Who we are
We are ONION TECH LIMITED, registered at 13 Freeland Park Lytchett House, Wareham Road, Poole, England, BH16 6FA. For the purposes of the EU/UK General Data Protection Regulation (GDPR), we are the data controllerof personal data processed through the Service, except where we act as a processor on behalf of a third party (in which case the third party's policy governs).
Scope
This Policy applies to information processed in connection with:
- the ZeeVPN Android application (
com.zeevpn.secure.proxy); - the ZeeVPN website at zeevpn.com and any subdomains we operate;
- support communications you send to us.
It does not cover websites, apps, or services that you access through the VPN, nor third-party services we integrate (we link to their policies in Section 08).
Information we collect
3.1 Information you provide
- Support communications. If you email us, the content of your message and your email address.
- Payment information (if you buy a Premium subscription). Payments are processed by Google Play Billing; we receive a purchase token and entitlement status, but we do not receive your card or bank details.
3.2 Information collected automatically by the App
- Device-bound identifier. When you continue as a guest, we generate an identifier tied to your device install. Used to deliver configuration, enforce free-tier limits, and provide support. Not your name, email, or government ID.
- Approximate geographic region. On launch (before any VPN tunnel is established) the App queries a public IP-geolocation service to display your origin location on the in-app map. Used client-side only.
- App configuration and preferences. Selected server, auto-connect, kill-switch, per-app routing, language, onboarding completion — stored locally on your device.
- Free-tier balance. Daily allowance, watches today, banked time, boost / pro-pass expirations — stored locally on your device only.
- VPN session events.Connect / disconnect events, selected server's country and city, time-to-connect, session duration, and disconnect reason, sent to Firebase Analytics.
- Ad events.Whether an interstitial / rewarded / app-open ad was shown, dismissed, or earned a reward, and the placement (e.g. “post_disconnect”).
- In-app update events. Update available / started / cancelled / failed / completed, and the version code offered.
- Diagnostic information. Crash reports, error codes, app version, OS version, device model, language, and screen views.
3.3 Information collected by third parties through the App
When ads are enabled, Google AdMob and its measurement partners may collect:
- your advertising ID (Android's resettable AAID);
- your IP address (visible to Google when ads are requested);
- coarse device and locale information;
- ad-interaction events (impressions, clicks).
This collection is governed by Google's policies and the consent you provide through the User Messaging Platform (UMP) prompt on first launch. You can reset your advertising ID and limit ad personalization in your device settings (Settings → Privacy → Ads).
3.4 What we do NOT collect
- We do not retain logs of the websites you visit, DNS queries you make, or the contents of any traffic carried over the VPN tunnel.
- We do not sell or rent personal information to third parties.
- We do not scan, monitor, or share the contents of your VPN traffic for advertising purposes.
How we use information
We use the information described above to:
- Provide the Service — establish VPN tunnels, deliver server configurations, enforce the free-tier daily allowance and ad caps, deliver in-app updates.
- Measure and improve the App — understand which features are used, diagnose crashes, prioritize improvements.
- Serve and measure ads (only when ads are enabled and you have consented where required).
- Communicate with you — respond to support requests and notify you of important changes.
- Prevent abuse and ensure security — detect fraudulent activity, abuse of the free tier, unauthorized access.
- Comply with law — fulfill our legal obligations and enforce our Terms.
Legal bases for processing (EU/UK users)
For users in the EU, EEA, UK, and Switzerland, we rely on the following lawful bases under GDPR Article 6:
| Activity | Legal basis |
|---|---|
| Providing the VPN service (tunnel, server config, allowance) | Performance of a contract (Art. 6(1)(b)) |
| Premium subscription billing | Performance of a contract (Art. 6(1)(b)) |
| Crash reporting, security, abuse prevention | Legitimate interests (Art. 6(1)(f)) |
| Product analytics (Firebase Analytics) | Consent (Art. 6(1)(a)) where required |
| Personalized advertising (AdMob) | Consent (Art. 6(1)(a)) collected via UMP |
| Non-personalized advertising | Legitimate interests (Art. 6(1)(f)) |
| Responding to legal requests | Legal obligation (Art. 6(1)(c)) |
You can withdraw your consent at any time via the in-app Settings → Privacy Options entry (where available) or by adjusting your device-level ad settings.
Data retention
| Category | Retention |
|---|---|
| Local app state (preferences, free-time balance) | On-device until you uninstall or clear app data |
| Guest device identifier | Until you uninstall, or up to 24 months of inactivity |
| Analytics events (Firebase) | Per Firebase default retention (currently up to 14 months) |
| Crash reports | Up to 90 days |
| Support correspondence | Up to 24 months after the case is closed |
| Billing records | As required by applicable tax and accounting law (typically 7 years) |
Where we have no continuing lawful basis to keep your data, we delete or anonymize it.
Third-party services
The App integrates the following third-party services. Each operates under its own privacy policy:
- Google Play Services & Google Play Billing — distribution, in-app purchases. policies.google.com/privacy
- Google AdMob — advertising. policies.google.com/technologies/ads
- Google User Messaging Platform (UMP) — consent capture. policies.google.com/privacy
- Firebase (Google LLC) — Analytics and Remote Config. firebase.google.com/support/privacy
- Google Play Core / In-App Updates — over-the-air updates.
These services may process your data in jurisdictions outside your own, including the United States. They are responsible for their own compliance with applicable data-protection law.
International data transfers
We are based in the United Kingdom. The third-party services listed in Section 08 process data in the United States and other countries. When personal data of EU/UK/EEA/Swiss users is transferred outside that region, we and our providers rely on appropriate safeguards such as the EU Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum, and adequacy decisions where available.
Your rights
Depending on where you live, you have the following rights regarding your personal data:
- Access — request a copy of the personal data we hold about you.
- Correction — ask us to correct inaccurate or incomplete data.
- Deletion — ask us to delete your data.
- Restriction — ask us to restrict processing in certain cases.
- Portability — receive your data in a portable format.
- Objection — object to processing based on our legitimate interests.
- Withdraw consent — where processing is based on consent.
- Opt out of sale/sharing for advertising (California, Colorado, Connecticut, Virginia and other US-state residents).
- Lodge a complaint with your local data-protection authority.
To exercise these rights, email us at hi@zeevpn.com. We will respond within the timeframes required by applicable law (typically 30 days under GDPR, 45 days under CCPA).
Children's privacy
ZeeVPN is intended for users 18 years of age or older. We do not knowingly collect personal data from anyone under 18. If you believe a person under 18 has provided us with personal data, contact us at hi@zeevpn.com and we will delete it.
Security
We use industry-standard technical and organizational measures to protect personal data, including encryption in transit (TLS), encrypted VPN tunnels, access controls, and audit logging. No internet service is 100% secure; we cannot guarantee absolute security and you use the Service at your own risk.
If we become aware of a personal-data breach that poses a risk to your rights, we will notify the relevant supervisory authority within the timeframe required by law (72 hours under GDPR) and, where required, notify you directly.
Changes to this Policy
We may update this Policy from time to time. When we make material changes we will update the “Last updated” date above and, where appropriate, provide additional notice (e.g., in-app notification or email to subscribers). Your continued use of the Service after the changes take effect constitutes acceptance of the revised Policy.
Contact
ONION TECH LIMITED
Email: hi@zeevpn.com
Address: 13 Freeland Park Lytchett House, Wareham Road, Poole, England, BH16 6FA
If you are in the EU/UK and feel we have not adequately addressed your concerns, you have the right to contact your national supervisory authority. A list of EU supervisory authorities is available at edpb.europa.eu/about-edpb/about-edpb/members_en.
