Terms of Service

These Terms of Service (the "Terms") are a binding agreement between you and BlackSwan VPN ("BlackSwan", "we", "us", or "our"). They govern your access to and use of the BlackSwan VPN mobile applications for iOS and Android, the underlying VPN service, and any related software, websites, and support channels (together, the "Service").

By installing, accessing, or using the Service — or by accepting these Terms during onboarding — you agree to be bound by them. If you do not agree, do not use the Service.

These Terms include our acceptable-use rules and our refund policy as integral parts of this single agreement (see the Acceptable Use and Refunds sections below), alongside our separate Privacy Policy. Where the Service involves payment, the rules of the relevant app store also apply. Last updated: July 18, 2026.

You may use the Service only if you can form a binding contract with us and are not barred from doing so under any applicable law. You must also meet the minimum age required to enter into this agreement and to consent to the processing described in our Privacy Policy in the jurisdiction where you use the Service. If you are below that age, you may not use the Service.

• You are responsible for ensuring that your use of a VPN, and of encrypted-tunnel technology generally, is lawful where you are.
• The Service is distributed through the Apple App Store and Google Play. Availability in your region is governed by those channels; the app does not run an in-app geographic or sanctions check.
• You are responsible for complying with any export-control, sanctions, or local restriction that applies to you.

BlackSwan is a no-logs consumer VPN. When you connect, your device traffic is carried through an encrypted tunnel to one of our servers and on toward your destination. The goal is privacy and access, including on networks that filter or restrict the open internet.

"No-logs" is concrete: we do not record the destination IP addresses, hostnames, or domains you reach, your DNS queries or responses, or the contents of your traffic. We keep no browsing history and no per-connection activity logs. What we do retain — and for how long — is a short list of operational metadata described in our Privacy Policy and summarized in Section 7. Our server software is configured at deployment to suppress access and connection logging.

The app selects an appropriate server for you automatically. We do not currently offer a manual location picker. The set of available servers, protocols, and plan options is managed by us and may change as we maintain and improve the network.

Some traffic may egress through third-party (rented) capacity rather than infrastructure we operate. Where it does, the third party — not BlackSwan — handles the exit under its own logging, retention, and jurisdiction, which our no-logs commitment cannot bind. We use such capacity only with providers we consider no-logs-credible, it is off by default, and we label third-party-exit servers in the app. Our no-logs claim is scoped to exclude traffic carried over third-party exit. See our Privacy Policy for the difference between relay capacity (the provider sees only our server's address, not you) and passthrough capacity (the provider can see your real address and destinations directly).

BlackSwan VPN is designed to be used without an identity. A consumer "account" is an anonymous enrolled device: we do not require an email address, password, or any personal login. Your entitlement is bound to your device through a subscription token issued at enrollment.

Because there is no human-readable login, losing your device — or uninstalling without using the restore mechanism described in the app — means losing that access path. Keep your device and any restore credentials safe. Restore and device-transfer behavior is described in the apps.

Separate from consumer accounts, we operate admin accounts — internal BlackSwan staff accounts used to operate the Service through our administrative dashboard. These are not available to the public, are sign-in protected, and are governed by our internal policies in addition to these Terms.

BlackSwan is offered as a free tier and as a paid subscription. Both consumer tiers are limited to a single device and a single concurrent connection. The free tier requires no payment and has no separate trial clock — it is the ongoing trial, and you can use it for as long as you like within its limits. The paid tier unlocks the full plan. Plan names, prices, billing periods, and any included data are dynamic and shown in the app at the point of purchase. The price you see and confirm in the app store at checkout governs.

Paid subscriptions purchased in the apps are processed through Apple's App Store (StoreKit) and Google Play Billing. We do not collect, process, or store your payment-card data, and the app store is the merchant of record for these purchases.

Paid subscriptions renew automatically. Your subscription renews for successive periods at the then-current price charged by the app store until you cancel; your store account is charged at confirmation and at the start of each renewal period.

• Manage or cancel an auto-renewing subscription in your Apple App Store or Google Play account settings — not in the BlackSwan app. Cancellation takes effect at the end of the current paid period.
• Billing, renewal, and refunds for in-app purchases are governed by the terms of the app store you bought through, and refund requests for store purchases are made to and decided by that store. BlackSwan does not issue refunds for purchases made directly from us — direct sales are final — except where your local consumer law requires otherwise; the Refunds section below explains how this works.
• If a paid plan lapses or you stop paying, your access does not hard-stop: it falls back to the free tier and keeps connecting, subject to the free-tier limits. The only exception is a suspension we apply for abuse (see "Suspension and termination" below).

Some plans, including the free tier, include a data allowance or other fair-use limits. Where a plan specifies a data cap, it is enforced through aggregate up/down byte counters: we measure the total volume of data carried, never what that data is.

To run billing, enforce caps, manage one-device/one-connection limits, and respond to abuse, we retain a short list of operational metadata for limited windows: aggregate byte counters per device (raw samples are rolled up and pruned, typically within 30 to 90 days, with the running totals kept while your account is active); your source IP address (kept for 24 to 72 hours, then automatically deleted, and never stored alongside any destination data); billing and entitlement events (kept for the life of the account plus any legally required tax or accounting period); and your device enrollment record (kept for the life of the account). Because we keep no destination data at all, this metadata cannot reconstruct what you did online. Our Privacy Policy is the authoritative description of what we keep and for how long.

All use of the Service is subject to fair use. The Service is intended for ordinary personal use by an individual. We may take reasonable steps — including throttling, requiring an upgrade, or limiting access — to protect the network and other users against use that is excessive, automated, abusive, or inconsistent with a personal-use consumer VPN, or that attempts to circumvent device, concurrency, or data limits.

Subject to these Terms, we grant you a personal, limited, revocable, non-exclusive, and non-transferable license to download and use the BlackSwan apps and to use the Service for your own personal, non-commercial use, on the number of devices your plan permits. This license is for use only; it grants you no ownership.

Except where applicable law expressly permits, you may not copy, modify, distribute, sell, lease, sublicense, or create derivative works of the apps; reverse engineer, decompile, or disassemble them; remove or alter any proprietary notice; resell or commercially exploit the Service; or circumvent, disable, or interfere with any security, metering, or access-control feature.

Your use of the Service must comply with the acceptable-use rules set out below. They prohibit, among other things, child sexual abuse material, malware command-and-control, network intrusion or unauthorized access, mass abuse or spam, use by sanctioned parties, and any use unlawful in the applicable jurisdiction. Because we keep no activity logs, enforcement is complaint-driven; the sections below explain how reports are handled.

The rules in this and the following sections apply to everyone who uses the Service — whether you subscribed through the Apple App Store or Google Play, or use the free tier.

Where these acceptable-use rules and any other part of these Terms conflict on a question of acceptable use, this section and the ones that follow control.

BlackSwan exists to give people private, secure access to the open internet, including where it is censored. That only works if the network is not used to harm others. Do not use BlackSwan to break the law, to attack or abuse other people or networks, or to endanger the service for everyone else.

You may not use BlackSwan VPN, or allow anyone using your access to use it, for any of the following:

• Illegal activity. Any activity unlawful under applicable law, or that promotes, facilitates, or enables others to engage in unlawful activity.
• Child sexual abuse material (CSAM). Any storage, transmission, distribution, advertisement, or solicitation of material that sexually exploits or endangers minors. Zero tolerance applies; see "CSAM: zero tolerance" below.
• Hacking and network attacks. Unauthorized access to, or interference with, any system, account, network, or data; denial-of-service or distributed denial-of-service (DoS/DDoS) attacks; flooding, amplification, or reflection attacks; or any attempt to disrupt, degrade, or overwhelm a service or host.
• Intrusion and reconnaissance. Port scanning, vulnerability scanning, penetration probing, credential stuffing, brute-forcing, or any other attempt to gain or test access to systems you are not authorized to access.
• Malware and malicious code. Creating, hosting, distributing, or operating viruses, worms, ransomware, spyware, botnets, command-and-control (C2) infrastructure, or any other malicious code.
• Spam and unsolicited bulk messaging. Sending spam or unsolicited bulk or commercial messages; operating mailing infrastructure for such activity; or harvesting addresses or contacts for it.
• Fraud and deception. Phishing, identity theft, payment or carding fraud, impersonation, or any scheme intended to deceive or defraud others.
• Infringing the rights of others. Infringing copyright, trademark, trade secret, privacy, publicity, or other intellectual-property or proprietary rights; or distributing material you have no right to distribute.
• Harming or harassing others. Threats, stalking, harassment, doxxing, non-consensual intimate imagery, or any conduct that violates the safety, privacy, or dignity of another person.
• Endangering the network. Any use that compromises, destabilizes, or endangers BlackSwan's infrastructure, exit nodes, or other users, including activity likely to get our network blocklisted or to trigger action by an upstream or hosting provider against shared resources.

Child sexual abuse material is the one category we treat with zero tolerance and zero discretion. Any account or device credibly associated with CSAM is suspended immediately, without warning.

We report CSAM to the appropriate authorities and cooperate with law-enforcement investigations into it. Our no-logs posture (see "Legal process and law-enforcement requests" below) is not intended to shield this conduct: any relevant data we still hold within our retention window will be preserved and disclosed in response to valid legal process. We cannot, however, produce records we never collected.

Each BlackSwan plan is licensed to a single user and provisioned to a single device, with one concurrent connection. You may not:

• Resell, rent, sublicense, or commercially redistribute your access.
• Share a single-user account or its enrollment with people outside your household, or pool one subscription across multiple users.
• Circumvent, tamper with, or work around the single-device or single-connection limits, including by cloning, spoofing, or transferring device enrollment to evade them.
• Circumvent data caps, quotas, rate limits, or fair-use controls, including the free-tier allowance, by any technical or procedural means.
• Probe, reverse-engineer, or interfere with our provisioning, entitlement, or billing systems, or use the service in any way intended to obtain access you have not paid for or been granted.

Because we keep no logs of your activity, enforcement is complaint-driven, not surveillance-driven. We do not inspect your traffic looking for violations. We act on external reports, valid legal process, and the limited operational data we do hold.

When we find a violation, or have a reasonable basis to believe one is occurring, we may take any of the following steps, in proportion to the severity:

• Warning. For lower-severity or first-time issues, we may notify you and ask you to stop.
• Suspension. We may suspend an account or device, cutting access at the node while we investigate.
• Termination. We may permanently terminate access for serious, repeated, or egregious violations.
• Other operational measures. We may rotate or re-point network resources, decline to provision access, or take other steps to protect the network and its users.

If you believe BlackSwan is being used in violation of these rules, including copyright complaints and notices from hosting or upstream providers, contact us at abuse@blackswan.vpn.

Please include as much detail as you can: what happened, when it happened (date and time in UTC), the originating IP address if you have it, and any supporting evidence. Timing matters. The only source-network identifier we retain is a source IP address held for 24 to 72 hours (see "Legal process and law-enforcement requests" below), so a report sent promptly is far more likely to be actionable than one sent after that window has passed.

We review every report we can act on, triage it, and take proportionate action under "Enforcement of these rules" above. For privacy or data requests, contact privacy@blackswan.vpn; for other legal matters, legal@blackswan.vpn; for general help, support@blackswan.vpn.

We cooperate with valid, legally binding requests from competent authorities. We review each request for validity and scope and respond as required by the law of our operating jurisdiction. We push back on requests that are overbroad, improperly served, or outside that jurisdiction.

What we will not do is invent data we never collected. BlackSwan is a no-logs VPN. We do not record the destination IP addresses, hostnames, or domains you connect to; we do not log your DNS queries; we do not record packet or flow contents; and we do not keep your browsing history or any per-connection activity. These are hard engineering invariants, not just promises: our exit nodes are configured to suppress connection and access logging, so this data is never written to disk in the first place. We cannot produce records we do not hold.

What we do hold is deliberately minimal and described in full in our Privacy Policy and in "Fair use, data allowances, and the metadata we keep" above — briefly, a short-lived source IP, aggregate byte counters, and billing/device-enrollment records. None of it can reconstruct your activity, because we never collect destination or content data in the first place.

Within the relevant retention window, and only to the extent we actually hold relevant data, we may use it to investigate abuse and may disclose it in response to valid legal process. Once it is purged, it is gone and cannot be recovered or produced. We do not operate a warrant canary or publish a periodic transparency report; what we can ever be compelled to produce is bounded by what we keep.

One exception to scope: if you enable an optional third-party exit (a passthrough server, which we label as third-party in the app), your traffic egresses through an external provider whose logging, retention, and jurisdiction we cannot control. Our no-logs commitment covers the BlackSwan network and does not extend to traffic you route through a third-party exit.

We work to keep the Service available and performant, but we provide it on a best-effort basis. We do not guarantee that the Service will be uninterrupted, error-free, available in any particular place, or available at any particular speed. We may carry out maintenance, update protocols and server addresses, add or remove capacity, and change how the Service works, sometimes with limited or no notice.

In particular, we cannot guarantee that the Service will bypass any specific network restriction, firewall, or censorship system, or that any given network, country, or internet provider will permit a connection. Filtering systems are adversarial and change constantly: a connection that works today may be blocked tomorrow, and a server reachable on one network may be unreachable on another. Server addresses are rotated as part of normal operations and as servers are blocked.

The Service is not a substitute for your own judgment about your safety, security, or legal exposure. You use the Service in restricted or censored networks at your own risk.

When you obtain the apps from the Apple App Store or Google Play, you also agree to that store's terms, and your purchase, renewal, and refund rights for in-app purchases are governed by them. The app store is not a party to these Terms and is not responsible for the Service.

To the extent a store's rules require it, those rules prevail over any conflicting provision of these Terms as between you and the store, and the store and its subsidiaries are third-party beneficiaries entitled to enforce these Terms against you with respect to the app you obtained from it. The Service also relies on third-party software and providers; their components are subject to their own terms and licenses.

You may stop using the Service at any time, cancel any auto-renewing subscription through your app store, and request erasure of your data as described in our Privacy Policy. A verified erasure request results in a full hard-delete of your data, except for the minimal transaction records we are legally required to retain for tax or accounting purposes, if any.

We may suspend or terminate your access — in whole or in part, with or without notice — where we reasonably believe you have violated these Terms or the acceptable-use rules above, where your use poses a risk to the Service or to others, where required by law, or to respond to an abuse report. This is applied as a hard suspension at the server level.

Patterns associated with payment abuse — including repeated refunds or chargebacks — may inform a decision to suspend or terminate, and may affect eligibility for future paid access. On termination, the license in Section 7 ends and you must stop using the Service. Sections that by their nature should survive — including intellectual property, disclaimers, limitation of liability, indemnity, and governing law — survive termination.

This section explains how refunds work for a BlackSwan VPN subscription. In short: all sales made directly through BlackSwan are final, and we do not issue refunds for them. Purchases you make through the Apple App Store or Google Play are governed by that store's own refund rules, which only the store can apply.

This section does not limit any non-waivable rights you may have under the consumer-protection law of your own country; where such law grants a remedy we cannot exclude, that remedy still applies.

Who — if anyone — can refund a charge depends on how you bought. Read the section below that matches your purchase: Apple App Store and Google Play, or a direct purchase from BlackSwan.

BlackSwan VPN is sold through distinct channels, and each is handled differently for refunds. We never receive or store your card details on any channel.

• In-app purchases through the Apple App Store or Google Play. Apple or Google takes the payment, renews you, and is the only party that can issue a refund for that charge. BlackSwan cannot see the payment instrument or reverse the charge.
• Direct purchases from BlackSwan, where offered. Payment is handled by a third-party payment processor; BlackSwan does not store card or bank details. These purchases are final — BlackSwan does not issue refunds for them (see "Direct purchases: all sales are final").

Ending a paid plan is never a punishment. When a paid subscription is refunded by a store, ends, or lapses, your device does not lose connectivity. It falls back to the BlackSwan free tier and keeps connecting, subject to the free tier's daily data cap. This is the same fallback that applies to any expiry.

Access is removed entirely only by an explicit enforcement action for a confirmed violation of the acceptable-use rules above. A single store refund is routine. A pattern of refunds or chargebacks may be reviewed, and access may be suspended only where abuse is established (see "When refunds are not available" below and the acceptable-use rules above).

If you subscribed through an in-app purchase, your billing relationship is with the store, and any refund must be requested from the store. BlackSwan cannot issue, approve, or override a store refund.

Apple App Store: request a refund at reportaproblem.apple.com or from Settings on your device. Apple decides the outcome under its own Media Services and App Store terms, including its own time limits.

Google Play: request a refund in the Google Play app or at play.google.com. Google offers self-service refunds within a short window after purchase (generally up to 48 hours for many purchases) and reviews later requests case by case under its own terms.

Cancelling and refunding are separate. Cancelling stops future renewals but does not, by itself, refund a charge already made. Manage cancellation in the store: your Apple Account in iOS Settings, or the Subscriptions screen in the Google Play app on Android.

If the store declines and you believe the service was genuinely unusable, contact support@blackswan.vpn. We cannot reverse a store decision, but we can help you troubleshoot and support a renewed request to the store.

For subscriptions purchased directly from BlackSwan, where this option is offered, all sales are final. We do not offer a money-back window and do not issue refunds for direct purchases, including for time you have not used.

If something isn't working, contact support@blackswan.vpn — before or after you buy — and we will help you get connected. Because the free tier keeps your device online at no cost, you can confirm the service works for you before committing to a paid plan.

This does not limit any non-waivable right you have under the consumer law of your country. Where that law requires a refund or other remedy we cannot exclude, we honor it despite the all-sales-final rule.

• Auto-renewals are also final. To avoid a renewal charge, cancel before the renewal date in the store or with your payment processor.
• A direct purchase does not entitle you to a partial refund for a billing period you have already had access to.

Except where the consumer law of your country requires otherwise, BlackSwan does not issue refunds. In particular, none of the following qualifies for a BlackSwan-issued refund:

• Any purchase made directly from BlackSwan. All direct sales are final, whether or not the time has been used.
• Time already used. We do not refund a portion of a billing period during which you had access.
• Subscriptions cancelled mid-term. Cancelling stops the next renewal but does not refund the current period, which stays active until it expires.
• Promotional, discounted, or bundled plans.
• Access suspended or terminated for a confirmed violation of the acceptable-use rules above. No refund is due for the remaining term.
• Repeated refund or chargeback activity that indicates abuse. A chargeback filed without first contacting us is treated as a dispute rather than a refund request and may trigger review of the account.

Use the path that matches how you bought:

• App Store purchase: request through Apple at reportaproblem.apple.com. Apple sets the timeline and notifies you of the outcome; BlackSwan cannot override it.
• Google Play purchase: request in the Google Play app or at play.google.com. Self-service requests are usually decided quickly; reviewed requests can take a few business days. BlackSwan cannot override it.
• Direct purchase from BlackSwan: direct purchases are final, so there is no BlackSwan refund to request. If the service isn't working, email support@blackswan.vpn — with the purchase date, a short description of the problem, and the troubleshooting you tried — and we will help you get connected.

BlackSwan does not keep activity logs. We never record your destinations, DNS queries, or traffic contents, so any billing or support request can only be handled from billing and entitlement records, never from any record of what you did online. See our Privacy Policy for the full picture.

We retain billing and entitlement events for the life of the account plus the period required by applicable tax and accounting law. We keep aggregate byte counters for the free-tier cap, and a short-lived source IP for fraud and concurrency control that is purged within 72 hours. None of this records your activity.

If you ask us to delete your account, erasure removes the billing and entitlement records tied to it, subject only to any minimal retention we are legally required to keep.

The Service, the BlackSwan apps, the BlackSwan name and logo, and all related software, designs, text, and other content are owned by BlackSwan VPN or its licensors and are protected by intellectual-property laws. Except for the limited license in Section 7, these Terms do not transfer any right, title, or interest in the Service to you.

Certain components of the Service are provided under open-source or third-party licenses; nothing in these Terms limits your rights under those licenses with respect to those components. You may not use our trademarks without our prior written permission.

The Service is provided "as is" and "as available", without warranties of any kind, whether express, implied, or statutory. To the fullest extent permitted by law, we disclaim all implied warranties, including merchantability, fitness for a particular purpose, title, accuracy, and non-infringement.

We do not warrant that the Service will be uninterrupted, secure, or error-free; that it will defeat any censorship, surveillance, or filtering system; that it will protect against every threat to your privacy or security; or that any defect will be corrected. No advice or information you obtain from us creates any warranty not expressly stated here. Some jurisdictions do not allow the exclusion of certain warranties, so some of these exclusions may not apply to you; in that case our liability is limited to the minimum extent permitted by law.

To the fullest extent permitted by law, BlackSwan and its officers, directors, employees, and suppliers will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenue, data, goodwill, or anticipated savings, arising out of or relating to the Service or these Terms, whether based in contract, tort, or otherwise, even if we have been advised of the possibility of such damages.

To the fullest extent permitted by law, our total aggregate liability arising out of or relating to the Service or these Terms will not exceed the greater of the amount you paid to BlackSwan for the Service in the twelve months before the event giving rise to the claim, or twenty United States dollars (USD 20).

Nothing in these Terms excludes or limits liability that cannot lawfully be excluded or limited. Some jurisdictions do not allow certain limitations, so parts of this section may not apply to you.

You agree to indemnify, defend, and hold harmless BlackSwan VPN and its officers, directors, employees, and suppliers from and against any claims, demands, losses, liabilities, damages, costs, and expenses (including reasonable legal fees) arising out of or related to your use of the Service, your violation of these Terms or the acceptable-use rules above, your violation of any law or the rights of any third party. We may, at our own expense, assume the exclusive defense and control of any matter subject to indemnification by you, in which case you agree to cooperate with us.

We may update these Terms, our plans, and the Service from time to time. When we make a material change to these Terms, we will update the "Last updated" date and provide notice through reasonable means, such as in-app notice or release notes. Changes take effect when posted unless we state otherwise, and your continued use of the Service after a change takes effect means you accept the updated Terms. If you do not agree to a change, stop using the Service and cancel any subscription. We may also change, suspend, or discontinue any part of the Service at any time.

These Terms, and any dispute arising out of or relating to them or to the Service, are governed by the laws of our operating jurisdiction, which is being finalized ahead of launch and will be stated here once confirmed. This does not deprive you of the protection of the mandatory consumer-protection rules of your country of residence.

Before starting any formal proceeding, you agree to first contact us at legal@blackswan.vpn and attempt in good faith to resolve the dispute informally; many concerns can be settled this way. Nothing in this section deprives a consumer of the protection of mandatory provisions of the law of the place where they reside.

These Terms, together with our Privacy Policy, are the entire agreement between you and BlackSwan regarding the Service. If any provision is found unenforceable, the rest remains in effect, and the unenforceable provision is modified to the minimum extent necessary. Our failure to enforce any provision is not a waiver of it. You may not assign these Terms; we may assign them in connection with a merger, acquisition, or sale of assets. Nothing in these Terms creates any partnership, agency, or employment relationship between you and us.

Questions about these Terms can be sent to legal@blackswan.vpn. For other matters, use the contact that fits:

• General support — support@blackswan.vpn
• Privacy and data-erasure requests — privacy@blackswan.vpn
• Abuse reports and DMCA notices — abuse@blackswan.vpn
• Legal notices — legal@blackswan.vpn
• BlackSwan VPN — website: blackswan.vpn