
Point Wild Inc.
Also owns Betternet, TouchVPN, Ultra VPN.
Key People
Hari Ravichandran
Founder & CEO
Quick Facts
Founded 2019
Notable Events
Jan 2020
Rebrand
Anchorfree rebranded to Pango Group
Not quite right? Consider these alternatives
Trust No One (Test Yourself)
Run our independent leak test while connected to your VPN and see the results for yourself. We check for IP, DNS, and WebRTC leaks in under 30 seconds. Every test adds to our public dataset.
Join Our Test Panel →Hotspot Shield Alternatives
Considering Hotspot Shield? See how it compares
Based on independent testing data and specifications from each provider.
How we test VPNs
Our testing process involves purchasing each VPN with our own money and installing it on Windows, macOS, and mobile devices. We run a three-stage leak test (IP, DNS, and WebRTC) multiple times across different servers to check for data exposure.
We also test streaming access, kill switch reliability, and split tunneling functionality. All testing is conducted without notifying the provider. Specifications and pricing are verified directly from the provider's website.
Our full testing methodology is published at vpntesting.com/methodology.