Privacy Policy

1. Introduction & Data Controller

This Privacy Policy explains how Rinzler Technologies Ltd ("we", "us", "our", "Rinzler") collects, uses, discloses, and protects your personal data when you use our Rinzler VPN application ("App") and related services ("Services").

We are committed to protecting your privacy and ensuring that your personal data is handled in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).

2. Data We Collect

2.1 Data We DO NOT Collect (No-Logs Policy)

We do not collect, store, or log:

• Your browsing history or internet activity
• Your original IP address when connected to VPN
• VPN connection timestamps
• DNS queries made through our service
• Any data content transmitted through our VPN
• Bandwidth usage per user session

2.2 Account Information

When you create an account, we collect:

• Email address — for account creation, authentication, and communication
• Password — stored in encrypted (hashed) form only
• Payment information — processed by third-party payment processors; we do not store full card details

2.3 Technical Data

We may collect limited technical data for service operation:

• Device type and operating system — to provide compatible app versions
• App version — for updates and support
• Aggregate bandwidth statistics — non-identifiable, for server capacity planning
• Crash reports — anonymised, with your consent, to improve app stability

2.4 Communication Data

If you contact our support team, we retain:

• Your email address and name (if provided)
• Content of your communications
• Support ticket history

3. Legal Basis for Processing

Under UK GDPR, we process your personal data based on the following legal grounds:

• Contract Performance (Article 6(1)(b)): Processing necessary to provide our VPN services to you under our Terms of Service.
• Legitimate Interests (Article 6(1)(f)): Processing for fraud prevention, security, and service improvement, where our interests do not override your rights.
• Consent (Article 6(1)(a)): Where you have given explicit consent, such as for marketing communications or optional crash reporting.
• Legal Obligation (Article 6(1)(c)): Processing required to comply with UK law, such as tax and accounting requirements.

4. How We Use Your Data

We use your personal data for the following purposes:

• Service Provision: To create and manage your account, authenticate your access, and provide VPN services
• Payment Processing: To process subscription payments and manage billing
• Customer Support: To respond to your enquiries and provide technical assistance
• Service Improvement: To analyse aggregated, non-identifiable data to improve our infrastructure
• Security: To detect and prevent fraud, abuse, and security threats
• Communications: To send essential service notifications (e.g., security alerts, policy updates)
• Marketing: With your consent, to send promotional materials about our services

5. Data Sharing & International Transfers

5.1 Third-Party Service Providers

We may share limited data with trusted service providers who assist us in operating our services:

• Payment Processors: Stripe, Apple Pay, Google Pay — for secure payment processing
• Cloud Infrastructure: Server hosting providers with appropriate data protection agreements
• Customer Support Tools: Helpdesk software providers
• Analytics: Privacy-focused, aggregated analytics only (no personal data shared)

5.2 International Data Transfers

Your data may be transferred to countries outside the UK. When this occurs, we ensure appropriate safeguards are in place:

• UK adequacy decisions
• Standard Contractual Clauses (SCCs) approved by the ICO
• Binding Corporate Rules where applicable

5.3 Legal Disclosure

We may disclose personal data if required by law or in response to valid legal requests. However, due to our no-logs policy, we have no VPN activity data to provide.

6. Data Retention

We retain your personal data only for as long as necessary:

• Account Data: Retained while your account is active, plus 30 days after deletion request
• Payment Records: 7 years after transaction (UK legal requirement)
• Support Communications: 2 years after ticket resolution
• Marketing Consent Records: Until consent is withdrawn, plus 1 year for compliance records
• VPN Activity Data: Not retained — we do not log this data

7. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

• Right of Access (Article 15): Request a copy of your personal data we hold
• Right to Rectification (Article 16): Request correction of inaccurate data
• Right to Erasure (Article 17): Request deletion of your data ("right to be forgotten")
• Right to Restrict Processing (Article 18): Request limitation of how we use your data
• Right to Data Portability (Article 20): Receive your data in a structured, machine-readable format
• Right to Object (Article 21): Object to processing based on legitimate interests or for marketing
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Rights Related to Automated Decision-Making (Article 22): We do not use automated decision-making that produces legal effects

Complaints

If you are unsatisfied with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Telephone: 0303 123 1113

8. Data Security

We implement robust technical and organisational measures to protect your data:

• Encryption: AES-256 encryption for data at rest; TLS 1.3 for data in transit
• VPN Protocols: Industry-leading protocols including WireGuard, OpenVPN, and IKEv2
• Access Controls: Strict role-based access to systems containing personal data
• Infrastructure Security: Regular security audits and penetration testing
• Password Security: Passwords stored using bcrypt hashing with salting
• Incident Response: Documented procedures for data breach detection and notification

9. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us immediately, and we will take steps to delete such information.

10. Changes to This Policy

We may update this Privacy Policy from time to time. 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 in-app notification for significant changes
• Continued use of our Services after changes constitutes acceptance of the updated policy

We encourage you to review this policy periodically.

11. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

We aim to respond to all enquiries within 5 business days.