Personal Data Processing

1. PRINCIPLES

Cluster VPN processes personal data for defined and lawful purposes. The data collected is proportionate to those purposes, and access is limited to those who need it to operate the service.

2. DATA SUBJECTS AND CATEGORIES

Data subjects include users, payers, referral participants, and people contacting support. Data categories include Telegram identifiers and profile details, subscription and payment records, support content, service events, and necessary technical identifiers.

Cluster VPN does not request sensitive categories of personal data and asks users not to submit them to support unless strictly necessary.

3. PURPOSES AND BASES

• entering into and performing the Terms of Use;
• providing trial and paid access and additional traffic;
• processing payments, support requests, and referral rewards;
• security, abuse prevention, and mandatory compliance;
• user consent where required for a specific operation.

4. PROCESSING OPERATIONS

Operations may include collection, recording, organisation, storage, updating, use, disclosure to an authorised processor, restriction, deletion, and destruction by automated or non-automated means.

Personal data is not sold. Decisions producing legal effects for users are not based solely on automated profiling.

5. PROCESSORS AND TRANSFERS

Telegram, payment providers, hosting suppliers, and VPN infrastructure providers are used for specific functions and receive only the data needed for those functions. Where processing involves another jurisdiction, available contractual and technical safeguards are applied subject to mandatory requirements.

6. RETENTION, SECURITY, AND LIABILITY

Retention is determined by the processing purpose, contractual relationship, security needs, and mandatory record-keeping periods. Data is deleted, destroyed, or anonymised when the applicable period ends.

The operator takes reasonable safeguards but, to the fullest extent permitted by law, is not responsible for independent third-party systems or events beyond reasonable control. Liability that cannot lawfully be limited remains unaffected.