Privacy Statement

1. Introduction

This Privacy Statement (the "Statement") describes what data the UnderVPN Service collects in the course of its operation, the purposes for which it is used, with whom it is shared, and how it is protected.

This Statement is informational. Its purpose is to provide transparency about how the Service operates and to help Users make an informed decision about using the Service.

1.1. Service principles

The Service follows two core principles:

• Minimisation: the Service seeks to limit the scope of data it collects and stores to what is necessary for the operation of the Service and the purposes listed in Section 4
• Purpose limitation: the data collected is used for the purposes described in Section 4 of this Statement

1.2. Payment data

Funds are collected from Users through third-party payment services engaged by UnderVPN to process payments under separate agreements. Full bank card details and other confidential payment instrument information are not transmitted to UnderVPN and are not stored in its systems.

The list of currently available payment services is shown to the User at the moment of payment.

Use of the Service indicates an understanding of the practices described in this Statement.

2. Data collected by the Service

2.1. Identification data

When registering with the Service, the following data is collected depending on the chosen channel:

• Via the Telegram bot @gutvpn_bot: Telegram ID, username (if set by the User), first/last name (as specified in the Telegram profile)
• Via the my.undervpn.org website with email registration: email address, fact of address confirmation
• Via the my.undervpn.org website using a third-party authentication provider: the User's identifier with the relevant provider, email address, profile name (to the extent transmitted to the Service by the relevant provider)

When the User configures additional authentication methods in the Dashboard (see Terms of Service Section 3.1.1), such as Passkey / Face ID (the WebAuthn standard), the Service stores the technical data necessary for subsequent authentication: the public cryptographic key of the User's device and the WebAuthn credential identifier. Biometric data itself (fingerprint, face) is not transmitted to the Service — biometrics are used by the User's device locally to unlock cryptographic keys.

Where the User has multiple accounts linked via the "Account linking" section of the Dashboard (see Terms of Service Section 3.2), the identification data of all linked accounts is treated as relating to a single User account for the purposes of this Statement.

This data is used for:

• Identifying the User
• Communicating with the User (notifications, support)
• Managing the Subscription

2.2. Payment data

Funds are collected from Users through third-party payment services. Full bank card details and other confidential payment instrument information are not transmitted to UnderVPN and are not stored in its systems.

From engaged payment services the Service receives:

• The fact of a successful or unsuccessful payment
• The payment transaction identifier (necessary to enable refunds)
• The type of payment method used (without disclosure of specific payment details)

For the Subscription auto-renewal feature, engaged payment services issue a technical token — a binding that does not contain payment instrument details in plain form. Use of the token allows repeat charges to be initiated exclusively through the payment service without transferring full payment details to UnderVPN.

2.3. Technical usage data

To ensure the operation of the Service, the following is collected:

• Volume of traffic transferred under the Subscription (for metering and limit enforcement) — without content
• Number of concurrent connections (for tariff limit enforcement)
• Date of last connection (for account activity monitoring)
• Device identifier (HWID), if this feature is enabled in the tariff — to enforce the number of permitted devices

2.4. Diagnostic data (on request)

When contacting support, the User may provide:

• Application logs for diagnostics (at the User's own initiative)
• A description of the issue

This data is used solely to resolve the support request and is deleted once the request is closed.

2.5. Web analytics data

A third-party web analytics system is used in the Dashboard at my.undervpn.org for the purpose of analysing use of the Service. No third-party web analytics systems are connected on the informational website undervpn.org.

The web analytics system in the Dashboard may collect:

• Anonymised information about pages visited in the Dashboard
• Technical parameters of the User's device (browser type, operating system, screen resolution)
• The source of arrival at the Dashboard (referrer URL)
• User actions within the interface (clicks, transitions, navigation)
• Recordings of User actions on the page (Session Replay), excluding input into fields of type "password" and fields technically marked as confidential
• Subscription purchase data transmitted via the e-commerce mechanism

Instructions for opting out of data collection are set out in the Cookie Notice Section 3.2.

3. Principles of data handling

The Service follows the principles of minimisation and purpose limitation:

3.1. Collection minimisation

The Service seeks to limit the scope of collected data to what is necessary for:

• Identifying the User and managing their Subscription
• Ensuring operability, diagnostics and security of the infrastructure
• Analysing use of the Service and improving the user experience (see Section 2.5)
• Complying with applicable requirements when working with payment services

The composition of collected data is described in Section 2 of this Statement.

3.2. Purpose limitation

Collected data is used for the purposes listed in Section 4. The Service does not:

• Analyse the content of User traffic passing through the Service infrastructure
• Sell User data to third parties
• Transfer User data to advertising networks, marketing partners or data brokers
• Use User data for targeted advertising purposes

3.3. Technical caveats

To ensure the operation of the Service, the infrastructure inevitably processes the User's network traffic at the moment of its transmission. This is a technical necessity of routing without which the Service cannot operate.

Information that may be recorded by the infrastructure for technical or operational reasons (diagnostic events, connection statistics, security events) is stored for the periods specified in Section 7 and is not used beyond the purposes listed in Section 4.

3.4. Requests from third parties

Upon receipt of a lawful and binding request from competent authorities, the Service may provide only such data as it actually holds (see Section 5.5). The scope of stored data is described in Section 2 and is limited by the principles of minimisation set out above.

4. Purposes of data processing

Collected data is used solely for:

Purpose	Data used
Providing access to the Service	Identification, technical
Managing the Subscription	Identification, payment (from engaged payment services)
Communicating with the User (notifications, support)	Identification, contact
Processing payments	Payment (via engaged payment services)
Analysing use of the Service and improving the user experience	Web analytics data (see Section 2.5)
Protecting the Service from abuse	Technical (usage patterns)
Compliance with applicable law	All categories — upon lawful requests

The Service does not use User data for marketing communications without explicit separate consent.

5. Transfer of data to third parties

The Service transfers data to third parties only in the following cases:

5.1. Payment services

• Data: User identifier, payment amount, tariff information, transaction identifier
• Purpose: payment processing, generation of primary accounting documents
• Basis: User consent through acceptance of the Terms of Service
• Payment service policies: posted directly on the websites of the engaged payment services; the list of currently available payment services is shown to the User at the moment of payment

5.2. Web analytics providers (Dashboard only)

• Recipient: a third-party organisation — web analytics provider engaged by the Service
• Scope: the Dashboard at my.undervpn.org. No third-party web analytics providers are used on the informational website undervpn.org
• Data: anonymised information about Dashboard page visits, technical device parameters, traffic source, User actions in the interface, page action recordings (Session Replay), Subscription purchase data via the e-commerce mechanism (see Section 2.5)
• Purpose: analysis of Service usage, improvement of the user experience, evaluation of Service performance
• Basis: User consent, expressed by continued use of the Service after reviewing the Cookie Notice
• Processing terms: data is processed by the engaged web analytics provider in accordance with its terms of use and privacy policy
• Opt-out option: the User has the right to opt out of web analytics data collection through browser settings (see Section 3.2 of the Cookie Notice)

The Service does not transfer web analytics data to advertising systems and does not use web analytics data for targeted advertising purposes.

5.3. Communication platforms

• Recipient: Telegram Messenger Inc. (the Telegram platform)
• Scope: User's use of the Telegram bot @gutvpn_bot as a channel of interaction with the Service
• Data: contents of messages and commands sent by the User to the Telegram bot; technical interaction metadata (User Telegram ID, time and fact of interaction with the bot); the Service's responses sent to the User via the Telegram bot
• Purpose: ensuring the operation of the Telegram bot as a channel of interaction between the User and the Service, delivery of notifications, processing of Subscription management commands
• Basis: the User's use of the Telegram bot under separate User consent to the Telegram terms of use (including the Telegram Bot Terms), which the User accepts upon registration in Telegram and upon first interaction with the Telegram bot
• Telegram processing terms: data processing by the Telegram platform is governed by the terms of use and privacy policy of Telegram Messenger Inc. published at telegram.org
• Alternative channels: if the User does not wish to use the Telegram bot, alternative channels of interaction with the Service are available — the Dashboard at my.undervpn.org and email (see Terms of Service Section 14)

5.4. Infrastructure providers

• Data: technical connection data (IP address for routing, not stored)
• Purpose: provision of computing resources for the operation of the Service's servers
• Basis: technical necessity for the provision of the service

5.5. Law enforcement authorities

• The Service considers only binding requests submitted in compliance with applicable procedural rules
• The Service reserves the right to challenge requests that do not comply with the law, are submitted with procedural violations or violate User rights
• The scope of data that may be provided upon a lawful request is limited to the data the Service actually holds — see Section 2 on the categories of data collected
• The Service does not proactively disclose User data and does not transfer data to commercial third parties (see also Section 5.6)

5.6. What the Service does not do

• Does not sell User data
• Does not transfer data to advertising networks, marketing partners or data brokers
• Does not use data for targeted advertising purposes

6. Cookies

The use of cookies on the undervpn.org website and in the Dashboard is described in a separate Cookie Notice.

7. Data retention period

Data category	Retention period
Identification data of an active account	For the duration of active use of the Service
Payment transactions (identifiers from engaged payment services)	For the period established by applicable tax and accounting legislation
Diagnostic data from support requests	Until the request is closed
Server infrastructure logs (non-personal)	For the period necessary for administration, fault diagnostics and ensuring the security of the Service
Data of a deleted account	Deleted within 30 days of the deletion request

8. User rights

The User has the right to:

8.1. Obtain a copy of their data

Send a request to privacy@undervpn.org — the Service will provide a copy of the data it holds within a reasonable time of receiving the request.

8.2. Request correction of data

Most data can be changed by the User in the Dashboard (email, settings). Changes to Telegram ID and username happen automatically when the Telegram profile is updated.

8.3. Request deletion of data

The account and all related data are deleted upon User request. The request may be sent through any of the available channels:

• A support request via the Telegram bot @gutvpn_bot
• Email: privacy@undervpn.org or support@undervpn.org

Where the User has multiple linked accounts (see Terms of Service Section 3.2), a deletion request by default applies to all linked accounts. Deletion of a single account from a linked group is possible upon corresponding clarification in the request.

Where the User has multiple unlinked accounts, a deletion request applies only to the account from which the request is sent. To delete other unlinked accounts a separate request must be sent confirming that they belong to the User.

After receipt of the request, data is deleted within a reasonable period, except for:

• Information about completed payments (retained for the period established by applicable tax and accounting legislation)
• Data that must be retained by law

8.4. Withdraw consent

The User may stop using the Service at any time. Further data processing ceases after deletion of the account (see Section 8.3).

9. Data security

The Service applies reasonable technical and organisational measures to protect User data, proportionate to the nature of the information processed and applicable requirements. The specific set of measures applied may vary depending on technological developments, available solutions and operational requirements.

The measures applied may include, in particular:

• Use of encryption when transferring data between the User and the Service, as well as when transferring User traffic through the Service infrastructure
• Restriction of access to User data to the circle of persons engaged by the Service for the operation and maintenance of the infrastructure
• Keeping the software and operating systems used up to date in accordance with operational requirements
• Backup measures for critical data where this is required by operational considerations

Despite the measures applied, no method of processing and transmitting data over public communication networks can provide absolute protection against unauthorised access, loss or distortion. The Service does not guarantee absolute protection of data against security incidents, including as a result of third-party actions, the User's own actions or failures in the User's software and hardware. The User accepts these risks by continuing to use the Service.

9.1. Security incidents

In the event of a data breach potentially affecting Users, the Service will notify affected Users in the manner and within the timeframes established by applicable law.

10. Children

The Service is not intended for use by persons under the age of 18. The Service does not knowingly collect data of persons under that age.

If a parent or legal representative becomes aware of the registration of a minor with the Service, a request to delete the account and related data may be sent to support@undervpn.org with the note "Deletion of a minor's account". Documents confirming parental or guardianship rights should be attached to the request.

Upon confirmation of such a request, the account and related data are deleted within a reasonable period.

11. Changes to this Statement

The Service reserves the right to update this Statement. The update procedure depends on the nature of the changes.

11.1. Technical edits

Edits that do not affect User data handling practices (typo corrections, clarification of wording, link updates, updates to contact information, details and the list of engaged payment services) may be made without separate notice. The current version of this Statement is published on the Statement page.

11.2. Material changes

Changes that expand the scope of collected data, the purposes of its use or the circle of data recipients take effect no earlier than 30 (thirty) calendar days from the moment of notifying the User.

Notification of material changes is sent through one or more of the Service's communication channels, including: the Telegram bot @gutvpn_bot, the Service's Telegram news channel, the "News" section on the undervpn.org website, the User's email address (if present in the account).

If the User disagrees with the changes, the User may stop using the Service in the manner set out in Section 8.3 of this Statement.

11.3. Changes due to legal requirements

Changes made in order to bring this Statement into compliance with regulatory acts that have come or are about to come into force take effect within a period that ensures compliance with those requirements. The User is notified of such changes within a reasonable period before they take effect or immediately upon their introduction, unless otherwise provided by applicable law.

The current version of this Statement is always available at the address of publication.

12. Privacy contacts

Requests on data processing matters should be sent to privacy@undervpn.org.

For general questions — support@undervpn.org.

Responses to requests are sent within a reasonable period of receipt, and in cases where the response time is established by applicable law — within the timeframes set by such law.

Change history

Version	Date	Changes
1.0	2026-05-19	First version