Privacy Policy
Effective date: October 3, 2026 · Controller: [TBD] · Contact: [TBD]
[TBD] (the "Service") does not require an email-and-password account, but operating a VPN still requires processing limited device, connection, transaction and support data. This policy explains honestly what we process, why, for how long, and what rights you have. We do not use absolute claims such as "completely anonymous" or "no data at all".
1. Scope and Controller
This policy applies to the Service's app, VPN connections, subscriptions, in-app feedback and related services. [TBD] ("we", "us") is responsible for the processing described here. Address: [TBD].
2. Key Points
- You do not need to provide a name, email, phone number or password to use the Service.
- The app generates a device identifier; our servers use it to issue a device credential, provide access, link entitlements and prevent the free allowance from being claimed repeatedly.
- To provide and protect the Service, we process limited operational data such as the IP address at registration, usage times and traffic byte counts.
- We do not log or store the content of what you access through the VPN, do not profile you based on traffic content, and do not sell your data to anyone.
- The app does not include third-party advertising or behavioral analytics SDKs.
"No account" is not the same as anonymous. Network carriers, app stores and the websites you visit may process your data under their own policies.
3. Data We Process
| Category | Details | Purpose |
|---|---|---|
| Device and credential | App-generated device identifier, platform (iOS / Android), basic information such as device model and OS version, a hash of the device credential, first and last seen times | Identify the device, provide access, enforce plan limits, prevent abuse |
| Network and connection | IP address at first registration; source IP, connection times and upload/download byte counts processed by VPN nodes while you use the VPN | Establish connections, meter data usage per plan, maintain capacity and security |
| Repeat-claim prevention | Platform device-check results (Apple DeviceCheck / Google Play Integrity); a one-way hash of the device identifier kept after account deletion | Ensure the free allowance is claimed only once per device |
| Purchases and entitlements | Plan, subscription status, expiry time, app store transaction identifiers and receipt data | Grant and restore paid entitlements, handle renewals and refunds |
| Feedback | Text and screenshots you submit, optional contact details, app and OS version | Respond to you, troubleshoot, improve the Service |
| Server logs | Request time, path, IP address, error information | Troubleshoot and defend against attacks |
We do not process your name, phone number, contacts, precise location, browsing history or the content you transmit through the VPN. Full payment card details are handled by the app store and are never available to us.
Screenshots: screenshots you upload are stripped of EXIF and other metadata (including any embedded location and device information) on our servers before being stored. Please avoid including passwords, verification codes or card numbers in screenshots.
4. Purposes and Legal Bases
- Contract: providing VPN connections, the free allowance, paid subscriptions, purchase restoration and the support you request.
- Legitimate interests: preventing fraud and abuse (including repeated free-allowance claims), securing the Service, troubleshooting and capacity planning, balanced against your rights.
- Legal obligations: tax, accounting, consumer protection and other legal requirements.
- Consent: where the law requires consent for other processing, we will ask for it first.
5. Sharing
We share data only as necessary with:
- providers of server hosting, network and infrastructure services to us;
- Apple and Google, for device checks (repeat-claim prevention) and for subscription purchases, renewals and refunds;
- authorities when we receive a valid legal request, or where necessary to protect the safety of users, us or the public;
- a successor in a merger, acquisition or reorganization, provided it continues to follow this policy or equivalent protections.
We do not sell personal data or share it for advertising.
6. Retention
| Data | Retention |
|---|---|
| Device, credential and connection data | Kept while you use the Service; deleted when you delete your account |
| Traffic counters | Kept while you use the Service for per-period metering; deleted with your account |
| Repeat-claim one-way hash | Kept after account deletion. It cannot be reversed into the device identifier and is used only to tell whether the device has claimed the free allowance |
| Feedback and screenshots | Kept while you use the Service; deleted when you delete your account |
| Purchase and transaction records | Kept as long as needed for entitlement restoration, accounting, tax and legal requirements |
| Server logs | Used for troubleshooting, rotated regularly, not kept long term |
| Database backups | Rolling retention of about 14 days, then deleted automatically |
7. Deleting Your Account
You can use "Delete Account" in the app. After deletion:
- we delete your device record, device credential, VPN account, traffic records and feedback (including screenshots);
- we keep an irreversible hash of the device identifier to prevent the same device from claiming the free allowance again;
- deleted data may remain in database backups for up to about 14 days, after which it is removed as backups expire;
- deleting your account does not cancel your app store subscription; please cancel it in the app store.
8. International Processing
Our servers and VPN nodes may be located outside your country or region, so your data may be processed abroad, where data protection laws may differ. We protect such data with measures including access controls and data minimization.
9. Your Rights
Depending on where you live, you may have the right to access, correct or delete your data, obtain a copy, restrict or object to certain processing, withdraw consent, and complain to a data protection authority.
Because we do not collect identity information such as email, we may ask for device information shown in the app, a feedback number or an order number to verify that records relate to you. We will not ask for more than is necessary. Contact us at [TBD] or through "Feedback" in the app.
10. Children
The Service is not directed to children under 13 (or a higher age where local law requires). If you believe a child has provided us data without a guardian's consent, contact us and we will verify and delete it.
11. Security
We protect data with measures including encryption in transit, storing credentials only as hashes, access controls, operation audit logs and data minimization. No system can guarantee absolute security; please keep your device safe.
12. Changes
We may update this policy for product, legal or security reasons, and will update the version number and effective date on this page. We will notify you of material changes, for example by an in-app notice. If the Chinese and English versions conflict, the Chinese version prevails to the extent permitted by law.
13. Contact
For privacy questions, complaints or requests, email [TBD] or use "Feedback" in the app.
[TBD] [TBD]