V-Turbo

V-Turbo Privacy Policy

Effective from 16 июня 2026

This Privacy Policy explains how TOP HOUSE SOLUTIONS S.R.L., a company organized under the laws of Romania, with its registered office at Sector 1, Sos Chitila Nr.3, Parter, Biroul 6, Bucharest 010011 ("V-Turbo", "we", "us", or "our"), collects, uses, and protects information when you use the V-Turbo application and VPN service, the Telegram Mini App and bot, and related websites (together, the "Service").

V-Turbo is a VPN service. **We do not log the contents of your traffic or the websites and services you visit.** We do, however, process the limited account, device, billing, and operational data described below, which is necessary to provide the Service. Please read this Policy carefully.

1. Who Is the Data Controller

The data controller responsible for your personal data is TOP HOUSE SOLUTIONS S.R.L., Sector 1, Sos Chitila Nr.3, Parter, Biroul 6, Bucharest 010011, Romania.

For any privacy-related request, please use the in-app support chat (Settings → Support) in your account. This is our primary channel for handling your requests.

2. What Data We Collect

2.1. Account data

  • **Email address** (for email/password accounts, and where provided through Sign in with Apple or Telegram).
  • **Password** (stored only as a salted hash; we never store your password in plain text).
  • **Display name** and **avatar** (if you set one or if provided by Apple/Telegram at sign-in).
  • **Language** and **country/region** preferences.
  • **Authentication provider data**: when you sign in with Apple or Telegram, we store the provider identifier (e.g. the Apple subject identifier or the Telegram ID) and a snapshot of the basic profile the provider returns.

2.2. Device data

  • **Device identifier (HWID)**: a per-device hardware identifier (on iOS, the identifier-for-vendor; otherwise a locally generated identifier).
  • **Device model, operating-system version, platform, and app version**.
  • **Device name** (as set on your device).

We use this to register and manage your devices, enforce device limits, and prevent abuse of free trials.

2.3. Session and security data

  • **Session tokens** for keeping you signed in.
  • **IP address and user agent** associated with a sign-in session (used for security and session management).
  • **Sign-in timestamps**.

2.4. Subscription and usage data

  • **Subscription details**: plan, status, start and end dates, device limit, traffic allowance.
  • **Traffic usage volume (in bytes)** consumed under your subscription, used to enforce your allowance.
  • **VPN session logs (metadata only)**: the start and stop time and duration of each VPN connection session, the node/server used, the device identifier, and the reason a session ended (for example, you disconnected, the connection dropped, or it expired). These are operational metadata; **they do not include the content of your traffic or the destinations you connect to.**

2.5. Push notification data

  • **Push token (APNs token on iOS / FCM token on Android)**, platform, and app version, used to deliver notifications you have enabled.

2.6. Support data

  • **Support chat messages** you send to us, including text messages and, if you send a voice message, the audio recording and its **text transcript** (the transcript is generated using a speech-to-text provider, see Section 6).
  • Basic metadata about the support conversation (topic, status, language, timestamps).

2.7. Diagnostics

  • If you keep diagnostics enabled, we collect **anonymous crash and error reports** (error message, stack trace, app version, and similar technical information) to fix bugs. These reports are designed not to include personal identifiers. You can disable diagnostics in Settings.
  • Connection-quality measurements (latency, speed, jitter) are performed on your device to choose and display the best connection.

3. What We Do NOT Collect or Log

We do **not** log, store, or sell:

  • the websites or services you visit, your DNS queries, or your browsing history;
  • the contents of your network traffic;
  • the IP addresses of the destinations you connect to.

The only traffic-related information we keep is **aggregate usage volume (bytes)** and **connection session metadata** (time, duration, chosen node), as described in Section 2.4, which we need to operate the Service and enforce your plan.

4. How We Use Your Data (Purposes)

We process your data to:

  • create and manage your account and authenticate you;
  • provide the VPN Service, select and operate connections, and manage your devices;
  • enforce subscription limits (traffic allowance, device limits) and operate free trials;
  • process and verify purchases made through Apple or Telegram and keep your subscription up to date;
  • deliver notifications you have enabled;
  • provide customer support, including transcribing voice messages you send;
  • maintain the security and integrity of the Service and prevent fraud and abuse;
  • diagnose and fix technical problems (if diagnostics are enabled);
  • comply with legal obligations.

5. Legal Bases for Processing

Where the EU/EEA General Data Protection Regulation (GDPR) or similar laws apply, we rely on the following legal bases:

  • **Performance of a contract** (providing the Service you signed up for): account, device, subscription, usage, and connection-metadata processing.
  • **Legitimate interests**: security, fraud and abuse prevention, enforcing limits, and improving reliability.
  • **Consent**: optional diagnostics/crash reporting and optional notifications. You can withdraw consent at any time in Settings.
  • **Legal obligation**: where we are required to retain or disclose data by law.

6. Third Parties and International Transfers

We share data with the following categories of third parties only as needed to provide the Service:

  • **Apple** - for in-app purchases and purchase verification, Sign in with Apple, and push notifications via APNs. Apple processes your payment and the related Apple ID information; we do not receive your card data.
  • **Telegram** - when you sign in through Telegram, use the Telegram bot or Mini App, or pay with Telegram Stars. Telegram processes the related Telegram account and payment information.
  • **VPN infrastructure (Remnawave)** - our self-hosted VPN management system, which provisions your access and accounts for your traffic usage and connection times. It receives your subscription identifier, device identifier, traffic allowance, and connection/usage metadata.
  • **Hosting providers** - our VPN nodes and servers run on third-party hosting infrastructure (such as cloud/VPS providers in various countries). Your traffic passes through these servers in encrypted form so that you can reach the internet.
  • **Speech-to-text provider (OpenAI)** - only when you send a voice message in support chat, the audio is sent to this provider to generate a text transcript.
  • **Error-monitoring** - on our website and backend, crash/error reports may be processed by an error-monitoring provider with personal identifiers stripped. The mobile app sends crash/error reports to our own backend only.

Because our nodes and some providers are located in different countries, your data may be transferred to and processed in countries other than your own. Where required, we rely on appropriate safeguards (such as standard contractual clauses) for international transfers.

We do **not** sell your personal data and do not use advertising or tracking SDKs in the app.

7. Data Retention

  • **Account data** is kept while your account is active.
  • **Session tokens** expire and are removed after their validity period.
  • **VPN session metadata and usage volume** are kept for as long as needed to operate the Service, support, and comply with legal obligations.
  • **Support messages, voice recordings, and transcripts** are kept to provide and improve support.
  • **Trial device identifiers** are kept to prevent repeated trials on the same device.
  • When you delete your account, we delete or anonymize your personal data within a reasonable period (target: within 30 days), except where we must retain certain records to comply with law.

8. Security

We use technical and organizational measures to protect your data, including encryption of the VPN tunnel, hashing of passwords, encrypted storage of sensitive credentials, and access controls. No method of transmission or storage is completely secure, but we work to protect your information against unauthorized access, alteration, or destruction.

9. Your Rights

Depending on your jurisdiction, you may have the right to:

  • access the personal data we hold about you;
  • correct inaccurate data;
  • delete your data ("right to be forgotten");
  • export/port your data;
  • restrict or object to certain processing;
  • withdraw consent for optional processing (such as diagnostics or notifications).

To exercise these rights, use the in-app support chat (Settings → Support) in your account. We may need to verify your identity before acting on a request.

10. Account Deletion

You can request deletion of your account and associated personal data through the app (Settings) or by contacting support. Upon deletion, your personal data is removed or anonymized within a reasonable period (target: within 30 days), subject to any legal retention obligations. Note that purchases processed by Apple or Telegram are also subject to those providers' records and policies.

11. Children

The Service is not directed to children and is intended for users who are at least 16 years old (or the age of majority in their jurisdiction). We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us so we can delete it.

12. Payment Data

All payments are processed by **Apple** (iOS in-app purchases) or **Telegram** (Telegram Stars). We do not collect, see, or store your full payment card details. We receive only the confirmation and the information needed to activate or verify your subscription.

13. Cookies and Identifiers

The mobile app uses local on-device storage and a device identifier (HWID) for the operational purposes described above, not for advertising or cross-app tracking. The app's privacy manifest declares **no tracking** and no advertising data collection. Our websites may use only essential cookies/storage needed for the site to function.

14. Changes to This Policy

We may update this Policy from time to time. When we make material changes, we will provide reasonable notice (for example, in the app or on the website). The current version is always available in the app.

15. Contact

For privacy questions or to exercise your rights, please contact us through the in-app support chat (Settings → Support) in your account. This is our primary channel for privacy and data-protection requests, including access, deletion, and export of your data.

Support is provided with the help of artificial intelligence (AI) and is escalated to human company managers when needed.

  • Privacy and support: in-app support chat (Settings → Support)
  • Data controller (for formal/legal correspondence only): TOP HOUSE SOLUTIONS S.R.L., Bucharest, Romania, info@tophouse.sale
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