Personal data processing policy

Controller and scope

• The personal data controller is Сервис RUMI. For data enquiries, contact info@rumiserv.app or @Rumivpn_bot.
• This policy applies to RUMI in all its forms: rumivpn.com, rumiserv.app and codometkappn.net; the @Rumivpn_bot Telegram bot; the Telegram mini-app; the account; and the RUMI VPN Android app, Google Play ID com.rumivpn.app.
• The policy was developed under Russian Federal Law No. 152-FZ of 27 July 2006, “On Personal Data”.
• Using the website or bot signifies agreement with the policy as a whole. The Android app requests consent separately: before checking a subscription or connecting for the first time, it shows the data to be transferred. Until “Accept” is selected, the app does not contact the servers or enable VPN. Consent can be withdrawn in app settings. The current text (version 3, app 0.2.10) describes IP address and subscription request history storage, direct routes bypassing RUMI servers, and disclosure of website names to public resolvers. Users who accepted an earlier text see the notice again. This policy provides the full description.

Data processed

Account

• Telegram user ID, username, display name and interface language when signing in with Telegram;
• email address, one-time sign-in codes and an irreversible transformation of your password, if set, when signing in by email;
• internal service account ID.

Payments

• email address for the receipt;
• order details: plan, date, amount, payment method and payment service transaction ID;
• subscription status, validity and internal balance transaction history.

App and connection

• device identifier: the Android app sends an SHA-256 irreversible transformation of Android ID to count devices against the limit;
• device model and operating system version;
• number of connected devices and total data transferred during the billing period;
• source IP address, saved in the device record with model, OS version and app string, and in subscription request history with the app string, request time and account. Both records have been kept since the control panel started and are not deleted automatically.

Connection check. The Android app accesses Cloudflare’s cloudflare.com/cdn-cgi/trace to display your public IP address. Cloudflare receives your IP address and ordinary technical request information both before and after VPN is enabled. The controller does not collect this information.

Support requests include the request and subsequent correspondence. Technical server logs are described below.

Technical logs

The service equipment maintains four types of logs, including logs related to network activity:

• Web server log: IP address, request date and time, page URL, browser and device type. Kept for 14 days, then overwritten.
• Subscription delivery log: date and time, IP address, requested subscription URL, device ID and client app string. Used to enforce device limits and notify users when reached. Kept for seven days.
• Network-node connection log: routing software records connection date and time, destination address or domain name, port, protocol, selected route and your control-panel account ID. It does not log transferred content, but it does log destination addresses. There is currently no automatic clearing or rotation; entries accumulate and are deleted manually by the controller. The St Petersburg entry node is an exception: a service program counting blocked torrent connections periodically reads and clears its file. The log is used only to protect the service from abuse and troubleshoot faults.
• Telegram bot log: operational records that can include Telegram IDs and email addresses. It is not currently deleted automatically.

Earlier versions of this policy and the service agreement stated that network activity logs were not kept. This was incorrect and was corrected on 11 September 2026.

Traffic and website names

• Not all traffic passes through RUMI servers. Russian websites and services, local network addresses, torrents and apps you exclude connect directly from the device, bypassing the controller’s servers. Other traffic goes through the tunnel. Node connection logs cover only tunnelled traffic.
• Website names (DNS queries) go to public resolvers. Yandex (77.88.8.8) is first in the configuration and is not restricted to Russian domains: it receives names of all sites and services requested by apps, not just Russian ones. Requests go directly from the device, so Yandex sees your IP address. Cloudflare (1.1.1.1) and Google (8.8.8.8) receive requests through RUMI servers only if Yandex does not respond. This was checked against the configuration and same network core on 12 September 2026, but not on a phone. An earlier version incorrectly stated that Yandex received only Russian domains.
• DNS encryption depends on the app. RUMI for Android 0.2.10 and later uses DNS-over-HTTPS for these three resolvers; the change is in the app and did not change servers, their order or domain lists. Shared server templates were not changed, so earlier RUMI versions and third-party clients using those templates use ordinary unencrypted DNS; the controller has not verified how individual third-party clients apply the template. Queries to resolvers you specify yourself and the service lookup of RUMI server names are also unencrypted; the latter contains no information about sites you visit.
• The server removes the tunnel layer, determines the destination from the TLS server name, HTTP header or IP address, records a connection log line and forwards the stream in real time.
• TLS content, including HTTPS, remains encrypted between your app and the website. The controller has no keys, no certificates are installed on the device and only the server name is read from the connection.
• Unencrypted content passes through server memory without being written to logs, but is technically accessible to the controller’s equipment at that point, as with an ordinary internet provider.
• QUIC connections on UDP port 443 are blocked, so browsers fall back to TLS over TCP.

What we do not collect

• transmitted content: only technical connection records are logged; see the preceding section for encrypted and unencrypted traffic;
• bank card details: the payment service processes and stores these under PCI DSS; the controller receives only an anonymised payment-method indication and the last four card digits;
• passport details, telephone number or residential address;
• geolocation, contacts or microphone recordings;
• camera images: the app uses the camera only to scan a QR code on the device; frames are neither sent nor stored;
• the list of installed apps or your selected exclusions: these stay on the device and are not sent to the server.

Purposes of processing

• concluding and performing the agreement: creating the account, issuing the access key, tracking paid time and devices;
• accepting payments and sending receipts and service notifications;
• user support and handling claims;
• maintaining operation and security and detecting abuse;
• fulfilling duties under Russian law.

Legal grounds

• performing an agreement to which the user is a party;
• complying with legal obligations concerning cash registers and accounting;
• user consent expressed through use of the service and acceptance of the service agreement.

Retention periods

• account data: during the agreement and three years after termination when no deletion is requested, corresponding to the general limitation period for disputes. On request, the account is deleted within 30 days without waiting for the three years; only information the controller must retain by law remains;
• payment information and receipts: five years as required by law;
• web server log: 14 days; subscription delivery log: seven days;
• node connection logs and bot logs: no automatic clearing currently; deleted manually by the controller;
• device records and subscription request history in the control panel, including IP addresses: no automatic clearing; records have been kept since the panel started;
• database backups: the seven most recent daily copies, approximately one week. Separate archives sent to the controller’s service channel are not deleted automatically;
• after the retention periods, data is destroyed or anonymised.

Where data is stored

• The primary server, including database, websites, bot and control panel, is in Amsterdam, Netherlands (Timeweb LLP hosting).
• Network nodes are in the Netherlands, UK, Germany, Sweden and Russia (St Petersburg and Moscow), provided by The Constant Company LLC, JSC Timeweb, JSC IOT and Yandex.Cloud LLC.
• Database backups are stored on the primary server, nodes in the UK and Moscow, and the controller’s service Telegram channel.
• Processing therefore includes cross-border data transfers. By using the service, you agree to such transfers.
• The controller does not claim compliance with the requirement for initial recording of Russian citizens’ personal data in databases in Russia. This matter is being addressed and the document will be updated when the position changes.

Security measures

• Data exchange between your device, websites, app and servers uses TLS (HTTPS).
• Only the controller has access to servers and data; access uses keys and password login is disabled.
• Account passwords are stored as irreversible transformations, not in plaintext.
• Database backups have no separate encryption; protection relies on restricting access to servers and the controller’s service channel. An earlier version incorrectly stated otherwise.
• Yandex Metrica is connected on service websites; see Cookies and analytics below.

Transfers to third parties

• Yandex, when Yandex Metrica collects website statistics; data may include technical request, browser and device information, cookie identifiers and visit information. See Yandex’s privacy policy and Metrica cookie documentation;
• YooKassa (NKO YooMoney LLC) to process payments;
• the fiscal data operator to generate receipts;
• Unisender Go to deliver sign-in codes and access information;
• Telegram because the bot and mini-app operate on its platform;
• Cloudflare, Inc. for the app connection check described above;
• public DNS resolvers Yandex (77.88.8.8), Cloudflare (1.1.1.1) and Google (8.8.8.8), to the extent of requested domain names as described above;
• the hosting providers listed above, because they host the equipment;
• government authorities upon a request made under Russian law.

The controller does not sell personal data or transfer it for advertising. Google Play distributes the app but does not receive service user data from the controller. The app has no third-party analytics, advertising or crash-reporting libraries.

Cookies and analytics

• Light or dark theme selection is stored in the browser and is not itself sent to the controller.
• Yandex Metrica is connected on service websites to measure visits and transitions to checkout. It may use cookies and local storage containing browser identifiers; its cookie lifetimes depend on their purpose and are listed in Yandex’s documentation. Counter settings restrict data acceptance to allowed website addresses.
• To track the source of a visit, site code may store UTM tags, a Metrica identifier, referrer and entry domain in local storage and the rumi_payment_attribution cookie. The code sets a period of up to 30 days for these records. Available values may be passed between service websites and when opening the account or checkout.

Your rights and deletion

• You may obtain information about processing and request correction, blocking or destruction.
• You may request account deletion; the procedure, verification methods and timeframes are on the account deletion page.
• Withdrawing consent ends the provision of services because the agreement cannot be performed without processing. Information the controller must retain by law remains.
• You may appeal the controller’s actions to Roskomnadzor or a court.

Contact and changes

• For personal data enquiries: info@rumiserv.app or @Rumivpn_bot.
• The controller responds within 10 working days of receipt.
• The controller may amend the policy; a new version takes effect upon publication.
• The current version is always available at rumivpn.com/legal/privacy.

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