Effective date: July 30, 2026
LAN Technology Limited (“we”, “us”, or “our”) operates the FlyElephant VPN / FXVPN website, applications, and related services. This Policy explains how we collect, use, retain, disclose, and protect personal data and how you may exercise your rights.
1. Scope
This Policy applies to our website, desktop and mobile applications, accounts, subscriptions, customer support, and related online services. Third-party websites, app stores, payment providers, and external platforms apply their own privacy policies.
2. Data we process
- Account data: account identifiers, email address, phone number, or other details required for registration and sign-in.
- Subscription and transaction data: order number, plan, amount, currency, payment status, and refund records. Full card or payment credentials are generally processed by payment providers, and we do not require full card numbers to be stored by us.
- Device and application data: device type, operating system, app version, language, time zone, device identifiers, IP address, and security logs needed to operate the service.
- Service operations data: connection time, selected region or server, connection result, error codes, aggregate traffic usage, and technical data needed for reliability and abuse prevention.
- Diagnostic data: crash logs, network diagnostics, and issue descriptions when you choose to submit diagnostics or enable the relevant feature. Please remove unnecessary sensitive content before submission.
- Support data: messages and attachments you send through Telegram, Instagram, WhatsApp, in-app support, or another official channel.
- Website data: essential cookies and, only when analytics is enabled, information such as page visits, referral source, and device category.
We do not intentionally inspect or sell the content of your communications or browsing for advertising profiles. Network data may still be technically transmitted and processed while providing connectivity.
3. Purposes and legal bases
- Create and maintain accounts, verify identity, and provide subscriptions;
- Establish connections, select routes, measure usage, and maintain service quality;
- Process orders, renewals, refunds, accounting, and support;
- Detect fraud, attacks, account sharing, Terms violations, and security risks;
- Diagnose faults and improve applications, servers, and user experience;
- Comply with applicable law, valid legal process, and regulatory obligations;
- Perform analytics or send service communications where consent or law permits.
Depending on the context, we rely on performance of a contract, compliance with legal obligations, legitimate interests in protecting users and the service, and consent. Where local law requires another basis, that requirement applies.
4. Sharing
We disclose data only as necessary to providers of cloud hosting, servers, payments, app stores, customer support, email, analytics, security, and professional advice, subject to appropriate safeguards. Data may transfer as part of a merger, reorganisation, or asset sale, with continued protection. We may also disclose necessary data when legally required, to protect rights, or to respond to a security incident. We do not sell personal data.
5. International processing
FlyElephant VPN uses infrastructure in multiple countries and regions. Your data may be processed outside your place of residence. Where required, we use contractual, technical, and organisational safeguards for international transfers.
6. Retention
We retain data only for as long as needed to provide the service, perform contracts, resolve disputes, prevent fraud, and meet accounting or legal obligations. The period depends on the data type, operational need, and applicable law. We then delete, anonymise, or securely isolate the data.
7. Security
We use reasonable technical and organisational measures, including access controls, transmission safeguards, audit logging, separation of privileges, backups, and incident response. No network or storage system is completely secure, so please protect your credentials and install security updates promptly.
8. Your rights
Depending on applicable law, you may ask whether we hold your personal data and request access, correction, deletion, restriction, objection, portability, or withdrawal of consent. You may also complain to a competent data protection authority. Rights may be limited by account security, legal obligations, fraud prevention, or the rights of others. We may need to verify your identity.
9. Cookies and analytics
The website may use cookies required for security and basic operation. Non-essential analytics or advertising functions operate only when enabled and when applicable consent requirements are met. You can manage cookies through browser or device settings, although disabling essential cookies may affect features.
10. Children
The service is not directed to anyone who has not reached the legal age to enter this agreement in their location. If you believe a child provided personal data without appropriate authorisation, contact us through an official support channel.
11. Changes
We may update this Policy to reflect product, legal, or operational changes. We will provide reasonable notice of material changes through the website, application, or another appropriate channel and update the effective date above.
12. Contact
For privacy, access, correction, or deletion requests, contact LAN Technology Limited through an official channel listed in the Contact section of the website and include “Privacy Request” in your message.
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