Privacy Policy

Last Updated: November 16, 2025

1. Company Information

Company Name: Fully Private LLC
Registered Address: 651 N Broad Street, Suite 201, Middletown, DE 19709, United States
State of Incorporation: Delaware
Email: [email protected]
Support: [email protected]

2. Our Commitment to Privacy

Fully Private VPN is built on the principle that your privacy is a fundamental right. We understand that when you choose a VPN service, you're placing your trust in us to protect your digital life. This Privacy Policy outlines our practices and your rights regarding your personal information.

3. Information We Collect

3.1 Information We DO Collect

To provide our VPN service, we collect only the following minimal information:

Account Information:

• Email Address: Required for account creation, authentication, and communication
• Username: Your chosen username for account identification
• Password: Stored in encrypted form for account security
• Account Status: Subscription plan and status information

Payment Information:

• Billing Details: Processed by third-party payment processors (Stripe, PayPal)
• Transaction History: Records of payments and subscriptions for billing purposes
• Note: We do NOT store full credit card numbers or payment details on our servers

Technical Information:

• Device Type: Operating system and device category (for app compatibility)
• App Version: Version of our VPN application you're using
• Aggregate Bandwidth Usage: Total data transferred (not associated with specific activities)

Customer Support Communications:

• Support Tickets: Your inquiries and our responses
• Diagnostic Data: Only when voluntarily provided to troubleshoot issues

3.2 Information We DO NOT Collect

We maintain a strict no-logs policy. We do NOT collect, log, or store:

• ❌ Browsing History: Websites you visit while connected to our VPN
• ❌ Connection Logs: Times when you connect or disconnect from our servers
• ❌ IP Addresses: Your real IP address or VPN server IP assignments
• ❌ DNS Queries: Domain names you look up or websites you access
• ❌ Traffic Data: Content of your internet communications
• ❌ Connection Duration: How long you use our service per session
• ❌ Bandwidth Monitoring: Individual usage patterns or data consumption per user
• ❌ Device Information: Unique device identifiers or hardware specifications

4. How We Use Your Information

The limited information we collect is used solely for the following purposes:

4.1 Service Provision:

• Create and manage your VPN account
• Authenticate your login credentials
• Process your subscription and payments
• Provide access to our VPN servers and network

4.2 Customer Support:

• Respond to your inquiries and support requests
• Troubleshoot technical issues
• Provide service updates and notifications

4.3 Service Improvement:

• Analyze aggregate usage patterns to improve server performance
• Monitor overall network health and capacity
• Develop new features and enhance existing ones

4.4 Legal Compliance:

• Comply with applicable laws and regulations
• Enforce our Terms and Conditions
• Protect our legal rights and prevent fraud

5. How We Protect Your Information

We implement industry-leading security measures to protect your data:

5.1 Encryption:

• AES-256 Encryption: Military-grade encryption for all VPN traffic
• TLS/SSL: Secure connections for our website and applications
• Secure Protocols: Support for OpenVPN, WireGuard, and IKEv2

5.2 Infrastructure Security:

• RAM-Only Servers: No data persists after server reboot
• Secure Data Centers: Physical and digital security measures
• Regular Security Audits: Third-party security assessments
• Network Isolation: Segregated systems to prevent unauthorized access

5.3 Access Controls:

• Limited Access: Only authorized personnel can access user data
• Multi-Factor Authentication: For all administrative access
• Encryption at Rest: All stored data is encrypted

6. Information Sharing and Disclosure

6.1 We DO NOT Sell Your Data: We never sell, rent, or trade your personal information to third parties for marketing purposes.

6.2 Limited Third-Party Sharing: We only share information with:

Payment Processors:

• Stripe, PayPal, and other payment gateways for billing
• Only transaction information necessary to process payments
• These providers have their own privacy policies

Service Providers:

• Cloud hosting providers for infrastructure
• Email service providers for account communications
• All providers are contractually bound to protect your data

6.3 Legal Requirements:

We may disclose information if required by law, but due to our no-logs policy, we have minimal data to provide. We will:

• Challenge overly broad or improper requests
• Notify you of legal requests when legally permitted
• Only provide information we actually possess

7. Data Retention

7.1 Account Information: Retained while your account is active and for a limited period after cancellation for billing and legal purposes.

7.2 Payment Records: Retained as required by law for tax and accounting purposes (typically 7 years).

7.3 Support Communications: Retained for up to 2 years to improve service quality.

7.4 Connection Data: We do NOT retain any connection logs, browsing history, or traffic data.

7.5 Data Deletion: You can request deletion of your account data at any time by contacting [email protected].

8. Your Privacy Rights

Depending on your location, you may have the following rights:

8.1 Access Rights:

• Request a copy of the personal information we hold about you
• Access your account information through your user dashboard

8.2 Correction Rights:

• Update or correct your account information
• Change your email address or password

8.3 Deletion Rights:

• Request deletion of your account and associated data
• Close your account at any time

8.4 Portability Rights:

• Request your data in a portable format
• Transfer your data to another service

8.5 Objection Rights:

• Opt-out of marketing communications
• Object to processing of your personal data

To Exercise Your Rights: Contact us at [email protected] with your request.

9. International Data Transfers

We operate globally and may transfer your information to servers located in different countries. When we transfer data internationally:

• We ensure adequate protection through standard contractual clauses
• We comply with applicable data protection laws (GDPR, CCPA, etc.)
• Data is encrypted during transfer and at rest
• We use secure data centers with appropriate safeguards

10. Cookies and Tracking Technologies

10.1 Website Cookies: Our website uses minimal cookies for:

• Essential Cookies: Required for website functionality and security
• Session Cookies: To maintain your logged-in state
• Preference Cookies: To remember your settings

10.2 No Tracking: We do NOT use:

• ❌ Third-party advertising cookies
• ❌ Analytics tracking that identifies individuals
• ❌ Cross-site tracking technologies
• ❌ Behavioral profiling tools

10.3 Cookie Management: You can control cookies through your browser settings.

11. Children's Privacy

Our Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at [email protected], and we will delete such information.

12. Third-Party Links and Services

Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

13. Data Breach Notification

In the unlikely event of a data breach that affects your personal information, we will:

• Notify affected users within 72 hours of discovery
• Report the breach to relevant authorities as required by law
• Take immediate action to secure our systems
• Provide guidance on protective measures you can take

14. Compliance with Privacy Laws

We comply with major privacy regulations worldwide, including:

14.1 GDPR (General Data Protection Regulation):

• Legal basis for processing: Contractual necessity and legitimate interest
• Data protection officer available for inquiries
• Right to lodge complaints with supervisory authorities

14.2 CCPA (California Consumer Privacy Act):

• California residents have additional rights under CCPA
• We do not sell personal information
• Right to opt-out and non-discrimination

14.3 Other Jurisdictions:

• We comply with local privacy laws where we operate
• Additional rights may apply based on your location

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes:

• We will update the "Last Updated" date at the top of this policy
• We will notify you via email or through our service
• We will provide at least 30 days' notice for significant changes
• Continued use of our Service after changes indicates acceptance

16. Transparency Report

We believe in transparency. We commit to publishing an annual transparency report detailing:

• Number and types of legal requests received
• How we responded to those requests
• Any government data requests (we typically have no data to provide)
• Security incidents or breaches (if any)

17. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

• Company: Fully Private LLC
• Address: 651 N Broad Street, Suite 201, Middletown, DE 19709, United States
• Privacy Email: [email protected]
• Support Email: [email protected]
• Legal Department: [email protected]

We will respond to all privacy inquiries within 30 days.