HawkwireVPN Privacy Policy

PRIVACY POLICY Last updated: 04/07/26 This Privacy Policy explains how HawkwireVPN, operated by Trevor Render, trading as HawkwireVPN, a sole trader with a business address at 3 Ash Grove, Riccall, York YO19 6NW ("HawkwireVPN", "we", "us", "our"), collects, uses, and protects your personal data. We are registered with the UK Information Commissioner's Office (ICO), registration reference ZC186939. This policy should be read alongside our Terms of Service, available at https://www.hawkwirevpn.co.uk/terms WHO WE ARE HawkwireVPN is a VPN reseller. We do not own or operate our own VPN server network. Your account, billing, and support are managed directly by us; the underlying VPN connection runs on infrastructure supplied by a third-party infrastructure provider. This affects what data we can and cannot see, as explained below. WHAT DATA WE COLLECT We collect the following categories of personal data: Account data — the email address you provide when signing up, and your chosen username/password. Billing data — payments are processed by Stripe, our payment processor. We do not store your full card number, expiry date, or CVC ourselves — Stripe handles this directly and securely. We retain only what Stripe provides us for billing records, such as transaction confirmations and, where applicable, the last 4 digits of your card. Support correspondence — anything you send us via email, such as support requests or complaints, and our replies. Website usage data — standard technical data such as IP address and browser type, collected when you visit our website (not while connected to the VPN), for example via cookies or analytics tools, if used. We do not collect or require any government ID, and we do not ask for more personal information than is needed to provide the service. WHAT WE DO NOT COLLECT HawkwireVPN does not monitor, log, or store your browsing activity, connection history, or VPN traffic on our own systems. We are a reseller, and the VPN connection itself is carried over a third-party infrastructure provider's network, not our own servers. We have not independently verified that provider's internal logging practices through third-party audit, and we make no representation as to whether connection-level logs are or are not retained at the infrastructure level. If logging practices at the infrastructure level matter to you, please contact us before subscribing and we'll share what we know. HOW WE USE YOUR DATA We use the data we collect to:

Create and manage your account Process payments and subscription renewals Provide customer support and respond to complaints Meet our legal and accounting obligations Improve our website and service

We do not sell your personal data to third parties, and we do not use it for targeted advertising. LEGAL BASIS FOR PROCESSING Under UK GDPR, we process your data on the following bases:

Contract — to provide the service you've subscribed to Legal obligation — for example, retaining billing records for tax purposes Legitimate interests — for example, responding to support enquiries and keeping our service secure

WHO WE SHARE DATA WITH We share data with:

Stripe (payment processing), to process your subscription payments — see Stripe's own privacy policy at https://stripe.com/gb/privacy for how they handle your payment data Our third-party VPN infrastructure provider, to the extent necessary to provision your VPN access Professional advisers (e.g. accountant), where necessary for our legal and tax obligations Law enforcement or regulators, if we are legally required to disclose information

We do not sell or rent your personal data to third parties for marketing purposes. INTERNATIONAL TRANSFERS Stripe, our payment processor, may process data outside the UK. Stripe participates in relevant data protection frameworks and provides its own safeguards for international transfers — see Stripe's privacy policy for details. Where any of our other providers are based outside the UK, we take reasonable steps to ensure your data is protected to a standard consistent with UK data protection law. HOW LONG WE KEEP YOUR DATA We retain account and billing data for as long as your account is active, and for a reasonable period afterward to meet our legal and accounting obligations (typically up to 6 years for financial records, in line with HMRC requirements). Support correspondence is retained for as long as reasonably necessary to resolve your query and for our records. YOUR RIGHTS Under UK GDPR, you have the right to:

Access the personal data we hold about you Request correction of inaccurate data Request deletion of your data, subject to our legal retention obligations Object to or restrict certain processing Request a copy of your data in a portable format Withdraw consent, where processing is based on consent

To exercise any of these rights, contact us at support@hawkwirevpn.co.uk. We will respond within one month. If you are unhappy with how we've handled your data, you have the right to complain to the ICO at ico.org.uk. COOKIES Our website may use cookies or similar technologies for basic functionality and, where applicable, analytics. You can control cookies through your browser settings. This does not affect data handling while connected to the VPN itself, which is covered separately above. CHILDREN'S PRIVACY HawkwireVPN is not intended for use by anyone under 18. We do not knowingly collect personal data from children. CHANGES TO THIS POLICY We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or via a notice on our website before the changes take effect. CONTACT Trevor Render, trading as HawkwireVPN 3 Ash Grove, Riccall, York YO19 6NW support@hawkwirevpn.co.uk ICO registration reference: ZC186939