This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from ImpireX.com the Site or you use ImpireX VPN App (the “App”).
Personal information we collect by the App:
We only collect DeviceId by the app if you choose to start the trial account, you can choose to use the app with an existing account, and you can choose to not remember your account, so we do not collect any details.
Also, the device id will transfer to the server encrypted. We do not share the details with third party companies; we only use the device Id to identify and find your subscription, and we do not use it for any other purposes.
The app uses a web view to view ImpireX Shop (the site); you can find it with the Pre-Configured Router and Contact us tabs with the app. By choosing them, you will visit part of our website; please read the below sections (how we collect data by the website) if you use these tabs. You can also choose not to use both accounts, and they are not required and do not affect the app functionalities.
Personal information we collect by the Site:
When you visit our web site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse our website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.
We collect Device Information using the following technologies:
“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
“Log files” track actions occurring on our website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
“Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse our website.
Additionally, when you make a purchase or attempt to purchase through the App, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number. We refer to this information as “Order Information”.
When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.
How do we use your personal information?
We use the Order Information that we generally collect to fulfil any orders placed through the App (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
Communicate with you;
Screen our orders for potential risk or fraud; and
When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our App(for example, by generating analytics about how our customers browse and interact with the App, and to assess the success of our marketing and advertising campaigns).
Sharing your Personal Information
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the App-- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or another lawful request for information we receive, or to protect our rights otherwise.
Behavioural advertising
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt-out of targeted advertising by using the links below:
Facebook: https://www.facebook.com/settings/?tab=ads
Google: https://www.google.com/settings/ads/anonymous
Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/.
Do not track
Please note that we do not alter our App’s data collection and use practices when we see a Do Not Track signal from your browser.
Your rights
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
Additionally, if you are a European resident we note that we are processing your information to fulfil contracts we might have with you (for example if you make an order through the App), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
Data retention
When you place an order through the App, we will maintain your Order Information for our records unless and until you ask us to delete this information.
Changes
We may update this privacy policy from time to time to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.
Contact us
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at support@impirex.com
Social media and AI messaging
Last updated: 12 October 2026
This section explains how we handle your personal data when you interact with ImpireX on Instagram and Facebook, including when our automated AI assistant replies to you. It forms part of our wider privacy policy.
1. Who we are
ImpireX is a trading name of Imperial Tech Limited, a company registered in England and Wales under company number 11553713, with its registered office at 35 Mount Pleasant, Swansea, Wales, SA1 6EQ.
For the activities described in this section, Imperial Tech Limited is the controller of your personal data. This means we decide how and why it is used, and we are responsible for it under UK data protection law (the UK GDPR and the Data Protection Act 2018).
Contact us about privacy: email info@impirex.com, or write to us at the registered office address above, marked "Privacy".
2. Our AI assistant: what to expect
Comments and direct messages (DMs) sent to our Instagram account (@theimpirex) and our Facebook Page may be answered by an automated AI assistant, not a person. We tell you this openly:
- our Instagram bio says replies come from an AI assistant;
- public replies written by the assistant are signed "— ImpireX AI assistant 🤖";
- the first DM in every conversation says you are talking to our automated AI assistant and links to this notice; and
- if you ask whether you are talking to a bot, the assistant will always answer truthfully.
What the assistant does: it answers general questions about our services, sends free guides and checklists, and shares a link to book a call with our team.
What it does not do: it does not give prices, quotes or legal or financial advice, and it does not negotiate or make commitments on our behalf. It does not ask you for your name, email address or phone number. If you choose to book a call, the booking tool collects your details under its own privacy notice. The assistant does not make any decision about you that has a legal effect or a similarly significant effect on you. Every decision about whether, and on what terms, we work with you is made by a person.
When a human gets involved: the assistant passes the conversation to a member of our team when:
- you ask for a person;
- you ask about prices, a complaint, a legal or data-protection matter, or an existing project;
- the conversation involves sensitive information or someone who appears to be under 18; or
- the assistant is not confident it can answer correctly.
A member of our team will normally reply within 1 business day. Our team also regularly reviews the assistant's replies to check their quality and accuracy.
Talk to a human at any time: reply HUMAN in the DM conversation, or email us at the address in section 1. To stop automated messages, reply STOP.
3. What personal data we process
When you interact with our Instagram or Facebook accounts, we may process:
- Profile information made available to us by Meta: your username, profile name, profile picture and account ID;
- Content of your comments and messages, including any text, images, links or other content you send us, and our replies (whether automated or from our team);
- Interaction details: the date and time of your comments and messages, the post or ad you commented on, any keyword you used (for example "APP" or "CALL"), and whether the conversation was passed to a person;
- Preferences you give us: for example, a request to speak to a human, a STOP request or a data-protection request; and
- Any other information you choose to share with us, such as details about your business or project.
Please do not send us sensitive information (for example health information, financial account details or identity numbers) through social media. If you do, the assistant will pass the conversation to our team, and we will use that information only as far as necessary to respond to you and delete it once it is no longer needed.
Our accounts are aimed at businesses and adults. They are not intended for children.
4. Why we use your data and our lawful basis
| Purpose |
Lawful basis (UK GDPR Article 6) |
| Reading and replying to your comments and DMs, including through our AI assistant, sending guides or booking links you ask for, and passing conversations to our team |
Legitimate interests: responding to people who contact us and running our social media accounts efficiently. Where you are asking about using our services, also taking steps at your request before entering into a contract |
| Reviewing and improving the quality, accuracy and safety of the assistant's replies |
Legitimate interests: making sure the information we give is accurate and that automated replies hand over to a person when they should |
| Honouring STOP requests and requests to speak to a human |
Legitimate interests: respecting your preferences (we keep a minimal record so we don't message you again) |
| Handling your data-protection requests and complaints, and keeping records of them |
Legal obligation |
| Moderating our accounts (for example hiding spam, abuse or scams), and establishing, exercising or defending legal claims |
Legitimate interests: keeping our accounts safe and protecting our business |
Where we rely on legitimate interests, we have weighed our interests against your rights and expectations. You have the right to object (see section 8).
No marketing without your consent. We will not add you to a mailing list or send you promotional messages because you commented on a post or messaged us. A DM conversation is used only to deal with your request.
5. Meta (Instagram and Facebook)
Instagram and Facebook are provided by Meta Platforms Ireland Limited (Block J, Serpentine Avenue, Dublin 4, Ireland). Meta is not our service provider. It processes your personal data as an independent controller, for its own purposes and under its own privacy policies:
Page Insights. When you interact with our Facebook Page and our Instagram professional account, Meta creates statistics (known as "Insights") that it gives to us in aggregated form. Meta's terms say that we and Meta Platforms Ireland Limited are joint controllers for the processing of personal data used to create these Insights. Meta has agreed to take primary responsibility for that processing, including responding to your rights requests about it. You can read the essential terms in Meta's Page Insights Controller Addendum: https://www.facebook.com/legal/terms/page_controller_addendum. We only receive aggregated statistics, which do not identify you.
6. Who else receives your data
- Our AI messaging platform. Our AI assistant runs on messaging software developed and operated by Imperial Tech Limited, connected to Instagram and Facebook through Meta's official tools. It is hosted for us by Make.com.
- AI model provider. To generate replies, the content of your message and the conversation history are sent to OpenAI, which acts as our processor. This means it may use the data only on our instructions and under a written contract with appropriate confidentiality and security obligations.
- Booking tool. If you choose to book a call, you will use Calendly, which collects your booking details under its own privacy notice.
- Others, where necessary. Our professional advisers, or regulators, courts and law enforcement where we are legally required to share data or need to do so to protect our rights.
We do not sell your personal data.
7. International transfers
Some of the organisations listed above (including Meta and OpenAI) may process your personal data outside the UK, for example in the European Economic Area or the United States. Where your data is transferred outside the UK, we make sure it is protected by an appropriate safeguard, such as:
- UK "adequacy" regulations (for example, for the EEA, or for US organisations certified under the UK Extension to the EU-US Data Privacy Framework); or
- the UK International Data Transfer Agreement (IDTA), or the UK Addendum to the EU Standard Contractual Clauses.
Contact us if you would like more information about the safeguard that applies.
8. How long we keep your data
We keep DM conversations, and the related records in our AI messaging platform, for 12 months after the last message in the conversation. After that, we delete them or anonymise them so they no longer identify you. The exceptions are:
- if a conversation becomes an enquiry or a project with us, we keep the relevant details for as long as our main privacy policy sets out for customer and prospect records;
- records of data-protection requests and complaints are kept for 6 years; and
- a minimal record of a STOP request (your username and the date) is kept for as long as we run the account, so we can respect it.
Public comments stay on Instagram or Facebook until you delete them, or until we hide or remove them. Messages also stay in your own Instagram or Facebook inbox, which Meta controls. You can delete them using Meta's tools.
9. Your rights
Under UK data protection law, you have the right to:
- access the personal data we hold about you;
- have inaccurate data corrected (rectification);
- have your data deleted (erasure);
- restrict how we use your data;
- object to processing based on legitimate interests, including any use for direct marketing; and
- data portability, where it applies (it generally applies only to data processed on the basis of consent or a contract and by automated means).
You also have the right not to be subject to solely automated decisions with legal or similarly significant effects. As explained in section 2, our AI assistant does not make decisions of this kind.
How to make a request, including deleting your data: email info@impirex.com, or send a DM saying, for example, "delete my data". Our assistant will log the request and pass it to our team. We will delete your data from our own systems, including our AI messaging platform and our records held with our processors, and confirm this to you. We will respond within one month. In some cases the law allows us to extend this by up to two further months, in which case we will tell you why. We may need to check your identity before acting on a request (for example, by confirming it comes from the same account). Deleting data held by us does not delete data held by Meta: for that, please use your Instagram or Facebook settings or contact Meta.
10. Complaints
If you are unhappy with how we have handled your personal data, please contact us first at info@impirex.com. We will acknowledge your complaint within 30 days and respond without undue delay.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection regulator:
11. Changes to this section
We may update this section, for example if we change how our AI assistant works or which providers we use. We will change the "Last updated" date above whenever we do.
Social media and AI messaging
Last updated: 12 October 2026
This section explains how we handle your personal data when you interact with ImpireX on Instagram and Facebook, including when our automated AI assistant replies to you. It forms part of our wider privacy policy.
1. Who we are
ImpireX is a trading name of Imperial Tech Limited, a company registered in England and Wales under company number 11553713, with its registered office at 35 Mount Pleasant, Swansea, Wales, SA1 6EQ.
For the activities described in this section, Imperial Tech Limited is the controller of your personal data. This means we decide how and why it is used, and we are responsible for it under UK data protection law (the UK GDPR and the Data Protection Act 2018).
Contact us about privacy: email info@impirex.com, or write to us at the registered office address above, marked "Privacy".
2. Our AI assistant: what to expect
Comments and direct messages (DMs) sent to our Instagram account (@theimpirex) and our Facebook Page may be answered by an automated AI assistant, not a person. We tell you this openly:
What the assistant does: it answers general questions about our services, sends free guides and checklists, and shares a link to book a call with our team.
What it does not do: it does not give prices, quotes or legal or financial advice, and it does not negotiate or make commitments on our behalf. It does not ask you for your name, email address or phone number. If you choose to book a call, the booking tool collects your details under its own privacy notice. The assistant does not make any decision about you that has a legal effect or a similarly significant effect on you. Every decision about whether, and on what terms, we work with you is made by a person.
When a human gets involved: the assistant passes the conversation to a member of our team when:
A member of our team will normally reply within 1 business day. Our team also regularly reviews the assistant's replies to check their quality and accuracy.
Talk to a human at any time: reply HUMAN in the DM conversation, or email us at the address in section 1. To stop automated messages, reply STOP.
3. What personal data we process
When you interact with our Instagram or Facebook accounts, we may process:
Please do not send us sensitive information (for example health information, financial account details or identity numbers) through social media. If you do, the assistant will pass the conversation to our team, and we will use that information only as far as necessary to respond to you and delete it once it is no longer needed.
Our accounts are aimed at businesses and adults. They are not intended for children.
4. Why we use your data and our lawful basis
Where we rely on legitimate interests, we have weighed our interests against your rights and expectations. You have the right to object (see section 8).
No marketing without your consent. We will not add you to a mailing list or send you promotional messages because you commented on a post or messaged us. A DM conversation is used only to deal with your request.
5. Meta (Instagram and Facebook)
Instagram and Facebook are provided by Meta Platforms Ireland Limited (Block J, Serpentine Avenue, Dublin 4, Ireland). Meta is not our service provider. It processes your personal data as an independent controller, for its own purposes and under its own privacy policies:
Page Insights. When you interact with our Facebook Page and our Instagram professional account, Meta creates statistics (known as "Insights") that it gives to us in aggregated form. Meta's terms say that we and Meta Platforms Ireland Limited are joint controllers for the processing of personal data used to create these Insights. Meta has agreed to take primary responsibility for that processing, including responding to your rights requests about it. You can read the essential terms in Meta's Page Insights Controller Addendum: https://www.facebook.com/legal/terms/page_controller_addendum. We only receive aggregated statistics, which do not identify you.
6. Who else receives your data
We do not sell your personal data.
7. International transfers
Some of the organisations listed above (including Meta and OpenAI) may process your personal data outside the UK, for example in the European Economic Area or the United States. Where your data is transferred outside the UK, we make sure it is protected by an appropriate safeguard, such as:
Contact us if you would like more information about the safeguard that applies.
8. How long we keep your data
We keep DM conversations, and the related records in our AI messaging platform, for 12 months after the last message in the conversation. After that, we delete them or anonymise them so they no longer identify you. The exceptions are:
Public comments stay on Instagram or Facebook until you delete them, or until we hide or remove them. Messages also stay in your own Instagram or Facebook inbox, which Meta controls. You can delete them using Meta's tools.
9. Your rights
Under UK data protection law, you have the right to:
You also have the right not to be subject to solely automated decisions with legal or similarly significant effects. As explained in section 2, our AI assistant does not make decisions of this kind.
How to make a request, including deleting your data: email info@impirex.com, or send a DM saying, for example, "delete my data". Our assistant will log the request and pass it to our team. We will delete your data from our own systems, including our AI messaging platform and our records held with our processors, and confirm this to you. We will respond within one month. In some cases the law allows us to extend this by up to two further months, in which case we will tell you why. We may need to check your identity before acting on a request (for example, by confirming it comes from the same account). Deleting data held by us does not delete data held by Meta: for that, please use your Instagram or Facebook settings or contact Meta.
10. Complaints
If you are unhappy with how we have handled your personal data, please contact us first at info@impirex.com. We will acknowledge your complaint within 30 days and respond without undue delay.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection regulator:
11. Changes to this section
We may update this section, for example if we change how our AI assistant works or which providers we use. We will change the "Last updated" date above whenever we do.