Privacy Policy

Last updated: February 11, 2026

1. Introduction

Welcome to Digital Commerce & Technologies Ltd.

Digital Commerce & Technologies Ltd ("us", "we", or "our") operates VAVA VPN, including the VAVA VPN mobile applications for iOS and Android and the website vavavpn.net (hereinafter referred to as the "Service"). This Privacy Policy governs your use of the Service and explains how we collect, safeguard, and disclose information that results from your use of our Service.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used here have the same meanings as in our Terms and Conditions.

Our Terms and Conditions ("Terms") govern all use of our Service and together with this Privacy Policy constitute your agreement with us.

2. Definitions

  • SERVICE means the VAVA VPN applications and website operated by Digital Commerce & Technologies Ltd (company number 13025211, registered in England and Wales).
  • PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information in our possession or likely to come into our possession).
  • USAGE DATA means data collected automatically, generated by the use of the Service or from the Service infrastructure itself (for example, app session duration or feature usage).
  • DEVICE DATA means information about the device you use to access our Service, such as device type, operating system, and app version.
  • DATA CONTROLLER means the natural or legal person who determines the purposes and manner in which any personal data are processed. For this Privacy Policy, we are the Data Controller of your data.
  • DATA PROCESSORS (SERVICE PROVIDERS) means any natural or legal person who processes data on behalf of the Data Controller. We may use service providers to process your data.
  • USER means the individual using our Service, who corresponds to the Data Subject.

3. Information We Collect

We collect several types of information for various purposes to provide and improve our Service.

Personal Data

When using our Service, you may provide us with personally identifiable information that can be used to contact or identify you, including but not limited to:

  • Email address
  • Name (if you choose to provide it, e.g., for support)
  • Account credentials if you create an account

We may use your Personal Data to contact you with service updates, security notices, or support. You may opt out of marketing communications at any time.

Usage Data

We may collect information about how you interact with our app and website, such as which features you use, app version, and general usage patterns. This does not include your browsing activity when connected to the VPN (see No-Log VPN Policy below).

Device Data

When you access the Service from a device, we may collect information such as device type, operating system and version, unique device identifiers, and other diagnostic data necessary to provide and improve the Service.

Payment Information

If you make in-app purchases, payment processing is handled by Apple (App Store) or Google (Google Play). We do not store or collect your payment card details. Those are governed by the respective platform privacy policies.

4. No-Log VPN Policy

VAVA VPN is designed with privacy at its core. We do not log, store, or associate the following with your identity or account when you use our VPN service:

  • Your browsing history, traffic, or content you access
  • Connection timestamps or session duration in a way that identifies you
  • Your original IP address or the IP addresses you are assigned while connected
  • DNS queries or destinations you visit

We may collect minimal, aggregated, or anonymized technical data (such as server load or connection success rates) to maintain and improve the VPN infrastructure. Such data cannot be used to identify you or your activity.

This no-log approach is central to our commitment to your privacy and is consistent with our promise: no logs, no tracking, just a more private internet.

5. How We Use Your Information

Digital Commerce & Technologies Ltd uses the collected data for purposes including:

  1. To provide and maintain our Service
  2. To notify you about changes to our Service
  3. To provide customer support
  4. To gather analysis or valuable information to improve our Service
  5. To monitor usage of our Service
  6. To detect, prevent, and address technical issues and security threats
  7. To fulfill any other purpose for which you provide the information
  8. To carry out our obligations and enforce our rights arising from any contracts
  9. To provide notices about your account or subscription, if applicable
  10. For any other purpose with your consent

6. Disclosure of Information

We may disclose personal information we collect or you provide:

  • Business transaction. If we or our subsidiaries are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred.
  • Service providers. To contractors, service providers, and other third parties we use to support our business (e.g., hosting, analytics, payment processing), who are obligated to protect your data.
  • Purpose. To fulfill the purpose for which you provide it or as disclosed when you provide it.
  • Consent. With your consent in other cases.
  • Legal and safety. If we believe disclosure is necessary to comply with applicable law, legal process, or to protect the rights, property, or safety of Digital Commerce & Technologies Ltd, our users, or others.

7. Data Retention

We retain your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy. We retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and policies.

Usage Data is generally retained for a shorter period, except when used to strengthen security or improve the Service, or when we are legally obligated to retain it longer.

With respect to VPN usage, we do not collect or retain data about your browsing activity while you are connected to our VPN service.

8. Data Security

The security of your data is important to us. We use commercially reasonable measures to protect your Personal Data, including encryption where appropriate. However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your Personal Data, we cannot guarantee its absolute security.

9. International Data Transfers

Your information, including Personal Data, may be transferred to and maintained on servers located outside your state, province, country, or other governmental jurisdiction where data protection laws may differ.

If you are located outside the United States and choose to provide information to us, we may transfer the data, including Personal Data, to the United States and process it there. Your consent to this Privacy Policy and your submission of such information represents your agreement to that transfer.

Digital Commerce & Technologies Ltd will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to an organization or country unless there are adequate controls in place.

10. Your Data Protection Rights (GDPR)

If you are a resident of the European Union (EU) or European Economic Area (EEA), you have certain data protection rights under the General Data Protection Regulation (GDPR).

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to know what Personal Data we hold about you or want it removed, please email us at support@vavavpn.net.

In certain circumstances, you have the right to:

  1. Access, update, or delete the information we have on you
  2. Have your information rectified if it is inaccurate or incomplete
  3. Object to our processing of your Personal Data
  4. Request that we restrict the processing of your personal information
  5. Receive a copy of your Personal Data in a structured, machine-readable format (data portability)
  6. Withdraw your consent at any time where we rely on consent to process your personal information

We may ask you to verify your identity before responding to such requests. We may not be able to provide the Service without some necessary data.

You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, contact your local data protection authority in the EEA.

11. Your California Privacy Rights

CalOPPA

Under the California Online Privacy Protection Act (CalOPPA), we agree that: users can visit our site anonymously; our Privacy Policy link includes the word "Privacy" and can be found on our website; users will be notified of privacy policy changes on this page; and users can change their personal information by emailing us at support@vavavpn.net.

CCPA

If you are a California resident, you may have the right to know what personal information we collect, how we use and share it, and to request access, deletion, or correction. We do not sell your personal information for monetary consideration. To exercise your California data protection rights, send your request by email to support@vavavpn.net.

We will not discriminate against you for exercising your privacy rights.

12. Third-Party Services

We may use third-party companies and individuals to facilitate our Service, provide it on our behalf, perform Service-related services, or assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

This may include analytics providers, hosting and infrastructure providers, and (for in-app purchases) Apple and Google as payment processors. Payment card details are not stored by us and are governed by the respective platform and processor policies.

Our website may use cookies or similar technologies for essential operation, preferences, and analytics. You can manage cookie preferences in your browser settings.

13. Children's Privacy

Our Service is not intended for use by children under the age of 18 ("Child" or "Children").

We do not knowingly collect personally identifiable information from children under 18. If you become aware that a child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

14. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

We may also notify you via email and/or a prominent notice in our Service prior to the change becoming effective. You are advised to review this Privacy Policy periodically. Changes are effective when posted on this page.

15. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, please contact us by email: support@vavavpn.net.