Privacy Policy

1. Data Controller

• Controller: AEU DNS
• Registered address: European Union
• Email: privacy@aeu-dns.com
• Service website: https://aeu-dns.com

2. Data We Collect

We collect the minimum data necessary to provide the service:

• Email address — Required for account creation and communication. Legal basis: contract performance (Art. 6(1)(b) GDPR).
• Password — Stored as Argon2id hash (irreversible). We never store or see your plaintext password.
• IP addresses — Stored only as one-way cryptographic hashes (SHA-256 with salt). We cannot reverse-engineer or read your actual IP address. Used solely for device authentication. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
• Profile settings — Your filtering preferences (blocklists, parental controls, DNS rewrites). Legal basis: contract performance.
• mTLS certificates — Certificate serial number and fingerprint (not the private key). Used for mutual authentication. Legal basis: contract performance.

3. Data We Do NOT Collect

4. DNS Query Privacy

All DNS queries are resolved using Oblivious DNS over HTTPS (ODoH). This architecture ensures:

• The relay server sees your IP but cannot read the DNS query (encrypted)
• The resolver sees the DNS query but does not know your IP
• No single point in the system can associate your identity with your queries
• DNS queries are resolved in real-time and never stored on any server

5. Cookies

We use only strictly necessary cookies (no consent required under ePrivacy Directive):

• Session cookie — Keeps you authenticated. Expires when you close the browser or after inactivity.
• Language cookie — Remembers your language preference.
• Theme cookie — Remembers your display theme (light/dark).

We use no marketing cookies, no analytics cookies, and no third-party tracking cookies.

6. Sub-processors & International Transfers

We use the following third-party services:

• Cloudflare, Inc. (USA) — CDN and DDoS protection for the web dashboard. Cloudflare is certified under the EU-US Data Privacy Framework. Cloudflare does NOT have access to DNS queries (which use ODoH encryption).
• Hosting providers (EU) — Our DNS servers are located exclusively in the European Union. DNS resolution is delivered globally via Cloudflare and Google CDN, routing users to the nearest available server.

No personal data is transferred outside the EU/EEA except through Cloudflare CDN for web dashboard access, covered by the EU-US Data Privacy Framework adequacy decision.

7. Data Retention

• Account data (email, password hash) — Retained until you delete your account.
• IP hashes — Retained while the device is linked. Automatically removed when you unlink or delete your account.
• Profile settings — Retained until you delete your profile or account.
• Certificates — Certificate metadata retained until certificate expiry or revocation. Revoked certificates purged after 30 days.
• Security logs — Failed authentication attempts (IP hash only, no personal data) retained for max 90 days for abuse prevention.

8. Your Rights (GDPR Articles 15-22)

Under GDPR, you have the following rights:

• Right of access (Art. 15) — Request a copy of all data we hold about you.
• Right to rectification (Art. 16) — Correct inaccurate personal data.
• Right to erasure (Art. 17) — Delete your account and all data ("right to be forgotten"). Available directly in your account settings.
• Right to restriction (Art. 18) — Restrict processing of your data.
• Right to data portability (Art. 20) — Export your profile settings in machine-readable format.
• Right to object (Art. 21) — Object to processing based on legitimate interest.
• Right to withdraw consent (Art. 7(3)) — Where processing is based on consent, you may withdraw it at any time.
• Right to lodge a complaint — You may file a complaint with your national data protection authority (supervisory authority).

To exercise any of these rights, contact us at privacy@aeu-dns.com. We will respond within 30 days.

9. Children's Privacy

AEU DNS accounts require a valid email address to register. We do not collect age, name, or any other identifying information, and therefore we have no technical means to determine whether a user is an adult or a minor. Account registration is intended for users aged 16 or older (see Terms of Service, Section 3). Parents and guardians may create profiles for children under their own account.

Parental control features (content filtering, SafeSearch, time controls) are designed to be configured by parents/guardians for children's profiles.

10. Security Measures

• Passwords hashed with Argon2id (65MB memory, 4 iterations, 3 threads)
• IP addresses stored as one-way SHA-256 hashes (cannot be reversed)
• All connections encrypted with TLS 1.3 (DoH, DoT, DoQ protocols)
• Post-Quantum Cryptography (X25519MLKEM768) protects against future quantum attacks
• Mutual TLS (mTLS) authentication with hybrid RSA-4096 + ML-DSA-65 certificates
• Zero-Knowledge Proof (SRP-6a) login option — password never leaves your device
• All servers located in the European Union
• Regular security audits and penetration testing

11. Legal Basis Summary

• Contract performance (Art. 6(1)(b)) — Account data, profile settings, certificates
• Legitimate interest (Art. 6(1)(f)) — IP hashes for authentication, security logs for abuse prevention
• Legal obligation (Art. 6(1)(c)) — Responding to valid legal requests

12. Changes to This Policy

We may update this privacy policy from time to time. Material changes will be communicated via email or a notice on our website. The "Last updated" date at the top indicates when the policy was last revised.