Last Updated: October 16, 2026

1. Who We AreThis Privacy Policy explains how personal data is processed in connection with the SHOKO VPN application, related VPN services, subscriptions, customer support, and SHOKO VPN pages on shokosim.com (collectively, the “Service”).

For subscription management, customer relationships, website operations and the other activities described in this Policy, the relevant service provider and data controller is:
ISIM GLOBAL Sp. z o.o.
ul. Wolbromska 18/1B
53-148 Wrocław, Poland
KRS: 0000972227
NIP: 8992925738
REGON: 522058030
Email: info@isim.net.ua

The SHOKO VPN software application is owned by ISIM UKRAINE LLC (ТОВ «АЙСІМ ЮКРЕЙН»), Ukraine.

Technical infrastructure used to provide VPN connectivity may be supplied by third-party technology providers, including KeepSolid. Depending on the processing activity and applicable contractual arrangements, third-party providers may act as processors, independent controllers or other recipients of personal data as provided by applicable law.

2. Scope of This PolicyThis Policy applies to personal data processed when you use the SHOKO VPN application, create or manage an account, purchase or manage a subscription, contact customer support, or visit SHOKO VPN pages on shokosim.com.

Third-party websites, stores, payment services and platforms have their own privacy practices. Their processing is governed by their respective privacy policies where they act independently from us.

3. Personal Data We May ProcessDepending on how you use the Service, we may process:

• Account data, such as your email address, account identifier and authentication-related information.

• Subscription and transaction data, such as your subscription plan, subscription status, trial status, purchase and renewal dates, transaction identifiers and payment status.

• Device and application data, such as device type, operating system, application version, language, device or application identifiers, crash information and diagnostic data.

• Network and connection data that is technically necessary to establish, secure and maintain a VPN connection.

• Support and communications data, including information you provide when contacting us.

• Website usage data, which may include IP address, browser and device information, pages visited, referring page, interactions with the website, cookie or similar identifiers, and information relating to analytics or advertising events, where permitted by applicable law and your consent choices.

We do not normally receive your complete payment-card details when payment is processed by Apple, Google or another independent payment provider.

4. VPN Traffic and PrivacySHOKO VPN is designed to provide private VPN connectivity.
We do not intend to monitor, sell or maintain a history of the content of your internet activity for advertising purposes.
Providing a VPN service necessarily requires certain network information to be processed while a connection is being established or maintained. The precise technical data processed may depend on the VPN protocol, server infrastructure, security requirements and technology provider used for the connection.
We do not sell users’ browsing history.
Third-party VPN infrastructure providers may process limited technical information necessary to provide, secure and maintain the VPN functionality in accordance with their contractual role and applicable law.

5. Purposes and Legal BasesWe may process personal data for the following purposes:
• To provide the application, VPN connectivity and requested Service — where processing is necessary to perform our contract with you.

• To create and maintain accounts, manage subscriptions and trials, verify transactions and provide customer support — where necessary to perform our contract with you.

• To comply with accounting, tax, consumer-protection, regulatory and other legal requirements — where processing is necessary to comply with a legal obligation.

• To protect the Service, prevent fraud and abuse, diagnose failures and maintain security — based on our legitimate interests where those interests are not overridden by your rights and freedoms.

• To measure website usage and performance through non-essential analytics technologies — based on consent where consent is required.

• To conduct advertising measurement, remarketing or personalized advertising through advertising technologies — based on consent where consent is required.

Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Website Cookies, Analytics and Advertising TechnologiesSHOKO VPN pages on shokosim.com may use cookies, pixels, tags, local storage or similar technologies.
Strictly necessary technologies may be used where required to provide website functionality, security, fraud prevention or to remember privacy choices.
Subject to your consent where required, we may use analytics technologies to understand how visitors use the website and to measure website performance.
The website currently uses Google Tag Manager to manage website tags. Depending on the tags configured through Google Tag Manager and your consent choices, information about website visits and interactions may be transmitted to Google services.
The website may also use Meta/Facebook technologies, including the Meta Pixel or related Meta Business Tools, for advertising measurement, campaign attribution, audience measurement or remarketing, subject to consent where required. These technologies may allow Meta to receive information about your browser or device and your interactions with our website.
Non-essential analytics and advertising technologies should be activated in accordance with the consent choices presented to you. Where available, you can change or withdraw your choices through the website’s cookie/privacy settings.
Declining non-essential cookies or similar technologies should not prevent access to the core SHOKO VPN Service.

7. Google and MetaGoogle and Meta may process data they receive through their technologies under their own terms and privacy policies where they act as independent controllers.
Information transmitted through these technologies may include online identifiers, IP address, browser/device information, page or event information and consent signals, depending on configuration.
We do not use this Policy to claim that every Google or Meta service is active at all times. The specific technologies used may change as our website and marketing activities develop. Non-essential technologies are subject to applicable consent requirements.

8. VPN and Other Technology ProvidersWe may engage third-party providers necessary to operate SHOKO VPN, including providers of VPN and network infrastructure, hosting and cloud services, application distribution, security, diagnostics and customer support.
KeepSolid may provide technology or infrastructure involved in delivering VPN functionality.
Such providers may receive or process only the information reasonably necessary for their role, subject to applicable contractual and legal requirements.

9. Payments, App Store and Google PlaySubscriptions may be purchased through Apple App Store, Google Play or other authorized payment channels.
When a third party processes payment, that provider may independently process payment and transaction information under its own privacy policy. We generally receive information necessary to confirm the purchase or subscription status rather than complete payment-card credentials.
Apple and Google may also process information relating to application distribution, purchases, subscriptions, devices and store usage according to their respective terms and privacy policies.

10. Data SharingWe may disclose personal data to service providers and other recipients where reasonably necessary to operate the Service, process subscriptions, provide customer support, maintain security, comply with law or exercise or defend legal rights.
We may also disclose information where required by a valid legal obligation, court order or lawful request from a competent authority.
We do not sell users’ VPN browsing history.

11. International Data TransfersSHOKO VPN is a global internet service, and some providers may process data outside Poland or the European Economic Area.
Where the GDPR requires safeguards for transfers of personal data to countries that do not benefit from an adequacy decision, we use an appropriate transfer mechanism where required, such as applicable standard contractual clauses or another legally recognized safeguard.

12. Data RetentionWe retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including providing the Service, maintaining security, resolving disputes and meeting legal, accounting and tax requirements.
Retention periods may differ depending on the type of information and the legal or operational purpose for which it is processed.
We do not intentionally retain VPN traffic content as a history of users’ browsing activity for advertising purposes.
Analytics and advertising providers may apply their own retention periods to data processed by them in accordance with their respective policies and our configured settings.

13. Your GDPR and Privacy RightsWhere the GDPR applies, you may have the right to:
• request access to personal data concerning you;
• request correction of inaccurate personal data;
• request deletion of personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive certain personal data in a portable format;
• withdraw consent at any time where processing is based on consent; and
• lodge a complaint with a competent data protection supervisory authority.

You may submit a privacy request to info@isim.net.ua.
We may need to verify your identity before fulfilling certain requests. Rights may be subject to exceptions and limitations provided by applicable law.

14. Account DeletionIf SHOKO VPN provides user accounts, users may request deletion of their account and associated personal data by contacting info@isim.net.ua or through another account-deletion method made available in the application or on the website.
Following a valid deletion request, we will delete or anonymize personal data associated with the account unless retention is required or permitted by applicable law, for example for accounting, tax, fraud-prevention, dispute-resolution or legal-compliance purposes.
Deletion of a SHOKO VPN account does not necessarily cancel a subscription billed independently by Apple, Google or another payment provider. Users should also cancel recurring billing through the relevant purchase channel where applicable.

15. SecurityWe use reasonable technical and organizational measures designed to protect personal data against unauthorized access, alteration, loss, misuse or disclosure.
No internet-based system or VPN service can guarantee absolute security.

16. ChildrenSHOKO VPN is not intended to knowingly collect personal data from children in violation of applicable law.
Where consent is relied upon for processing personal data of a child, any parental-consent requirements imposed by applicable law will apply.

17. Changes to This Privacy PolicyWe may update this Privacy Policy to reflect changes to the Service, technologies we use, legal requirements or our business operations.
The current version will display its “Last Updated” date. Where required by applicable law, we will provide appropriate notice of material changes.

18. ContactFor questions, requests or complaints concerning privacy or personal data, contact:
ISIM GLOBAL Sp. z o.o.
ul. Wolbromska 18/1B
53-148 Wrocław, Poland
KRS: 0000972227
NIP: 8992925738
REGON: 522058030

Email: info@isim.net.ua