Pango Data Privacy Framework Privacy Policy

Intersections, LLC d/b/a Pango Group and its U.S. affiliated entities and subsidiaries, Anchorfree LLC, Betternet LLC, Total Security US LLC, TouchVPN LLC, and VPN Proxy Pro, LLC (collectively referred to as, “Pango”) adhere to the Data Privacy Framework Principles (“DPF Principles”) regarding the collection, use, and retention of personal data that is transferred from the European Union, United Kingdom, and Switzerland to the U.S. If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles shall govern. Additionally, Pango may protect your data through other legally valid methods, including international data transfer agreements.

Pango has self-certified its commitment to 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”) and to the rights of EU and UK individuals and Swiss individuals. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. DPF Principles with regards 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. We have also certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. DPF Principles with regards to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. Under the Data Privacy Framework (“DPF”), Pango may disclose your personal data covered by the DPF for the purposes described in our general Pango Privacy Policy and the applicable service specific privacy policies. Under the Data Privacy Framework, you may inquire as to whether Pango is processing personal data about you, request access to personal data, and ask that we correct, amend, or delete your personal data where it is inaccurate or has been processed in violation of the DPF Principles using the contact details provided below.

Pango is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf. As required under the DPF Principles, when we receive personal data under the Data Privacy Framework and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Data Privacy Framework if the agent processes the data in a manner inconsistent with the Data Privacy Framework and we are responsible for the event giving rise to the damage. For more information about how we may disclose your personal data and your choices for limiting the disclosure and use of your personal data, please see our general Pango Privacy Policy or the applicable Pango product privacy policies available on our Pango websites. Please note that we may be required to disclose your personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

To learn more about the Data Privacy Framework program, please visit the Data Privacy Framework website. To view our DPF certifications, please visit this page and search for “Pango”.

We encourage you to contact us as provided below should you have a Data Privacy Framework related concern or complaint.  If you have an unresolved privacy or data use complaint that we have not addressed satisfactorily, you may contact the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR-AAA) to seek resolution, free of charge, by calling 888-855-9575 or visiting https://go.adr.org/dpf_irm.html. You may also contact your local data protection authority within the European Economic Area, U.K., or Switzerland (as applicable) for unresolved complaints.    

Under certain conditions, more fully described in the Pre-Arbitration Requirements of Annex I of the DPF Principles on the Data Privacy Framework website, including when other dispute resolution procedures have been exhausted, you may invoke binding arbitration regarding DPF compliance not resolved by any of the other DPF mechanisms.  

Pango is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Contact Us:

If you have any questions about these terms, please contact us at privacy@pango.co or contact us at:

Customer Service
250 Northern Ave, Floor 3
Boston, Massachusetts, 02210