Personal Data Processing Policy

Last updated: February 23, 2026 This Personal Data Processing Policy explains how 'LOKKA TEAM' LLC (the 'Company', 'we', 'us' or 'our') processes personal data when you use the LOKKA services (the 'Services'). This policy supplements our Privacy Policy; if there is a conflict, the Privacy Policy prevails. 1. Controller and contacts Legal entity: 'LOKKA TEAM' LLC Registered address: Nar Dos 2, Yerevan, Armenia Support: support@lokkavpn.com 2. What data we process We may process data you provide (email, name, account identifiers), support correspondence, subscription/payment status and transaction identifiers, and technical data collected automatically (IP address, device identifiers, app version, interface language, approximate location by IP). To operate the VPN, we also process limited connection logs (connect/disconnect timestamps, server/protocol identifiers, basic performance/diagnostic data, aggregated traffic volume). We do not log the content of your internet traffic. 3. Purposes - providing and administering the Services and your account; - customer support and service-related notices; - security, abuse prevention, and fraud detection; - performance monitoring and improving reliability; - legal compliance and dispute resolution. 4. Legal bases (GDPR where applicable) Consent, contract performance, legal obligations, and legitimate interests (security and service improvement). 5. Sharing We share data only as necessary with infrastructure providers, app stores and payment processors, and when required by law or in corporate transactions, under appropriate confidentiality and security obligations. We do not sell personal data. 6. Retention Account data is kept while the account is active and deleted/anonymized after deletion unless longer retention is required by law. Connection logs are kept up to 90 days for security and troubleshooting unless legally required otherwise. Payment records may be retained longer as required by accounting/tax rules. 7. Your rights Depending on your jurisdiction, you may have rights to access, correct, delete, restrict processing, portability, object, and withdraw consent. Contact us at support@lokkavpn.com. 8. Security and updates We apply reasonable security measures and may update this policy from time to time; the 'Last updated' date will change accordingly.