CCPA Notice

1. INTRODUCTION

This California Consumer Privacy Act Notice (“CCPA Notice”) is provided to comply with the California Consumer Privacy Act (CCPA) and applies only to California residents who use TuxlerVPN Mobile’s services.

While TuxlerVPN Mobile operates under Panamanian law, we acknowledge our obligations under the CCPA for users residing in California, USA. This notice outlines how we collect, use, disclose, and protect personal information of California users, as well as the rights afforded to them under the CCPA and other applicable laws.

For a complete understanding of TuxlerVPN Mobile’s privacy practices, please refer to our Privacy Policy.

2. PERSONAL INFORMATION WE COLLECT

Under the CCPA (Cal. Civ. Code § 1798.140(o)), “personal information” is broadly defined as any information that identifies, relates to, describes, or could reasonably be linked to an individual or household.

How We Collect This Information

The TuxlerVPN Mobile Android app does not require you to register a TuxlerVPN Mobile account, and we do not collect names, postal addresses, or phone numbers in the app. The personal information that is processed about California residents is limited to:

• App-instance identifier (a random UUID generated on your device on first launch) and basic device information (manufacturer, model, Android version, app version), processed when the app requests a VPN configuration

• Approximate location (the VPN server region you select)

• Crash reports and diagnostics (sent to Sentry)

• Google Play subscription information (purchase token and subscription status, for premium users)

• Customer support communications (when you email us or submit in-app feedback)

• Website interactions at tuxlervpn.app (strictly-necessary cookies only; no analytics or advertising cookies are currently set)

3. HOW WE USE PERSONAL INFORMATION

We use personal information for the following business purposes:

• Service Provisioning. To deliver VPN services, route you to the appropriate gateway, and verify Google Play subscription status for premium users.
• Security & Fraud Prevention. To detect fraudulent transactions, prevent abuse, and ensure secure access.
• Customer Support. To respond to inquiries, process refunds, and troubleshoot technical issues.
• Legal & Compliance. To comply with applicable laws, enforce our terms, and address legal claims.

We DO NOT:

-Sell personal data to third parties.

-Use personal data for targeted advertising.

4. SHARING PERSONAL INFORMATION

We do not sell your personal data. However, we may share certain data with service providers for business purposes, such as:

Recipient	Purpose
Google LLC (Google Play Billing)	Secure payment processing and subscription management
Sentry (Functional Software, Inc., USA)	Crash reports and diagnostics
Customer-support provider (USA)	Responding to support inquiries and resolving issues
Cloud hosting and IT providers	Hosting our VPN backend infrastructure and website

These third parties are contractually required to handle your data securely and only for authorized purposes. We do not sell or rent your personal information.

5. YOUR RIGHTS UNDER THE CCPA

As a California resident, you have the following CCPA rights:

5.1 Right to Know

You may request disclosure of the personal information we collected, used, shared, or disclosed in the past 12 months, including:

• The categories of personal information collected
• The categories of sources from which we obtained personal information
• The business purpose for collecting the information
• The categories of third parties with whom we share data

✅ How to Submit a Request: Contact [email protected] with the subject “CCPA Data Request.”

5.2 Right to Delete

You may request deletion of your personal data, subject to the following exceptions:

• If the data is necessary to complete a transaction, provide a service, or comply with legal obligations.
• If the deletion would impair security, fraud detection, or troubleshooting activities.

✅ How to Submit a Request: Contact [email protected] with the subject “CCPA Deletion Request.”

5.3 Right to Opt-Out of Sale of Personal Data

TuxlerVPN Mobile does not sell personal data. Therefore, this right does not apply.

5.4 Right to Non-Discrimination

We do not:

• Deny services

• Charge different prices

• Provide lower service quality

For exercising your CCPA rights.

6. HOW TO EXERCISE YOUR CCPA RIGHTS

To submit a CCPA request, you may contact us:

📧 Email: [email protected]

Verification Process:

Because TuxlerVPN Mobile does not maintain user accounts, we cannot verify requests by account login. To protect user privacy while preventing fraudulent requests, we may ask you to provide:

• Your app-instance UUID (visible in the app’s About screen, where supported)

• The Google Play order ID (for Premium users), which we can match against our entitlement records

• The approximate dates and country from which you used the app

• Any other detail that reasonably allows us to associate the request with your data

7. DATA RETENTION

We retain user data only for as long as necessary for:

• Providing the VPN service and verifying Google Play subscriptions
• Legal compliance (e.g., tax or fraud prevention)
• Security & troubleshooting

When a deletion request is granted (see §5.2), data tied to your installation (app-instance UUID, device info, server-region selection, Sentry crash records, and subscription verification records) is permanently removed, except where retention is legally required (e.g., tax records).

8. GOVERNING LAW & DISPUTE RESOLUTION

This CCPA Notice is governed by Panamanian law.

However, for California residents, disputes regarding CCPA rights may be handled:

-Via arbitration in Panama, if mutually agreed upon.

-Via California consumer protection agencies, where applicable.

For legal inquiries, contact [email protected]

9. CHANGES TO THIS NOTICE

We may update this CCPA Notice from time to time to reflect:

-Changes in legal requirements

-Updates in privacy practices

We will notify users via email or app notifications if significant changes occur.

10. CONTACT INFORMATION

For questions about CCPA rights, reach out to us:

📧 Privacy Support: [email protected]