Privacy Policy

1) Definitions and interpretation

In this Privacy Policy, the following definitions are used:

• Data / Personal Data: any information relating to an identified or identifiable individual that you submit to ClearFlow VPN, or that we collect in connection with your use of the Website and/or Services.
• Cookies: a small text file placed on your device by the Website when you visit certain parts of the Website and/or when you use certain features.
• Data Protection Laws: all applicable data protection laws, including the UK GDPR and the Data Protection Act 2018, and any applicable regulations (including the Privacy and Electronic Communications Regulations).
• UK GDPR: the UK General Data Protection Regulation.
• Services: ClearFlow VPN's VPN service and any related offerings you purchase or use (e.g., subscriptions, customer support, account portal, and related features).
• Website: https://clearflowvpn.com and any sub-domains, unless expressly excluded by their own terms.

Unless the context requires otherwise:

• the singular includes the plural and vice versa; and
• headings are for convenience and do not affect interpretation.

2) Scope of this Privacy Policy

This Privacy Policy applies to the actions of ClearFlow VPN and Users in relation to:

• our Website; and
• our Services to the extent personal data is processed in connection with them.

It does not extend to any websites that can be accessed from this Website, including (but not limited to) links we may provide to social media websites or other third-party sites.

3) Data controller

For the purposes of the Data Protection Laws, the data controller is Mooncrate Studios (trading as ClearFlow VPN).

4) Data we may collect

We may collect the following personal data from you:

• Name
• Contact information such as email address and telephone number
• Account information (e.g., account ID/username, subscription status)
• Billing and transaction information (e.g., invoices/receipts, payment status, transaction references)
• Communications and support information (messages you send us, support tickets)
• Website usage data (IP address and basic usage data collected through server logs and cookies)

Payment processing: We use Stripe to process payments. We do not store full payment card details on our servers. Stripe processes payment information under its own privacy policy.

5) No-logs policy (VPN usage data)

Note: Like most websites, our website hosting may process IP addresses in standard server logs for security and reliability. This is separate from VPN traffic and does not record your VPN activity.

6) How we collect data

We collect data in the following ways:

• Data is given to us by you, for example when you contact us, create an account, purchase a subscription, or request support; and
• Data is collected automatically, for example via cookies and basic server logs when you browse the Website.

7) Our use of data

We may use your data for the following reasons:

• internal record keeping and administration;
• creating and managing accounts and subscriptions;
• processing payments and providing invoices/receipts;
• providing customer support and responding to enquiries;
• maintaining and improving the Website and service reliability;
• security, fraud prevention, and abuse detection relating to the Website and account systems; and
• compliance with legal obligations (e.g., tax/accounting).

8) Lawful bases for processing

We process personal data under one or more of the following lawful bases:

• Contract: to provide the Services and manage your subscription.
• Legitimate interests: to operate, secure, and improve our Website and business, and to provide support (balanced against your rights).
• Legal obligation: to comply with applicable laws and regulations.
• Consent: where required for non-essential cookies and certain marketing communications (you can withdraw consent at any time).

9) Who we share data with

We may share your data with:

• our employees, agents, and/or professional advisers (to operate the business and obtain professional advice);
• Stripe (payment processing); and
• service providers who help us operate the Website and Services (e.g., hosting, email delivery, support tooling), acting as processors where applicable.

We do not sell your personal data. We may disclose data if required by law or to respond to lawful requests from competent authorities.

10) Keeping data secure

We use technical and organisational measures to safeguard your data, including access controls and secure hosting practices. If you suspect any misuse, loss, or unauthorised access to your data, please contact us immediately at [email protected].

11) Data retention

Unless a longer retention period is required or permitted by law, we will only hold your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the data be deleted. Even if we delete your data, it may persist on backup or archival media for legal, tax, or regulatory purposes for a limited period.

12) Your rights

You have the following rights in relation to your personal data:

• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to data portability
• Right to object
• Right to withdraw consent (where consent is the legal basis)

To exercise any of these rights, please contact [email protected]. If you are not satisfied with how we handle your complaint, you may refer your complaint to the UK data protection authority, the Information Commissioner's Office (ICO): ICO.

13) Links to other websites

This Website may provide links to other websites. We have no control over such websites and are not responsible for their content. This Privacy Policy does not extend to your use of such websites.

14) Changes of business ownership and control

Mooncrate Studios may, from time to time, expand or reduce our business and this may involve the sale and/or transfer of control of all or part of our business (including the ClearFlow VPN brand). Where relevant, user data may be transferred as part of that transaction, subject to appropriate protections.

15) Cookies

This Website may place and access certain cookies on your device. We use cookies to improve your experience of using the Website and to improve our products and services.

Before the Website places non-essential cookies on your device, you will be presented with a message requesting your consent. You may deny consent for non-essential cookies; however, certain features of the Website may not function fully as intended.

16) General

• You may not transfer any of your rights under this Privacy Policy to any other person.
• If any provision is found invalid, illegal, or unenforceable, it will be deemed deleted to the extent required, and the remaining provisions will continue in effect.
• This Privacy Policy is governed by the law of England and Wales, and disputes are subject to the exclusive jurisdiction of the English and Welsh courts.

17) Changes to this Privacy Policy

We reserve the right to change this Privacy Policy from time to time as we may deem necessary or as may be required by law. Any changes will be posted on the Website and will apply from the date of publication.