Privacy Policy

Secure VPN Lock

⚠️ Prominent Disclosure: Data Collection & Retention

To provide VPN services and comply with legal requirements, our service provider (VPNWholesaler) retains the following connection data for up to 12 months:

  • IP Addresses: The IP address you use to connect to our servers.
  • Connection Timestamps: The exact time you connect and disconnect.
  • Bandwidth Usage: The amount of data transferred.

We do NOT log your browsing history, traffic content, or DNS queries sent through the VPN tunnel. However, we are NOT a "No Logs" service regarding connection metadata.

Last Updated: January 2025

Effective Date: January 2025

1. Introduction

Welcome to Secure VPN Lock ("we," "our," or "us"). We are committed to protecting your security and ensuring transparency about how your information is handled.

Company: Falalla FZ LTD

Contact Email: info@falalla.com

Website: https://falalla.com

App: Secure VPN Lock

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our VPN application. Please read this policy carefully.

2. Information We Collect

2.1 Data Stored Locally (On Your Device Only)

We store the following information locally on your device using encrypted storage:

  • Device Identifiers: UUID (generated locally, not tied to personal identity) - Used for user identification within the app
  • User Credentials: Auto-generated email address ({uuid}@auto.lockvpn.com), auto-generated password, VPN username/password, authentication tokens
  • VPN Status: Connection status (connected/disconnected) and connection timestamps
  • Server Preferences: Last connected server information, favorite servers, recent servers list
  • App Activity: Bandwidth usage statistics stored locally for speed calculation and connection metadata for connection maintenance

Important: All local data is stored on your device only and is NOT transmitted to our servers or any third parties (except as necessary for VPN functionality).

2.2 Data NOT Collected (Content & Activity)

We do NOT collect or monitor specific user activity within the VPN tunnel:

  • ❌ Browsing History: We do not see or store which websites you visit.
  • ❌ Traffic Content: We do not inspect or store the data (payload) sent/received over the VPN tunnel.
  • ❌ DNS Queries (VPN): DNS requests made through the VPN tunnel are not logged.
  • ❌ Personal Information: We do not require your name, phone number, or physical address to use the app.

Note: While we do not collect activity content, we DO retain connection metadata (IPs, timestamps) as detailed in the Prominent Disclosure above.

3. How We Use Your Information

We use the information we collect for the following purposes:

  • App Functionality: To provide VPN connection services, maintain your VPN connection, and improve user experience
  • User Identification: To identify you within the app using locally-generated UUID
  • Server Preferences: To remember your favorite servers and connection history
  • Connection Maintenance: To maintain and improve VPN connection stability

We do NOT use your information for:

  • ❌ Advertising or marketing
  • ❌ Selling to third parties
  • ❌ Tracking across apps or websites
  • ❌ Creating user profiles

4. Data Sharing and Third Parties

4.1 VPNWholesaler (VPN Service Provider)

To provide VPN functionality, we use VPNWholesaler (Webistics Holdings Ltd) as our VPN service provider. When you use our app, the following data is shared with VPNWholesaler:

Data Shared with VPNWholesaler:

  • User Registration Data: Auto-generated email address, password, country code (for account creation)
  • Login Credentials: For VPN authentication
  • Connection Metadata: To establish and maintain VPN tunnel

Data VPNWholesaler Collects and Retains:

⚠️ IMPORTANT: VPNWholesaler collects and retains the following data:

  • Bandwidth Usage Logs: Data transmitted (upload/download) during VPN sessions - Retained up to 12 months (for abuse detection, fair usage policy, and billing)
  • Connection Timestamps: When you connect and disconnect from VPN servers - Retained up to 12 months
  • Connection IP Addresses: IP address used to connect to VPN servers - Retained up to 12 months
  • DNS Access Logs: DNS requests that don't go through VPN (for technical issue resolution) - Retained 7 days (archived daily, deleted after 7 days)
  • App Installation Data: For affiliate tracking and installation validation
  • Access Logs: Billing, support, and CRM system logs (for fraud prevention)

Data VPNWholesaler Does NOT Collect:

  • ✅ Traffic Content: VPNWholesaler does NOT monitor or store data sent/received over VPN tunnel
  • ✅ Browsing History: Not logged
  • ✅ DNS Requests from VPN: DNS requests from VPN servers are NOT logged (only non-VPN DNS requests are logged)

VPNWholesaler Information:

Note: VPNWholesaler's privacy policy and logging policy apply to data they collect. We recommend reviewing their policies for complete information.

4.2 Other Third Parties

We do NOT share your data with:

  • ❌ Data brokers
  • ❌ Advertising networks (currently)
  • ❌ Analytics providers (currently disabled)
  • ❌ Any other third parties (except VPNWholesaler as necessary for VPN functionality)

5. Data Security

We implement appropriate security measures to protect your information:

  • Encryption in Transit: All data transmitted to VPNWholesaler is encrypted using WireGuard protocol
  • Encryption at Rest: Local data is stored using Android KeyStore/EncryptedStorage
  • Local Storage Only: Most data is stored locally on your device and never transmitted
  • No Server-Side Storage: We do not maintain servers that store your personal data

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

6. Data Retention

Local Data (On Your Device):

  • Retained until you uninstall the app or clear app data
  • You can delete local data at any time by uninstalling the app or clearing app data in Android Settings

VPNWholesaler Data:

  • Bandwidth logs, connection timestamps, IP addresses: Retained up to 12 months
  • DNS logs (non-VPN): Retained 7 days
  • Access logs (billing/support): Retained for fraud prevention (duration not specified)
  • App installation data: Retained for affiliate tracking (duration not specified)

For more information about VPNWholesaler's data retention, please refer to their Logging Policy.

7. Your Rights (GDPR/CCPA/UAE Data Protection Law)

Depending on your location, you may have the following rights regarding your personal data:

  • Right to Access: Request access to your personal data
  • Right to Rectification: Request correction of inaccurate data
  • Right to Erasure (Deletion): Request deletion of your personal data
  • Right to Data Portability: Request a copy of your data in a portable format
  • Right to Object: Object to processing of your data (where applicable)
  • Right to Restrict Processing: Request restriction of data processing (where applicable)

How to Exercise Your Rights:

To exercise any of these rights, please contact us:

For VPNWholesaler Data: To exercise your rights regarding data held by VPNWholesaler, please contact them directly:

We will respond to your request within 30 days (as required by GDPR).

8. Cross-Border Data Transfer

Your data may be transferred to and processed in countries outside your jurisdiction:

  • VPNWholesaler: Located in New Jersey, USA. Data is transferred to USA for VPN service functionality.
  • UAE Users: Data is transferred outside UAE to USA (VPNWholesaler servers).
  • EU Users: Data is transferred outside EEA to USA. VPNWholesaler has an EU Representative for GDPR compliance.

By using our app, you consent to the transfer of your information to these locations. We ensure that appropriate safeguards are in place to protect your data.

9. Children's Privacy

Our app is not intended for children under 18 years of age (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. If we become aware that we have collected personal information from a child, we will take steps to delete such information.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by:

  • Posting the new Privacy Policy on this page
  • Updating the "Last Updated" date at the top of this policy
  • Notifying you through the app (if significant changes)

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

11. Contact Us

If you have any questions about this Privacy Policy, please contact us: