TuxlerVPN Mobile
Get App

User Data Governance

Data Processing Overview

This page summarises TuxlerVPN Mobile’s processing activities in a structure aligned with Article 30 of the GDPR (records of processing activities). It restates information already published in the Privacy Policy (sections 2 to 5 and 8) in a format that is convenient for data protection authorities, business reviewers, and researchers. The Privacy Policy controls in the event of any conflict.

Controller

Tuxler Digital Services Corp., incorporated in Panama. Postal address: World Trade Center 200-B, Suite 157, Calle 53 Este, Marbella, PA, Republica de Panama. Contact: [email protected]. A Data Protection Officer has not been appointed. Privacy and data-rights enquiries are handled through the email address above. Source: Privacy Policy §13.

Categories of data subjects

  • Standard (free) users: typically identifiable only by an app-instance UUID generated locally on first launch (Privacy Policy §2.1).
  • Premium subscribers: identified by the same app-instance UUID as Standard users, with a Google Play purchase token/payload used for entitlement verification, support, refunds, abuse prevention, and legally required payment records.
  • Website visitors: visitors to tuxlervpn.app, who interact only with strictly-necessary cookies (Privacy Policy §2.7).
  • Customer-support contacts: anyone who emails [email protected].

Processing activities

For each activity below we list the purpose, lawful basis, data categories, recipients, and retention.

1. Service operation (VPN tunnel). Purpose: deliver the VPN service requested by the user. Lawful basis: performance of a contract. Data: app-instance UUID, session token, device manufacturer / model, Android version, Android SDK version, app version/build number, approximate IP-derived location, server-region selection, and (during the active session only) connection metadata. Recipients: the TuxlerVPN Mobile backend and the Tuxler-operated VPN gateway servers. Retention: local UUID and session-token storage lasts until app-data clearing, uninstall, or token expiry; VPN-session metadata is discarded on disconnect (Privacy Policy §2.6, §8).

2. Play Integrity and subscription verification. Purpose: confirm that service requests come from a genuine app installation and, for Premium users, an entitled subscriber. Lawful basis: performance of a contract and legitimate interest in service security. Data: Play Integrity token, session token, Google Play purchase token and associated payload where applicable. Recipients: Google LLC (Google Play Integrity and Google Play Billing) and the TuxlerVPN Mobile backend. Retention: session/security tokens for their service lifetime; purchase-token records as needed for entitlement, support, refunds, abuse prevention, and legally required records (Privacy Policy §2.1, §2.2, §8).

3. Payment processing. Purpose: collect subscription fees. Lawful basis: performance of a contract. Data: payment instrument data (card / billing details). Recipients: Google LLC. Retention: held by Google per their billing terms. TuxlerVPN Mobile does not store full payment details (Privacy Policy §2.2).

4. Customer support. Purpose: respond to user enquiries and resolve issues. Lawful basis: performance of a contract or legitimate interest, with consent where required. Data: email address used to contact us, the message contents, and any information you choose to share. Recipients: a third-party customer-support provider (USA) acting as a processor, and the TuxlerVPN Mobile backend. Retention: while the request is active; support threads are deleted after 90 days of inactivity on the thread, or earlier on request (Privacy Policy §2.3, §8).

5. Crash reporting and diagnostics. Purpose: identify and fix bugs and crashes. Lawful basis: legitimate interest. Data: crash type, stack trace, app version, Android version, device model, and standard network metadata received by the crash-reporting processor. Recipients: Sentry (Functional Software, Inc., USA). Retention: Sentry’s standard schedule, typically 90 days (Privacy Policy §2.4, §8). The Sentry SDK is configured to send data only on actual crashes; session tracking, breadcrumbs, screenshots, and view-hierarchy capture are disabled (see Privacy Policy §2.4 for the full configuration).

6. Google Play ratings and reviews. If the app opens a rating prompt, it directs the user to Google Play. Ratings and public reviews submitted there are handled by Google Play under Google’s own terms. The TuxlerVPN Mobile app does not transmit written rating or review content to the TuxlerVPN Mobile backend.

7. Website hosting. Purpose: keep the website online and protected from abuse. Lawful basis: legitimate interest. Data: standard web-server access logs at the hosting provider plus strictly-necessary cookies. Recipients: a third-party web hosting provider. Retention: per the hosting provider’s documented log-retention policy. The website does not currently use analytics, advertising, or social-media tracking cookies, and no third-party cookies are placed on visitors’ devices (Privacy Policy §2.7).

8. Fraud, abuse, and legal compliance. Purpose: detect and prevent abuse of the Service, comply with applicable law, and respond to valid legal process. Lawful basis: legitimate interest and legal obligation. Data: the minimum necessary to act on the specific report or legal process. Recipients: where required, payment partners and competent authorities (see Law-Enforcement Request Policy). Retention: as required by law or by the specific matter (Privacy Policy §3, §4).

Sub-processors

TuxlerVPN Mobile engages the following categories of sub-processors (Privacy Policy §4).

  • Payment processing. Google LLC, Google Play Billing.
  • Crash reporting. Sentry, operated by Functional Software, Inc. (USA).
  • Customer-support delivery. Third-party provider (USA).
  • Web hosting. A third-party web hosting provider.
  • Cloud infrastructure for backend services. Third-party hosting providers operating our backend servers and supporting infrastructure under standard data-processing agreements.

VPN gateway servers are operated by Tuxler on infrastructure leased from hosting providers; the hosting providers act as sub-processors in line with Privacy Policy §4. The gateways route VPN traffic with no content logging (Privacy Policy §2.6, §4).

International transfers

Personal data may be processed in:

  • Panama: the controller.
  • United States: Sentry crash reporting and third-party customer-support delivery.
  • Canada, the United States, and/or the Netherlands: cloud infrastructure behind our backend, depending on routing.
  • Various countries worldwide: VPN gateway servers operated by Tuxler.

Where data is transferred outside the EEA or the UK, we rely on the European Commission’s Standard Contractual Clauses, the UK Addendum where applicable, or on the recipient’s certification under a recognised adequacy framework. A copy of the relevant SCCs is available on request from [email protected]. Source: Privacy Policy §5.

Updates log

This document is updated when sub-processors change or when a new processing activity begins. Material changes also trigger an update to the Privacy Policy.

Last reviewed: 21 July 2026.