Privacy Policy

1. Who we are

Octopus Telecom Ltd is the controller responsible for the personal information described in this policy.

2. Scope of this policy

This policy applies to the Octopus VPN website at octopusvpn.uk, the Octopus Cloud VPN service, the Octopus VPN Windows client, Octopus VPN apps for Apple devices, VPN account profiles, our subscription-validation API and the VPN infrastructure operated by or for Octopus Telecom Ltd.

The implemented Apple apps covered by this policy are the macOS and iOS versions, including builds distributed for testing through TestFlight and versions that may be distributed through the App Store. Describing an app or distribution channel in this policy does not state that a particular version has already been publicly released, approved by Apple or made available in every country. References to Octopus VPN apps for Apple devices apply only where the described feature exists in the relevant build.

Separate websites, payment providers, app stores, DNS resolvers and third-party services have their own privacy policies. Their processing is governed by those policies where they act independently.

3. Information we process

Website information

When you visit our website, our hosting and security systems may process your IP address, request time, requested page, browser and device information, referring page and security events. This information is used to deliver the website, prevent abuse and investigate faults. Website analytics are described separately in section 7.

Account, order and support information

When you enquire about, order or receive support for a service, we may process your name, company name, postal address, email address, telephone number, account identifiers, order and invoice information, support correspondence and service preferences. Payment providers may process card or bank details under their own privacy policies; we do not need to receive your complete payment-card number.

Windows client and Octopus Cloud VPN

An imported .octvpn profile used by the Windows client can contain the server address, account name, connection settings, a pinned server identity and a private authentication key. The client stores the profile locally so that it can connect. The private authentication key is used on the device and is not sent to Octopus Telecom Ltd.

The Windows client may calculate connection duration and sent/received byte totals for the current session for display in the application. Displaying those counters does not by itself transmit them to us. The current Windows client does not contain advertising SDKs and does not send advertising identifiers to us.

Apple purchase and account information

For an App Store subscription, the macOS and iOS apps send our API the App Store receipt or equivalent signed Apple transaction information needed to validate access. This applies to the relevant TestFlight or App Store purchase environment. The information is transmitted over HTTPS and is used to confirm the product, transaction, environment, subscription status and entitlement period.

Our server stores the original transaction identifier, purchase environment, an internal account identifier, subscription expiry and the time of the latest validation. The current server does not store the raw App Store receipt or Apple's signed response in its database. Transaction and account identifiers are linked to a subscription and are not anonymous.

Locally displayed session information

The macOS and iOS apps can calculate and display the duration of the current VPN connection and sent/received traffic counters locally on the device. Displaying these values does not by itself send the displayed duration or traffic totals to us. This local display is separate from the limited server-side last-connection record described below.

Device and access information

For authentication, an app can create an app-specific device identifier and a cryptographic key pair. The server receives the device identifier and public key, links them to an internal account and uses them to authenticate access and enforce device limits. The corresponding private key stays on the device. The app-specific identifier is not an advertising identifier or the hardware serial number of the device.

Apps use protected operating-system storage, such as Apple Keychain where available, for private keys and access tokens. Our server stores token hashes, their relationship to the relevant account and their expiry times. Removing an app does not guarantee removal of all data from Keychain, device or cloud backups, or our servers; local-storage behaviour depends on the platform and the user's settings.

VPN account and connection information

Our API and VPN systems process access permissions, selected VPN server, connection identifiers, activation state, account and device relationships, expiry times, authentication results and limited diagnostic or security events. For the most recent VPN connection, the API database stores the connection's source IP address, connection time and selected VPN server, linked to the relevant internal account. This record supports account visibility, troubleshooting, abuse prevention and service security. Depending on the service and customer portal, aggregate bandwidth or connection-status information may also be processed or displayed.

For abuse prevention and service protection, we use request counters that can include hashed IP-derived identifiers. Hashing by itself does not make this information anonymous. Our infrastructure also processes the source IP address and network information necessary to establish, route and protect a VPN connection.

4. Apple subscriptions and purchase validation

Apple processes App Store purchases, trial periods, renewals, billing and cancellation of Apple subscriptions used with the macOS and iOS apps. TestFlight transactions normally use Apple's test purchase environment.

Through the subscription checkout, the app does not receive your Apple Account password, full payment-card or bank details, name or email address from Apple. We may receive contact details separately if you contact support or provide them through another Octopus Telecom channel.

Our API sends the receipt or equivalent signed transaction information from both macOS and iOS to Apple as needed to verify the purchase, environment and current subscription status. Apple acts independently for its App Store, TestFlight and account processing. See Apple's Privacy Policy.

Purchase validation can support restoration of access for the relevant product and account. We do not currently promise that one Apple subscription provides shared access across Mac and iPhone unless that capability is expressly confirmed in the relevant App Store product information.

5. Devices, keys and continued access

Device identifiers, public keys, internal account identifiers and token records allow us to recognise an authorised installation, restore eligible access and limit the number of devices using a subscription. They are service identifiers rather than advertising identifiers.

Current API access tokens can remain valid for up to one hour, and refresh tokens can remain valid for up to 30 days. Token expiry prevents further use of that token but does not necessarily mean that its database record is physically deleted at the same moment.

6. Connection, traffic and security data

Connection, authentication, error and security records may be generated to provide the service, enforce device limits, diagnose faults, investigate abuse and protect customers and infrastructure. Some of these records are linked to an internal account and device. Connection records may remain after a VPN session ends.

The limited last-connection record currently stored in the API database consists of the source IP address, connection time and selected VPN server linked to the internal account. It is distinct from the connection duration and sent/received traffic counters calculated locally for display by the app.

VPN infrastructure necessarily processes source and destination network addresses and packet-routing information while carrying traffic. We do not intentionally use the content of VPN traffic, browsing history, destination URLs or DNS-query contents to profile users or target advertising, and we do not sell browsing data. This does not mean that no technical, authentication, error or security log can ever exist.

Our current VPN configurations use Cloudflare's 1.1.1.1 recursive DNS resolver. DNS queries needed to resolve domain names are therefore sent to Cloudflare, which processes DNS request and associated network information under its own terms and privacy commitments. See Cloudflare's Privacy Policy. A different resolver may be used for a particular network or future configuration; the relevant resolver or network operator can process the information necessary to provide its service.

7. Advertising, analytics and permissions

The implemented macOS and iOS apps do not contain advertising SDKs or third-party analytics SDKs. We do not use subscription, internal-account or app-generated device identifiers to track users across other companies' apps and websites for advertising.

We do not claim collection of location, contacts, photos or advertising identifiers unless an implemented build actually requests and processes that information and this policy is updated accordingly. We will review this statement if a later app version adds an SDK, permission or data flow.

Website analytics are separate from application processing. The Octopus VPN website uses Google Analytics only through its website consent mechanism: analytics storage is denied by default and analytics is enabled when the visitor gives the applicable consent. When enabled, Google may process cookie or similar identifiers, IP and approximate-location information, browser and device details, referral information and pages viewed. See Google's Privacy Policy.

8. Why we process information

9. When we share information

We may share only the information necessary for the relevant purpose with:

• Apple, for App Store purchase and subscription processing and validation;
• Cloudflare, where its 1.1.1.1 service resolves DNS queries for a VPN connection;
• data-centre, hosting, network transit and infrastructure providers;
• customer-account, billing and payment-service providers;
• website analytics and security providers;
• professional advisers, auditors and insurers; and
• courts, regulators, law-enforcement bodies or other authorities where disclosure is legally required.

We do not sell personal information or VPN browsing data.

10. How long we keep information

We keep personal information only for as long as needed for the purpose for which it was collected, including contractual, security, accounting and legal requirements.

• Local profiles, private keys and tokens remain subject to operating-system storage, Keychain and backup behaviour. Uninstalling an app does not guarantee immediate removal of every local or backed-up item.
• Internal account, device, public-key and purchase records are kept while needed to provide or restore access, validate a subscription, enforce limits, protect the service, resolve subscription questions or comply with applicable obligations.
• Access tokens currently expire within up to one hour and refresh tokens within up to 30 days. Expiry does not necessarily cause immediate physical deletion of the related record.
• Connection, authentication, error and security records may remain after a session and are retained according to operational troubleshooting, abuse-prevention, security, dispute and legal needs. We do not state a universal automatic 30-day or 90-day deletion period where one has not been implemented and verified.
• The most recent connection's source IP address, time and selected VPN server remain linked to the internal account until replaced by a later connection or removed when no longer required for the operational, security, dispute or legal purposes described in this policy.
• Support records are retained while an enquiry is active and afterwards where reasonably needed to document its resolution.
• Account, invoice and transaction records are retained for the period required by applicable tax and accounting law, normally up to six years.
• Website analytics data is retained according to our configured analytics retention settings and the provider's applicable terms.

Backups and replicated systems may retain data beyond the live-system record until the relevant backup or recovery copy is overwritten or retired. We may keep information longer where necessary to establish, exercise or defend legal claims, resolve a dispute, prevent fraud or comply with a binding legal requirement.

11. International transfers

The current API database is hosted in Latvia. Current VPN gateways are located in Latvia and the United Kingdom, so connection and account-related information can be processed in those locations. We may add or replace gateway locations as the service develops; this policy will be updated where a change materially affects the processing described here.

Our service also uses suppliers in the United Kingdom, the European Economic Area and potentially other countries. Apple, Cloudflare, Google and other suppliers may process information in the countries described in their own privacy documentation. Where a restricted international transfer requires a legal transfer mechanism, we assess and use an applicable mechanism for that transfer. Contact us for information about a particular transfer.

12. How we protect information

We use measures designed to protect information against unauthorised access, alteration, disclosure and loss. These include encrypted VPN and administrative connections, key-based authentication, restricted service accounts, network access controls, least-privilege separation and security updates.

Your .octvpn file contains a private authentication key. Anyone who obtains that file may be able to use the associated VPN account. Keep it private, do not send it through untrusted channels, and contact us promptly if it is lost or disclosed so that its key can be revoked.

No system can be guaranteed completely secure. Please keep Windows, macOS, iOS, the Octopus VPN application and your other device software up to date.

13. Your privacy rights and deletion requests

Depending on where you live, you may have rights to request access to your personal information, correction, deletion, restriction, portability or objection to certain processing. Where processing relies on consent, you may withdraw that consent without affecting earlier lawful processing.

Your right to object: you may object at any time to processing based on our legitimate interests. You also have an absolute right to object to the use of your personal information for direct marketing.

To make a request, email info@octopustelecom.co.uk with the subject Octopus VPN privacy request. We may need to verify safely that you control the relevant purchase or device. We will not ask for your Apple Account password, private key or full bank or payment-card details.

Deletion of service data may end your access to Octopus VPN, but it does not cancel an Apple subscription. You must cancel an Apple subscription separately through your Apple Account settings. Restoring a purchase or using the service again may create new records that are necessary to provide access. The current app does not claim to include an in-app account-deletion button.

You also have the right to complain to the UK Information Commissioner's Office at ico.org.uk, or to the relevant supervisory authority in your country.

14. Children's privacy

Octopus VPN is not directed specifically at children, and we do not knowingly collect personal information from children in circumstances where parental authorisation is legally required. If you believe a child has provided personal information to us improperly, please contact us.

15. Changes to this policy

We may update this policy when our services, suppliers, applications or legal obligations change. We review the policy against implemented macOS and iOS behaviour before material changes or wider distribution rather than assuming that the two platforms behave identically. The latest version will be published on this page with a revised “Last updated” date. We will provide additional notice where a material change requires it.