Privacy Policy

1. What Data We Collect

We collect the minimum data necessary to provide the Service. Depending on whether you are registered, we process different categories of data:

Anonymous trial (no registration): a unique app installation identifier (install_id), device model, operating system version, trial subscription identifier. Email is NOT collected. Retention: 30 days or until registration, whichever comes first.

Registered account: email address, hashed password (we never store passwords in plaintext), subscription status, connection history (time, selected region, success), identifiers of devices linked to the account.

Payments: when paying for a subscription, we receive the transaction status, amount, and payment identifier from the payment provider. Bank card details are NEVER sent to our servers — they are processed exclusively by the payment provider (YooMoney).

AI support assistant: the text of your messages in the AI support chat, the context of your account (subscription status, recent diagnostic events), and the assistant's responses. This data is used to provide context-aware support.

Technical logs: VPN tunnel connect/disconnect events, application errors, transport protocol types. The CONTENT of your traffic, visited websites, and DNS queries are NOT logged.

2. How We Use This Data

• To provide and maintain the Service (issue VPN profiles, manage subscriptions, diagnose incidents).
• To provide technical support via the AI assistant and human operators.
• To prevent abuse (e.g., enforcing the device limit per subscription, blocking automated registration).
• To improve Service quality (analyzing aggregated connection statistics, detecting infrastructure issues).
• For notifications about your subscription status, technical messages, and important Service changes.
• To comply with our legal obligations (e.g., responding to lawful government requests in jurisdictions where we operate).

3. Who We Share Data With

We use a limited set of third-party processors (sub-processors) to provide the Service:

Anthropic, PBC (USA) — processes the text of your AI support assistant messages via the Claude API. Anthropic does NOT use our data to train models in API mode. Transfer is governed by their terms of service.

YooMoney (Russia) — processes PRO_5 / PRO_10 subscription payments. Receives bank card details directly from you (bypassing our servers) and passes us only the transaction status.

Amazon Web Services (Ireland, region eu-north-1) — hosts our database and API servers. All your data is physically located on AWS servers in Stockholm, Sweden.

Vultr, AWS, TimeWeb, and other VPN infrastructure providers — hosting VPN exit nodes in various countries. These providers only see encrypted VPN traffic and connection metadata; the CONTENT of your traffic is not accessible to them or to us.

We do NOT sell your data to third parties for advertising or marketing purposes.

4. Data Retention

• Anonymous trial subscriptions: 30 days from activation or until registration (whichever comes first).
• Registered user accounts: until deleted at your request or after 3 years of inactivity.
• Connection history and diagnostic events: up to 90 days.
• Payment history: 5 years (required by tax and financial law).
• Support conversations (AI + human operators): 30 days.

5. Your Rights

Depending on your jurisdiction (GDPR for EU/EEA users, similar regimes in Russia and other countries), you have the right to:

Request a copy of the data we hold about you. Account data is accessible via the user cabinet; for a full export, contact support.

Request correction of inaccurate data.

Request deletion of your account and associated data. Payment records may be retained as required by law.

Withdraw consent for data processing (which terminates Service provision).

Lodge a complaint with the data-protection supervisory authority in your jurisdiction.

All requests should be sent to privacy@freecityvpn.net. We will respond within 30 days.

6. Data Security

We apply technical and organizational measures to protect your data: transport encryption (TLS 1.3), password hashing (bcrypt), restricted employee access to production systems, regular security updates.

Despite these measures, no method of data transmission over the internet or storage is absolutely secure. We cannot guarantee absolute data security.

7. Children

The Service is not intended for persons under 18. We do not knowingly collect data from minors. If you are a parent or guardian and become aware that your child has provided us with data, please contact us for its deletion.

8. International Data Transfers

Your data is processed on servers in Sweden (Amazon Web Services, region eu-north-1) and may be transferred to processors in the USA (Anthropic) and Russia (YooMoney). Transfers are governed by relevant data-processing agreements and standard contractual clauses where applicable.

9. Changes to This Policy

We may update this Policy from time to time. Material changes will be posted on this page with an updated effective date and, where possible, communicated via email or within the Service at least 14 days before they take effect.

10. Contact

Privacy data inquiries: privacy@freecityvpn.net

General support: support@freecityvpn.net

Legal entity: SparckTech LLC