Privacy Policy
SUNSHINE NETWORK S.R.L. operates Tumbler, including the Tumbler apps, the public API at api.tumbler.app, and this website. This Privacy Policy explains what data Tumbler collects, how it is used, how long it is retained, and how users can request export or deletion.
Data controller
Controller: SUNSHINE NETWORK S.R.L.
Privacy contact: privacy@tumbler.app
Data we collect
- Installation and device data, such as a random installation identifier, platform, device type, app version, public signing/encryption keys, and timestamps for creation and last activity.
- Subscription and configuration data that a user adds to the app, including subscription identifiers, provider metadata, support or management links exposed by a provider, normalized VPN configuration metadata, and the provider subscription source needed to refresh the configuration.
- VPN session and state metadata, such as session identifiers, selected subscription and node identifiers, connection start and end timestamps, heartbeat/reconnect state, and disconnect reason.
- Operational events, including ping results, sync outcomes, subscription add/remove events, errors, abuse-prevention events, request IDs, IP address, and user agent where required for security, reliability, audit, and support.
- Diagnostics data, if enabled or submitted, such as crash reports, app and tunnel runtime state, event type, severity, source, message, metadata, and identifiers needed to correlate a VPN incident.
- Push notification tokens when the app registers for push notifications.
- Support messages and attachments a user chooses to send to us.
- Privacy export and deletion job metadata needed to process a user's request.
VPN traffic and tracking
Tumbler does not sell, rent, or use VPN traffic data, browsing history, DNS query content, diagnostics, or session metadata for advertising or cross-app tracking. The Tumbler control plane is designed to operate subscriptions, sessions, diagnostics, security, and support. It does not intentionally collect the contents of websites, apps, messages, or files a user accesses through a VPN tunnel.
How we use data
- To register an installation, authenticate requests, and protect the API from replay, abuse, and unauthorized access.
- To add, refresh, normalize, sync, restore, and remove VPN subscriptions and configurations selected by the user.
- To authorize VPN sessions, route runtime state, maintain connection reliability, and support troubleshooting.
- To deliver push notifications and service status information where enabled.
- To provide privacy export, deletion, customer support, security review, and legal compliance.
- To measure service reliability using aggregated or minimized operational diagnostics.
Third parties and service providers
We use service providers only as needed to operate and support Tumbler, including cloud hosting, storage, databases, analytics/observability infrastructure, push notification platforms, app distribution platforms, and payment or subscription platforms where applicable. We require service providers that process user data for Tumbler to protect it at least as strongly as described in this policy.
If a user adds a third-party VPN subscription URL or provider configuration, Tumbler may contact that provider endpoint to fetch or refresh the configuration chosen by the user. Tumbler does not sell user data to VPN providers, advertisers, data brokers, or analytics networks.
Retention
We retain data only for the purposes described above. Unless a shorter period is configured or a longer period is required for security, legal, or abuse-prevention reasons, operational events, session records, and subscription snapshots are retained for up to 365 days. VPN diagnostics events are retained for up to 90 days. Privacy export links are temporary and expire after the configured export period.
When a user requests deletion, Tumbler marks the installation as deleted, invalidates signing keys, removes or disassociates installation-scoped records, clears push tokens and routing policies, and schedules deletion of related analytics records. Some backup copies, logs, or provider-side records may persist for a limited period according to the relevant provider's retention and legal requirements.
User choices and deletion
Users can request a copy of their Tumbler data or deletion of installation-scoped data from the app privacy controls where available. Users may also contact privacy@tumbler.app to request access, correction, export, deletion, or withdrawal of consent. We may ask for information needed to verify the installation or request.
Security
Tumbler uses signed API requests, authentication tokens, request replay protection, encrypted payload delivery, access controls, and operational monitoring to protect user data. No system is perfectly secure, but we design the service to minimize access and retain only data needed for the service.
Children
Tumbler is not directed to children. We do not knowingly collect personal data from children.
International processing
Data may be processed in countries where SUNSHINE NETWORK S.R.L. or its service providers operate. When data is transferred internationally, we use appropriate contractual, technical, and organizational safeguards.
Changes
We may update this policy when Tumbler's data practices change. The updated version will be posted on this page with a new "Last updated" date.