Privacy Policy

Liora Technologies International

Effective Date: June 8, 2025

This Privacy Policy (hereinafter, the “Policy”) describes how Liora Technologies International (“Liora Technologies,” “we,” “us,” or “our”) — a legal entity registered in Georgia as an individual entrepreneur, with a representative office in the USA — collects, uses, processes, and discloses information about you in connection with your use of our services. This includes LioraVPN, LioraCloud (server services, domains, CDNs, and other server and network services), LioraMail (a future Liora Technologies International service), as well as any other existing or future internet services provided by Liora Technologies International (collectively referred to as “Services”).

We recognize the fundamental importance of your privacy and are committed to protecting your personal information. This Policy is designed to provide you with comprehensive and transparent information about our data processing practices.

1. Our Approach to Privacy and Data Protection

Liora Technologies International is committed to the principles of data privacy and network security. We design our Services with data minimization in mind, striving to ensure maximum protection of your privacy while maintaining operational efficiency and compliance with legal requirements.

Important: All our technical infrastructure, including servers that store important data and potentially anonymized user data, is hosted in Switzerland. The management and protection of our entire network policy and infrastructure security, including handling user data, strictly comply with Swiss law, which is renowned for its high data protection standards. We operate exclusively in accordance with Swiss law regarding data processing and storage. Simultaneously, as a legal entity registered in Georgia, we also comply with applicable Georgian laws that do not conflict with our data protection obligations under Swiss law.

2. Information We Collect

To provide, maintain, and improve our Services, and to ensure their security and stability, we may collect certain information. We do so by adhering to the principle of data minimization, sufficient to achieve the stated purposes.

2.1. Information you provide to us directly:

When creating an account: To register and manage your account with our Services (LioraVPN, LioraCloud, LioraMail), we may request your email address. This is necessary for authentication, communication with you, and providing support.
When making payments: To process transactions for our Services, we use third-party payment providers. We do not collect or store your credit card information or other sensitive payment data. Information you provide to payment providers is governed by their privacy policies. We may receive limited information from payment providers, such as subscription type, payment status, and anonymized data necessary to confirm your payment and manage your subscription.
When contacting customer support: If you contact our customer support, we may collect information you provide during communication (e.g., via email or ticket system), including your email address and the content of your inquiry. This allows us to effectively answer your questions and resolve issues.
Voluntary information: You may voluntarily provide us with additional information, such as feedback about our Services, by participating in surveys or promotions.

2.2. Information collected automatically (non-identifiable and aggregated data, connection data):

We strive not to collect data that can be used for your direct identification. However, to ensure the functionality, security, and optimization of our Services, we may collect the following types of data:

Service usage data (aggregated and anonymized): To assess network performance, plan bandwidth, optimize server resources, and combat abuse, we may collect aggregated and anonymized data, such as the total volume of data transmitted through our servers, the number of simultaneous connections to a specific server, or statistics on the use of certain Service features. This data is not linked to specific users or their IP addresses.
Connection data (for LioraVPN): To ensure the stability, security, and prevent abuse of LioraVPN, we may log limited information about connection sessions. This may include:
- Connection session start and end times.
- Selected VPN server location.
- Volume of data transferred (inbound/outbound) within the session. Connection data does not contain information about your online activities, such as website Browse history, destination IP addresses, DNS queries, or the content of your traffic. This data is used solely for monitoring network performance, identifying anomalies related to Service abuse, and ensuring connection reliability. This data is stored for a limited time necessary for the stated purposes and is subject to strict security measures in accordance with Swiss law.
Diagnostic data (with your consent): In case of technical issues, we may offer you the option to send us anonymous diagnostic reports. These reports may include information about application crashes, performance, or errors. This data does not contain personally identifiable information and is used exclusively for diagnosing and improving the stability and functionality of our Services. You always have the option to decline sending such reports.
Device information (anonymized): To optimize Services for various platforms, we may receive general information about your device type, operating system, and application version, but without any unique identifiers linked to your identity.

2.3. Information we do not collect:

We deliberately do not collect or store the following types of information:

Your original IP addresses used to connect to our Services (except for temporary processing to establish a connection, which is not retained after it concludes).
DNS queries.
Website Browse history or other information related to your specific online activity.
The content of your encrypted traffic.
Any other information that could link you to your specific online activity beyond the connection data specified in Section 2.2.

3. How We Use the Collected Information

We use the collected information exclusively for the following purposes:

Providing and managing Services: To grant you access to our Services, manage your account, process payments, and ensure uninterrupted operation.
User support: To effectively respond to your inquiries, resolve technical issues, and provide necessary assistance.
Improving and developing Services: To analyze anonymized and aggregated data, as well as connection data (for LioraVPN), to understand the usage of our Services, identify trends, improve functionality, develop new features, and optimize performance.
Security and abuse prevention: To detect and prevent fraudulent activities, Service abuse, violations of our Terms of Service, and to ensure the integrity of our network.
Legal compliance: To fulfill our legal obligations in accordance with Swiss and Georgian law, as applicable depending on the context.

4. Disclosure of Information to Third Parties

We do not sell, trade, or otherwise transfer your personal information to third parties, except where strictly necessary for providing our Services, fulfilling legal obligations, and only in accordance with Swiss law.

Third-party service providers: We may engage third-party service providers to perform certain functions on our behalf, such as payment processing, hosting, analytics (anonymized data only), or customer support. These service providers have access only to the information necessary for them to perform their specific functions and are obligated to maintain the confidentiality of this information. We carefully select our partners and enter into agreements with them that obligate them to comply with high data security standards consistent with Swiss law.
Law enforcement and government requests (force majeure): In exceptional circumstances, we may be required to disclose certain information in response to a lawful and binding request from law enforcement or government authorities. Important: Any such request will be handled strictly in accordance with Swiss law, which requires a reasoned judicial order and clear legal grounds. As our policy aims to minimize the collection of identifiable data, we do not possess data about your online activities (such as website Browse history or destination IP addresses) that could be transmitted. We will challenge any requests that do not comply with the strict requirements of Swiss law. We also comply with Georgian law to the extent that it does not conflict with our data protection obligations under Swiss law.
Merger, acquisition, or asset sale: In the event of a merger, acquisition, reorganization, or sale of all or part of our assets, your information may be transferred as part of such a transaction. We commit to notifying you of any such changes in ownership or control of your personal information.

5. Data Transfer

Since all our technical infrastructure, including servers with important data and potentially anonymized user data, is hosted in **Switzerland**, primary data processing occurs within Switzerland. Data transfer outside of Switzerland takes place only when necessary (e.g., for interaction with third-party payment providers) and only under the condition that an adequate level of data protection is ensured, consistent with Swiss law.

6. Data Retention Period

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by law.

Account data: We store your account data (e.g., email address) as long as your account is active. You can delete your account at any time, after which your personal information will be deleted or anonymized, except where we are obliged to retain it in accordance with Swiss or Georgian law (e.g., for financial reporting).
Connection data (for LioraVPN): The limited connection data mentioned in Section 2.2 is stored for a limited period necessary to ensure Service stability and security, after which it is deleted or anonymized. The exact retention period is determined by operational needs and compliance with Swiss law.
Anonymized and aggregated data: Anonymized, aggregated, or statistical data may be retained indefinitely for analytics and Service improvement purposes.
Backup: We may perform data backups to ensure the continuity of Services. Data in backups is also protected in accordance with this Privacy Policy and Swiss law.

7. Data Security

We implement all reasonable and technically feasible measures to protect your information from unauthorized access, use, alteration, or destruction. Our infrastructure and security policies comply with the strict standards stipulated by Swiss law, and include:

Encryption: Use of advanced encryption protocols to protect data during transmission and storage.
Access control: Strict access control to data, based on the principle of least privilege.
Physical security: Secure data centers in Switzerland with multi-level physical security systems.
Administrative and organizational measures: Regular staff training, internal policies, and procedures aimed at ensuring data security.
Regular security audits: Conducting regular audits and penetration testing to identify and address vulnerabilities.

Despite our comprehensive efforts, no data transmission over the internet or storage system can be guaranteed 100% secure. Therefore, while we strive to protect your information to the maximum extent, we cannot guarantee absolute security.

8. Your Rights

In accordance with Swiss law and applicable data protection regulations, you have the following rights regarding your personal information:

Right of access: You have the right to request confirmation of whether we are processing your personal data, and if so, to request access to it.
Right to rectification: You have the right to request the correction of inaccurate or incomplete data about you.
Right to erasure ("right to be forgotten"): You have the right to request the deletion of your personal information in certain circumstances, provided that it does not conflict with our legal obligations to retain data.
Right to restriction of processing: You have the right to request the restriction of processing your data in certain circumstances.
Right to object to processing: You have the right to object to the processing of your data in certain circumstances.
Right to data portability: You have the right to receive a copy of your data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller, if technically feasible.
Right to withdraw consent: If the processing of your data is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us at the email address provided in Section 11.

9. LioraVPN, LioraCloud, LioraMail, and Future Services

LioraVPN: We design LioraVPN with a data minimization philosophy. As stated in Section 2.2, we do not keep logs of your online activity, such as website Browse history, destination IP addresses, or the content of your traffic. We log limited connection data solely for the purposes of ensuring Service stability, security, and preventing Service abuse.
LioraCloud: LioraCloud services, including server services, domains, and CDNs, are also designed with privacy and security in mind. We implement strict security measures to protect data hosted on our servers in Switzerland and comply with applicable data protection laws. We do not monitor content hosted on our servers unless required by a lawful and binding Swiss court order.
LioraMail: Regarding LioraMail, a future service, we will adhere to the principles of maximum confidentiality and security, including but not limited to end-to-end encryption and minimal data collection, in full compliance with Swiss law.
Future Internet Services: Any future internet services provided by Liora Technologies International will be designed and operated in accordance with the principles outlined in this Privacy Policy, with an emphasis on privacy, data security, and strict compliance with Swiss law.

10. Changes to the Privacy Policy

We reserve the right to update this Privacy Policy periodically. We will notify you of any material changes by posting the updated version on our website and/or, if necessary, by sending an email notification. The "Effective Date" at the beginning of the Policy will be updated. We encourage you to regularly review this Privacy Policy to stay informed about our current information practices.

11. Contact Information

The data controller under this Privacy Policy is Liora Technologies International.

Legal Entity in Georgia:

Name: Kirill Safarchev (კირილლ საფარჩევ)
Tax ID: 345789916
Address: Georgia, Adjara, Batumi, Pirosmani st. 17B

Legal Entity in the USA:

Company: Liora Technologies U.S.
Address: 602 N Canon Dr, Beverly Hills, California (CA), 90210, United States of America (USA)

For all questions regarding this Privacy Policy, exercising your rights, or processing your data, please contact the data protection officer:

Name: Dawid Nowak
Email: dawid@lioravpn.com