Last updated: December 23, 2025
π’ Data Controller
Your data is controlled by ATHENA AI LLP, a company registered in the Republic of Kazakhstan.
BIN: 250940001338
π¬π§ UK GDPR Compliance
This policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are committed to protecting your personal data and respecting your privacy rights.
π‘οΈ Strict No-Logs Policy
Holdem VPN operates under a strict no-logs policy. We do not collect, store, or monitor your browsing activity, connection logs, IP addresses, or any data that could identify you or your online behavior.
π No-Logs Policy
Holdem VPN does NOT collect, store, or have the ability to provide:
β We do NOT log
- β’ Your IP address
- β’ Connection timestamps
- β’ Websites visited
- β’ DNS queries
- β’ Session bandwidth
- β’ Traffic content
β
Technical Implementation
- β’ Xray-core with loglevel: warning
- β’ System error logs only
- β’ No access logs on VPN servers
- β’ Client UUID not linked to identity on server
π‘ What This Means
Even if a VPN server were seized by law enforcement or accessed by malicious actors, it would be impossible to find: connection history, websites visited, user IP addresses, or any data that could identify a specific person and their activity.
1. Data We Collect
1.1. Account Data
- Email address β For authentication and communication
- Account creation date β For service management
- Referral code β If you joined via referral link
1.2. Usage Data (Aggregate Only)
- Total traffic volume β To enforce fair usage limits (aggregate only, not per-session)
- Device type β For compatibility optimization (optional)
1.3. What We DON'T Collect
- β Browsing history
- β DNS queries
- β Traffic content
- β Original IP addresses
- β Connection timestamps
- β Session logs linking you to specific websites
2. How We Use Your Data
- Provide and maintain the VPN service
- Send important service notifications
- Prevent abuse and fraud
- Improve service quality
- Process referral rewards
3. Data Storage & Security
3.1. Your data is stored on secure servers in the European Union (Germany), complying with GDPR requirements.
3.2. We use industry-standard encryption for all data transfers.
3.3. VPN servers use VLESS + Reality protocol, providing strong encryption and traffic obfuscation.
4. Third-Party Services
We use the following third-party services:
- TipTop Pay β Payment processing (tiptoppay.kz)
- Hetzner Cloud β VPN server infrastructure (Germany)
- Vercel β Web application hosting
- Brevo β Email delivery service
- Cloudflare β Security and CAPTCHA
5. Lawful Basis for Processing
Under UK GDPR, we process your data based on:
- Contract β To provide the VPN service you requested (Article 6(1)(b))
- Consent β For marketing emails, with your explicit opt-in (Article 6(1)(a))
- Legitimate Interest β For fraud prevention and service improvement (Article 6(1)(f))
- Legal Obligation β To comply with applicable laws (Article 6(1)(c))
6. Your Rights Under UK GDPR
You have the right to:
- Access β Request a copy of your personal data (Article 15)
- Rectification β Correct inaccurate data (Article 16)
- Erasure β Request deletion of your data (Article 17)
- Restrict Processing β Limit how we use your data (Article 18)
- Data Portability β Receive your data in a portable format (Article 20)
- Object β Object to processing based on legitimate interests (Article 21)
- Withdraw Consent β Withdraw consent at any time for consent-based processing
Exercise your rights: Visit our Data Request page or email privacy@holdemvpn.app
We will respond within 30 days (extendable to 3 months for complex requests).
7. Cookies
We use essential cookies only for authentication purposes. No tracking or advertising cookies are used.
8. Data Retention
Account data is retained while your account is active. Upon account deletion, your personal data is removed within 30 days. Anonymous aggregate statistics may be retained indefinitely.
9. International Transfers
Your data may be transferred to and processed in the European Union (Germany) where our VPN servers are located. The EU provides adequate protection under UK GDPR adequacy regulations. For transfers to other countries, we use Standard Contractual Clauses approved by the ICO.
10. Marketing Communications
We only send marketing emails if you have explicitly opted in during registration. You can withdraw your consent at any time by:
- Clicking "Unsubscribe" in any marketing email
- Visiting your account settings
- Contacting us at privacy@holdemvpn.app
π Transparency Report & Warrant Canary
Last updated: December 23, 2025
π 2025 Request Statistics:
π€ Warrant Canary
As of December 23, 2025:
- β
Holdem VPN has NOT received any requests for user data from government authorities
- β
Holdem VPN has NOT received any search warrants or server seizure orders
- β
Holdem VPN has NOT received any gag orders
- β
Holdem VPN has NOT received any National Security Letters (NSL)
- β
Holdem VPN has NOT disclosed any data to third parties under compulsion
This statement is updated quarterly. If this statement is not updated for more than 90 days or disappears, it may indicate receipt of a legal request.
11. Complaints
If you're not satisfied with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
Information Commissioner's Office (ICO)
Website: ico.org.uk
Phone: 0303 123 1113
12. Contact Us
For privacy-related inquiries:
ATHENA AI LLP
- BIN: 250940001338
- Privacy Email: privacy@holdemvpn.app
- General Support: support@holdemvpn.app
- Abuse Reports: abuse@holdemvpn.app
- Data Requests: Submit online