I. PRIVACY CHARTER
At CipherWay VPN, we believe that privacy is not a feature; it is the entire product. Our infrastructure is engineered to facilitate secure connectivity without establishing a digital shadow of our users.
The No-Logs & Local Processing Mandate
CipherWay VPN provides a secure encrypted tunnel for your internet traffic.
Non-Persistent Traffic: We do not monitor, record, or store your browsing history, destination IPs, data content, or DNS queries. Your traffic is processed in real-time and is never cached on our systems.
Local Configuration: All VPN configurations and connection preferences are stored locally on your device. We do not maintain centralized user accounts or cloud-based activity logs.
Anonymized Connectivity: We do not collect your original IP address or the IP address of the VPN server you connect to in association with your identity.
Technical Telemetry and Third-Party Interaction
To maintain the integrity of our global network and troubleshoot connectivity failures, we interface with specific technical frameworks.
Firebase (Google): Used exclusively for real-time crash diagnostics and performance monitoring. If a connection fails, Firebase generates a pseudonymized report (e.g., protocol used, device OS) to help us patch vulnerabilities.
Attribution & Analytics (e.g., Adjust, AppsFlyer): These platforms allow us to understand the commercial origin of an installation. They process device-level technical tokens such as your Advertising ID (GAID or IDFA).
The Zero-Access Rule: These partners are contractually prohibited from inspecting your tunneled traffic or correlating technical events with your real-world identity.
Legal Grounds for Processing
We handle technical data based on:
Contractual Necessity: Providing the encrypted tunnel and server switching you have requested via the application.
Legitimate Interests: Utilizing pseudonymized technical IDs to prevent service abuse, defend against DDoS attacks, and ensure software stability.
Your Data Sovereignty and Rights
We uphold the following rights for every user of CipherWay VPN:
Right to Know (Sharing & Selling): You have the right to be informed if your data is shared or sold. CipherWay VPN does not sell your personal or traffic data. Sharing is strictly limited to the technical partners listed in Section 2 for operational maintenance.
Right of Access: You may request access to any personal data we hold. Since we do not log traffic, the data we hold is typically limited to transient technical identifiers; you may contact our DPO for inquiries.
Right to Rectification: You may request that we correct inaccurate or incomplete technical data held by our telemetry partners.
Right to Erasure (Deletion): You can request the deletion of your data. Deleting the app immediately purges local configurations. For technical logs held by partners, our DPO can facilitate a purge request.
Right to Complain: You are entitled to contact a regulatory authority in your jurisdiction if you believe our privacy practices are non-compliant with local laws.
Retention Lifecycle
Connection Data: Ephemeral metadata (e.g., session duration) is purged immediately upon disconnection.
Telemetry Data: Non-identifiable logs held by third-party partners are retained for the minimum period necessary for aggregate reporting—typically 12 to 24 months—before being permanently anonymized.
Choice and Opt-Out Mechanisms
Disallowing Sharing/Sales: While we do not "sell" data, you can stop technical sharing by enabling "Limit Ad Tracking" (iOS) or "Opt out of Ads Personalization" (Android) within your system settings.
Kill-Switch Control: You have the right to terminate all data processing by disconnecting the VPN or revoking the "VPN Configuration" permission in your device settings.
Data Protection Officer (DPO)
We have appointed a DPO to safeguard our encryption standards and handle privacy inquiries.
DPO Name: Julian Thorne
Contact Email: dpo@cipherway-vpn.com
II. END-USER LICENSE AGREEMENT (EULA)
Grant of License
CipherWay VPN grants you a personal, non-exclusive, non-transferable, and revocable license to use the software on a single device for secure internet access, subject to these terms.
Acceptable Use Policy
By utilizing CipherWay VPN, you agree not to:
- Use the service for any illegal activities, including but not limited to copyright infringement, cyber-attacks, or spreading malicious software.
- Attempt to reverse engineer or decompile the proprietary encryption protocols.
- Resell or commercially exploit the VPN bandwidth provided through the app.
Intellectual Property
The CipherWay VPN name, branding, and proprietary "CipherTunnel" logic are the exclusive property of the developer. No ownership is transferred to the user.
Disclaimer of Warranty
CipherWay VPN is provided "AS IS." While we strive for 99.9% uptime and military-grade encryption, we do not warrant that the service will be uninterrupted or that it will bypass every regional firewall. Internet speeds may vary based on your local provider.
Limitation of Liability
To the maximum extent permitted by law, CipherWay VPN and its creators shall not be liable for any damages resulting from your use of the service, including data loss or legal consequences arising from your online activities while connected.
Termination
This agreement is effective until terminated by you (via uninstallation). We reserve the right to revoke your license immediately if you violate any terms of this EULA or engage in illegal activities using our servers.