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

AEU DNS is a filtering forwarder, not a recursive resolver. Your device connects to our filtering servers in the EU, which apply your filters and then resolve each query using Oblivious DNS over HTTPS (ODoH): the query is sealed with HPKE encryption and sent through an independent relay to a public target resolver, so it is split between two parties that cannot combine what each one sees. This means:

• The relay (Fastly, or our own Cloudflare Worker) sees only our server's IP address and the encrypted query — it cannot read the domain you requested.
• The target resolver (e.g. Cloudflare, Google or crypto.sx over ODoH) decrypts and resolves the query, but only ever sees the relay's IP address — never yours or ours.
• No single party can link your identity to your queries, and we do not log DNS queries (zero-log).
• If ODoH is temporarily unavailable, queries fall back to encrypted DNS-over-TLS to the public resolvers listed under Sub-processors; DNSSEC and qname-minimisation are applied throughout.

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:

• ODoH relays — Fastly (edgecompute.app) and our own Cloudflare Worker relay your queries without being able to read them (HPKE-encrypted); they see only our server's IP address.
• ODoH target resolvers — Public resolvers reached over Oblivious DNS-over-HTTPS, including Cloudflare (USA), Google Public DNS (USA) and crypto.sx. They resolve the query but only ever see the relay's IP address — never your IP or identity.
• Fallback DNS resolvers — Used only if ODoH is temporarily unavailable, over encrypted DNS-over-TLS: Cloudflare (USA), Google (USA), Quad9 (Switzerland), Mullvad (Sweden), AdGuard (Cyprus), CIRA Canadian Shield (Canada), Digitale Gesellschaft (Switzerland), LibreDNS (Greece) and dot.sb. They receive only the domain name and our server's IP address — never your IP or identity.
• Cloudflare, Inc. (USA) — CDN and DDoS protection for the web dashboard and the DoH endpoint. Certified under the EU-US Data Privacy Framework.
• Hosting (EU) — Our filtering servers are located exclusively in the European Union.

By design (ODoH split-knowledge), no single party — including us — can link your IP address to the domains you look up: the relay never sees the query, and the resolver never sees you. DNS queries are never stored (zero-log). Web-dashboard access via Cloudflare is 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.