PRIVACY POLICY

1. Information We Collect

2. How We Use Information

1. Provide and operate the Service (connectivity, routing, filtering, support).
2. Enforce our Terms and respond to abuse reports and copyright notices.
3. Improve the apps via de-identified or aggregated analytics (feature adoption, error rates, performance).
4. Measure our website advertising, subject to your cookie choices.
5. Security and fraud prevention, and compliance with legal obligations.

Where required by law, we rely on consent for analytics/marketing and respect your choices.

3. "No Activity Logs"

We do not log: the content of your traffic, the sites or apps you connect to, or your DNS queries. Limited connection metadata (Section 1C) is used operationally and deleted within 30 days. App analytics aren't linked to your account, name or email.

4. Sharing & Disclosure

We do not sell your personal information. We share data with:

1. Service providers (hosting, analytics including Google Firebase Analytics in the iOS app, crash reporting, email and support) under confidentiality and data-processing terms;
2. Payment providers (Stripe, Apple, Google, RevenueCat) to process purchases;
3. DNS resolvers: DNS lookups made through the VPN are resolved by a third-party resolver (AdGuard DNS when filtering is on). They reach the resolver from our server's IP address, not yours;
4. Advertising and analytics providers (Google, Microsoft, Meta) on our website, subject to your cookie choices. Some U.S. state laws treat advertising cookies as "sharing"; you can opt out by declining cookies;
5. Legal authorities when required by law or necessary to protect users, the network, or our rights. Where permitted, we will notify you of requests unless legally prohibited.

5. P2P, Torrenting & Copyright Notices

P2P file-sharing and torrenting are allowed for lawful use. We do not fingerprint protocols, inspect traffic, or monitor what you download. Copyright notices we receive usually name one of our server IP addresses, which many users share at the same time; because we keep no activity logs, we generally cannot link such a notice to an individual account, and we do not pass personal data to complainants unless the law requires it.

6. DNS Content Filtering (ClearWeb)

When you turn filtering on, the DNS lookups your device makes through the VPN are resolved by AdGuard DNS, which blocks domains on its lists of ads, trackers, malware and, with the adult-content filter, adult sites. We do not keep per-user DNS logs. Filtering can over- or under-block and can break some sites or apps; you can switch it off in the app.

7. Data Retention

1. Account data: while your account is active. When you delete your account, we delete it, except records we must keep for accounting, tax, fraud prevention, or legal reasons (up to 24 months, or longer where the law requires).
2. Connection metadata: up to 30 days, then deleted, unless we are legally required to preserve specific records.
3. De-identified or aggregated analytics: retained as needed to improve the apps; not reasonably linkable to you.
4. Copyright, abuse, and legal records: as required by law.

8. Your Rights & Choices

Depending on your location, you may have rights to access, correct, delete, port, or object/restrict processing; withdraw consent; and lodge a complaint with a supervisory authority. Contact us to exercise rights; we will honor them where applicable.

9. International Transfers

We are U.S.-based (backend in the U.S.). When transferring personal data internationally (including from the EEA/UK), we use appropriate safeguards (e.g., Standard Contractual Clauses) or other lawful mechanisms.

10. Security

We use technical and organizational measures (encryption in transit, access controls, segmentation, monitoring). No system is perfectly secure; keep devices updated and use strong authentication.

11. Children's Privacy

The Service is not directed to children under 13. If you set up the Service on a device used by a minor, you are responsible for the child's use. If we learn that we collected personal information from a child under 13 without parental consent, we will delete it.

12. Changes

We may update this Policy. We will adjust the "Last Updated" date and, where required, notify you and/or seek consent.

13. Contact