Privacy Policy

Varayo Inc (“we,” “us,” or “our”) operates as an Internet Service Provider (ISP) and content service provider, delivering broadband internet access, content delivery, and related services. We also process online payments, including credit card transactions, for our services.

We are committed to protecting your privacy and handling your personal information responsibly. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services, visit our website, or interact with us.

Please read this policy carefully. By using our services, you agree to the practices described here. If you do not agree, please do not use our services.

We collect information in the following ways:

Information You Provide Directly:

• Account and billing information: Name, address, email, phone number, payment details (e.g., credit card information for online payments).
• Service registration details: Username, password, and preferences.
• Communications: Information from emails, support tickets, or surveys.

Information Collected Automatically as an ISP:

• Network usage data: IP addresses, device identifiers, traffic volume, connection times, and performance metrics.
• Browsing and content access data: We may log domain names, websites visited, or content accessed through our network (but we do not inspect encrypted traffic content).
• Location data: Approximate location based on IP address or service address.

Information from Content Services:

• Usage of streamed or hosted content: Viewing history, preferences, and interactions (if applicable to our content offerings).

Payment Information:

• Credit card details are processed through compliant third-party payment processors. We do not store full credit card numbers on our systems; we use tokenization where possible to comply with PCI DSS standards.

Cookies and Tracking Technologies:

• On our website: Cookies, web beacons, and similar technologies to improve user experience, analyze usage, and deliver targeted content.

We do not knowingly collect personal information from children under 13 without parental consent, in compliance with COPPA where applicable.

We use your information to:

• Provide and maintain services: Deliver internet access, content, billing, and customer support.
• Process payments: Securely handle transactions and prevent fraud.
• Improve services: Analyze network performance, troubleshoot issues, and enhance content offerings.
• Communicate: Send service updates, bills, promotions (with opt-out options), and respond to inquiries.
• Comply with laws: Respond to legal requests, enforce terms, or protect rights.
• Security and network management: Detect abuse, manage congestion, and ensure service integrity (reasonable network management practices only).

We do not sell your personal information or browsing history to third parties for marketing purposes without your explicit consent.

We may share information with:

• Service Providers: Third-party vendors for hosting, payment processing (PCI DSS-compliant), analytics, and customer support. They are contractually obligated to protect your data.
• Affiliates: Related companies for operational purposes.
• Legal Requirements: Law enforcement, regulators, or courts if required (e.g., under CALEA for lawful intercepts).
• Business Transfers: In mergers, acquisitions, or asset sales.
• With Consent: For any other purpose with your permission.

As an ISP, we may disclose aggregated, anonymized data for industry reports or performance benchmarking.

Data Security

We implement reasonable security measures, including encryption, firewalls, access controls, and compliance with PCI DSS for payment data. However, no system is 100% secure, and we cannot guarantee absolute protection.

In case of a data breach affecting your information, we will notify you and relevant authorities as required by law.

Data Retention

We retain information as long as needed for services, billing, legal compliance, or dispute resolution. Network logs are retained for reasonable periods for security and performance.

• Opt-Out: Unsubscribe from marketing emails via links provided.
• Access and Correction: Request access to or correction of your personal information by contacting us.
• Deletion: Request deletion of certain data, subject to legal retention requirements.
• State-Specific Rights: If you are a resident of California (CCPA/CPRA) or other states with privacy laws, you may have additional rights like opting out of sales or limiting sensitive data use.

For ISP-related disclosures (per FCC transparency rules), we do not engage in paid prioritization, blocking lawful content, or throttling without disclosure.

International Transfers

If you are outside the U.S., your data may be transferred to and processed in the U.S., where privacy laws may differ.

Changes to This Policy

We may update this policy periodically. Significant changes will be notified via email or website notice. Continued use of services constitutes acceptance.

For questions, requests, or concerns regarding this policy:

Varayo Privacy Team

c/o Varayo Inc.
530 W 6th St Ste 301
Los Angeles, CA 90014

Email: privacy@varayo.com

Phone: 213-212-9100