L2TP privacy notice

1. Who is responsible

Lodestar Networks Ltd is the controller for the personal information described here. Our company number is 17431367 and our registered office is 66 Paul Street, London EC2A 4NA. Contact hello@lodestarnetworks.co.uk or write to that address for privacy questions or requests.

This notice covers the L2TP website/account and supported tunnel profiles. Stripe also processes information for its payment, security and regulatory purposes, as explained in Stripe's privacy notice. Voice, Mobile and community-campaign activities have different contexts and notices.

2. Information we use and where it comes from

• Account details you provide: full name, date of birth, email, home address, account identifiers and account changes. Signup requires these fields and a valid date of birth; no minimum signup age is specified. Email verification confirms access to that email address; it is not independent identity or age verification.
• Authentication and choices: protected account/tunnel credentials, email-verification and password-reset records, terms-version acceptance records and privacy acknowledgements, early-activation requests and connection options such as permission for unencrypted plain L2TP.
• Billing: chosen plan, subscription/customer/checkout/invoice references, amounts, payment and renewal status, cancellation, refund/dispute records and Stripe event information. You enter payment details on Stripe's hosted pages. We receive transaction information needed to reconcile payment and service. We do not send your date of birth in Stripe metadata.
• Address and session records: tunnel username, allocated public IPv4, assignment/provisioning history, NAS and session identifiers, creation/update/start/stop timestamps, duration/byte counters and termination/status information where recorded. These records can associate an account and public address with a time.
• Operational and security records: website/gateway access and authentication events, connection addresses, failures, administrative/audit actions, billing-worker events and system/backup records needed to operate and protect the service.
• Correspondence: support messages, fault reports, complaints, cancellation requests, abuse reports and lawful-authority requests, including information supplied by the sender.

Information comes from you, your use of our website and gateway, Stripe, and people contacting us about a service issue or legal/security concern. These categories describe account and operational handling; they do not authorise blanket recording of traffic contents or imply that every network packet is stored.

We do not offer anonymous or no-logs accounts. If you do not supply the required signup information or email verification, the current ordering process cannot create an eligible subscription. Please contact us about an inaccurate record or a concern about a required field.

3. Why we use information

• Account, provisioning, payment and support: to take the steps you request before a contract and perform the subscription, including connection credentials, address allocation, renewal, cancellation and fault handling. The lawful basis is contract where the particular information is necessary for those tasks.
• Accountability and account administration: to keep accurate account records and distinguish them where justified when investigating security, fraud or abuse. We rely on legitimate interests in responsible service administration, preventing fraud and protecting the service. Collecting a full date of birth is our policy requirement; this is not a claim that VPN providers are legally required to collect it.
• Security and abuse investigations: to authenticate access, prevent fraud, protect users/networks, investigate credible misuse and keep reliable address/session evidence. We rely on legitimate interests in secure, accountable operation, subject to necessity and the rights of affected people.
• Accounting and binding legal duties: to keep records and respond to a valid legal requirement where the relevant law requires it. The basis is legal obligation for that specific duty; an allegation or informal request does not itself establish one.
• Complaints and legal claims: to investigate, resolve disputes and establish, exercise or defend legal rights. We rely on legitimate interests and any specific legal obligation that applies.
• Optional marketing: only where separately requested or otherwise permitted under the applicable rules. Where we rely on consent, you can withdraw it without affecting earlier lawful use. Essential service, security and billing messages are separate from marketing.

Our interests do not automatically override your rights. We assess whether the information and use are necessary and proportionate, including whether a less intrusive option can meet the purpose. Consent to marketing is not a condition of purchasing the service.

4. Who receives information

Access is limited to authorised personnel and service providers who need it for their role. Supplier categories include payment processing (Stripe), hosting and backups, email delivery, network/transit infrastructure and technical support. Professional advisers, insurers, auditors, banks or payment networks may receive relevant information for advice, accounts, disputes or legal obligations. Processor access is governed by appropriate instructions and contractual safeguards.

Stripe Hosted Checkout and Customer Portal handle payment/customer-portal interactions. Stripe may act as a processor for some activities and an independent controller for others; its notice explains that distinction. Network providers necessarily carry traffic, but do not routinely need our full account database or your date of birth simply to carry packets.

We do not disclose account identity to arbitrary abuse reporters. For a request from law enforcement or another authority, we verify the requester and legal authority, assess the scope and necessity, and disclose only the minimum information justified by applicable law. We may reject or narrow an unsupported request. An authorised request may justify preservation of relevant records. We notify the affected person where lawful and appropriate, without promising notice where it would be prohibited or prejudice a legitimate investigation.

We may use a report to investigate or ask the customer to respond without disclosing their identity to the reporter. Any disclosure needed for a specific legal claim is assessed separately for a lawful basis, necessity and safeguards.

5. International transfers

Suppliers, including Stripe and its service providers, may process information outside the UK. Where UK transfer rules apply, the transfer must be covered by an applicable adequacy arrangement or suitable safeguards, such as approved contractual provisions and the required assessment, or a lawful exception for the specific transfer.

Contact us for information about the destinations and safeguards relevant to your data and how to obtain a copy of applicable safeguards, subject to lawful redaction. We do not claim that all processing or backups are confined to the UK.

6. How long we keep information

Retention depends on the purpose and the following criteria; closing a subscription does not automatically erase every linked record.

• Account, contact and declared birth-date information: needed while administering the account. After closure we assess whether particular fields remain necessary for outstanding bills, record corrections, complaints, credible abuse investigations or legal claims. A field is not retained merely because another linked record must remain.
• Billing and consent/contract records: retained as needed for the accounting/tax obligations, payment disputes, cancellation/refund evidence and legal-claim periods applying to the record. The relevant obligation and unresolved issue determine what is kept.
• Public-address assignments and session/audit records: assessed against fault diagnosis, fraud/security investigation, reliable attribution of a reported event and legal-claim needs. An identified incident or valid preservation requirement can justify keeping the relevant subset longer; it does not justify unrelated records indefinitely.
• Support, complaints and authority requests: kept while the matter and any necessary follow-up, challenge or claim remain live, then reviewed for continuing need.
• Recovery copies: encrypted backups can contain earlier copies. Live-record removal does not instantly remove all historical backups. Their continued retention is assessed for recovery needs, security, capacity and applicable holds; access remains restricted. If data is restored, applicable restrictions and deletion decisions need to be reapplied before normal use.

No fixed automatic deletion period for these account, session or backup categories is promised here. We review requests and retention needs, delete or anonymise information when it is no longer needed, and isolate material that must be preserved for a specific reason. Ask us for the criteria relevant to your record or to challenge continued retention.

7. Security, cookies and automated decisions

We use access controls, secure website connections, protected credentials, audit records and encrypted off-host recovery captures to reduce risks. No system can guarantee absolute security. Do not send tunnel passwords or shared secrets in support messages.

Account sessions and security controls use necessary browser/session information. Stripe-hosted pages have their own cookie and privacy information. Optional analytics or marketing storage requires the choices and notices applicable to it; this notice does not authorise adding it silently.

Stripe performs the configured payment retries. Our automated payment reconciliation and entitlement checks can delay provisioning, suspend a tunnel or end access when payment or entitlement expires. These controls can affect your service. Contact us to explain an error, challenge an outcome and request human review; we will consider the relevant information and correct an inaccurate result. Stripe's own fraud/payment decisions are also subject to its processes and notice.

8. Your rights and complaints

Depending on the circumstances and lawful basis, you can request access, correction, erasure, restriction or portability of your data, object to processing based on legitimate interests and withdraw consent for a consent-based use. You can object to direct marketing at any time. Rights have legal conditions and exceptions; keeping a required billing or investigation record can remain lawful after an erasure request.

Email hello@lodestarnetworks.co.uk with “Privacy request”, or write to our address. We may ask for proportionate information to verify the request and protect another person's data. We normally respond within one month, explaining any lawful extension or refusal and available challenge route. You do not need to send a tunnel password or date of birth in an initial request.

You may complain to the Information Commissioner's Office, the UK data protection regulator, without giving up other remedies. Please tell us about concerns so we can try to resolve them, but contacting us is not a condition of your statutory rights.

We will explain material changes before they affect you where required. A changed notice does not retrospectively authorise an incompatible new use of information.