Privacy Policy
Version of 14 October 2026.
The company warrenBrowse is being incorporated. Until it is registered, the responsible entity is referred to in this document as "the Warren team".
This policy describes the processing of your personal data during the Warren public beta. It supplements the Public Beta Terms.
1. Controller
The Warren public beta is operated by the Warren team.
- Data protection contact: contact@warrenbrowse.com
No commercial company operates the service at this stage. A legal entity is being incorporated; it will become the controller for the paid service and will then publish its full registration details.
Processing is subject to the GDPR (Regulation (EU) 2016/679). You may contact the data protection authority of your country of residence.
2. What Warren does not record
Warren does not record its users' activity. To carry your traffic, Warren's servers process your IP address, your DNS queries and the state of your connections in memory, for the duration of the connection. Warren then keeps no record linked to you: no browsing or DNS history, no session time or duration linked to an account, no per-user data volume, no list of the ports an account has held, apart from the abuse files described in section 3. DNS answers stay for a while in a cache shared by all the users of a server, with no link to the person who asked for them.
The Warren team keeps account and security data, and the records created when it handles an abuse report about a forwarded port. Section 3 lists them, with their purpose and retention period.
This commitment is Warren's own. The hosting and network providers that supply the servers and the bandwidth keep their own records, under their own policies and the law of their country; section 7 names them. In France, the law may require the hosting provider of the Paris server to keep connection data for one year (Article L34-1 of the French Postal and Electronic Communications Code).
3. Data the Warren team processes during the beta
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Account identifier (pseudonymous public key, expiry date) | Give you access to the beta | performance of the contract, GDPR Art. 6(1)(b) | lifetime of the account, then 12 months after it expires; erasable (section 8) |
| Access updates sent to the exit servers (public key, expiry date) | Tell the exit servers which accounts are active | performance of the contract, 6(1)(b) | the latest 50,000 updates |
| Replay protection for signed requests (fingerprint of the key computed with a secret key, time) | Stop an intercepted request from being replayed | legitimate interest in security, 6(1)(f) | 120 seconds |
| Issuance of blind access tokens (Privacy Pass) (fingerprint of the key computed with a secret key, issuance period) | Issue only one batch of tokens per period | performance of the contract, 6(1)(b) | about 49 hours |
| Device or bandwidth limits specific to an account, when the team sets one (public key, value) | Apply that limit | performance of the contract, 6(1)(b) | until the account expires |
| Beta voucher attribution trace (fingerprint of the account, voucher granted) | Credit the free access and avoid double attribution | performance of the contract, 6(1)(b) | length of the campaign |
| Forum identity (pseudonym derived from your key, fingerprint of the key computed with a secret key, last sign-in date) and your posts | Support, follow-up and fixing of reported bugs | performance of the contract, 6(1)(b) | forum link: 730 days without sign-in; posts: until you or the moderators delete them |
| Problem report and attached logs | Reproduce and fix the defect you report | consent, 6(1)(a), given in the app | 12 months |
| Support or abuse message (email to contact@ or abuse@) | Answer you, handle the report | legitimate interest, 6(1)(f) | 12 months |
Site language preference (PARAGLIDE_LOCALE cookie) |
Show the site in your language | strictly necessary for the service you request | 400 days, in your browser |
| Attribution tag (encrypted account identifier that only Warren's central server can decrypt) | Identify the holder of a forwarded port when an abuse report arrives, and only then | legitimate interest in network security, 6(1)(f) | in memory on the exit server, while the port is open |
| Abuse report file (exit server, port, protocol, category, source of the report, dates; no account identifier) | Handle the report | legitimate interest in network security (Article 5 of Romanian Law 506/2004, GDPR Art. 6(1)(f)) | 12 months, then anonymised (server, port and time erased) |
| Warning (pseudonymous identifier derived from the account with a secret key, file reference, category, day) | Count warnings and show them to you in the app | legitimate interest in network security (Article 5 of Law 506/2004, GDPR Art. 6(1)(f)) | rolling 90 days |
| Account revocation (account identifier, dates to the day, reason), also entered on the signed revocation list the exit servers receive | Apply the revocation imposed after three warnings in 90 days | legitimate interest in network security (Article 5 of Law 506/2004, GDPR Art. 6(1)(f)) | 12 months, or until it is lifted |
| Log of the team's actions (action, date, fingerprint of the account key computed with a secret key) | Trace the team's interventions on an account | legitimate interest in security, 6(1)(f) | permanent; cannot be modified or deleted |
| API rate limiting (IP address of the request) | Protect the API from overload | legitimate interest in security, 6(1)(f) | in memory, until a few minutes of inactivity |
| Server technical logs (start-ups, errors, service health; no IP address and no account key) | Run and secure the service | legitimate interest in security, 6(1)(f) | a few days in memory on the exit servers; at most 100 MB on the API |
| Infrastructure metrics (load, overall throughput, session counts; no subscriber identifier) | Size and monitor the network | legitimate interest, 6(1)(f) | 2 years |
| Database backups | Restore the service after a failure | legitimate interest, 6(1)(f) | 7 days |
Files, warnings and revocations are documented in the Warren team's record of processing activities. They may be disclosed to an authority under the conditions of section 10.
No payment data. The beta is free: no payment method is stored, no payment provider is involved, and the Warren team produces no billing data, no tax location evidence and no accounting record about you.
4. Your identity on the forum
The forum is the bug reporting channel. Its design avoids linking your posts publicly to your Warren account:
- Your forum pseudonym is derived from your account key by a keyed hash (for
example
lusab-babad-dovok). It is stable for you and cannot be traced back to your account key by a forum reader. - The forum never receives your account key, nor your real IP address (it is replaced by a fixed value before reaching the forum), nor a real email address (a non-routable technical address is generated), nor a password (none exists).
- Internally, the Warren support team can match a forum pseudonym to an account key in order to handle a support request. That access is restricted, protected by strong authentication and logged.
- Your public posts are public. What you post is visible to everyone, including search engines.
The forum hosts content posted by its users. Any illegal content can be reported to contact@warrenbrowse.com; the Warren team examines every report and tells the author of removed content why it was removed (Regulation (EU) 2022/2065, Articles 16 and 17).
5. Problem reports and attached logs
When you report a bug, you can attach your application's technical logs. This processing rests on your consent and works as follows:
- You keep the initiative. Nothing is sent without an explicit confirmation by you in the app.
- Logs are redacted before leaving your device. An automatic pass replaces IPv4 and IPv6 addresses, MAC addresses, technical identifiers (UUIDs), long digit strings and your home directory paths.
- They contain technical information: app and service events and errors, versions, operating system, connection state. They do not contain the content of your browsing.
- They are never public. They pass through the Warren team's own service
(
connect.warrenbrowse.com) and are delivered to the support team alone by private message. They do not appear in your forum topic, and you receive a private acknowledgement. - They are deleted after 12 months.
- You may withdraw your consent for the future and ask for the deletion of a report already sent (section 8).
6. What the Warren team does not do
The Warren team does not carry out advertising profiling, does not sell or share your data for commercial purposes, does not run third-party tracking, and does not inspect your traffic.
Every warning rests on a report handled by a human. The revocation that follows the third warning applies automatically, and you may contest it by writing to abuse@warrenbrowse.com with the case reference; the Warren team re-examines it (Reports page). No other automated decision producing legal effects is taken in respect of you.
The beta.warren.ro site contains no analytics tool, no third-party script and
no advertising cookie. The only cookie set is your language preference.
7. Recipients, hosting providers and service providers
The Warren team uses only the providers the beta needs to run:
- Hosting of the exit servers: Hetzner (Germany, Finland, Singapore), FDCservers (Netherlands), M247 (France, Romania).
- Hosting of the API and the database: FlokiNet (Romania); backup copy at Hetzner (Finland).
- Hosting of the forum: Hetzner (Finland). The forum is a Discourse the Warren team runs itself; no forum data is entrusted to an outside service.
- Email for
warrenbrowse.com: hosted at Contabo (Germany). - Availability monitoring: healthchecks.io and ntfy.sh receive heartbeat signals from the servers, with no user data.
- No payment provider, as the beta is free.
The hosting providers act as processors within the meaning of Art. 28 GDPR, under their data processing terms. They also keep their own technical records (network flows, abuse tickets, IP address assignment), under their own policies and the law of their country.
8. Your rights
Under the GDPR (Art. 15 to 22), you have the rights of access, rectification, erasure, restriction, portability and objection, and the right to withdraw your consent for the logs you sent to the Warren team.
- How to exercise them: write to contact@warrenbrowse.com, or send a private
message to the
@supportgroup on the forum from your account. - Erasure: on request, the Warren team deletes your Warren account, the data in section 3 linked to it and the forum identity derived from it. The log of the team's actions keeps only a fingerprint of the key, and backups disappear within 7 days. A revocation in progress is kept until it ends: without that record it could not be applied. Your account key lives on your device: signing out in the app erases it there, and the Warren team has no copy of it.
- Access: the Warren team keeps no activity history; an access request covers the data in section 3. Any warnings and revocation on your account are shown in the app.
- Complaint: you may contact the data protection authority of your country of residence.
9. Security
Traffic is encrypted between your device and the exit server. The exit servers run in memory, with no persistent disk for activity data, and memory dumps (core dumps) are disabled on them. The Warren team applies proportionate technical and organisational measures (Art. 32 GDPR).
In the event of a personal data breach, the Warren team notifies the ANSPDCP (the Romanian data protection authority) within 24 hours of detecting it where feasible (Law 506/2004), and informs the users concerned by a message in the app where the breach is likely to harm them.
The beta is a test environment: its robustness is that of software still being tuned, which is the very reason for the programme.
10. Authority requests
A competent authority may require the Warren team, in the forms provided by law, to disclose the data it holds when the request is made, or to preserve it. The Warren team keeps no activity history that could be disclosed. The data described in section 3, including the files, warnings and revocations relating to port forwarding, may however be requested while they exist. Data covered by a preservation measure is not deleted before that measure ends. The Warren team may also be required to assist, with its hosting providers, a targeted interception measure authorised by law. It informs the user concerned where the law allows.
Authorities write to legal@warrenbrowse.com. The procedure is described on the Reports page.
11. Transfers outside the European Union
Account data, the database and the forum are hosted in the European Union. One exit server is in Singapore: if you choose it, your traffic is processed there in memory for the duration of the connection, and no account data is stored there. This transfer is covered by the standard contractual clauses adopted by the European Commission, concluded with the hosting provider (GDPR Art. 46).
12. Minors
The beta is not intended for people under 18 (see the Public Beta Terms). The Warren team does not knowingly collect data from minors.
13. Changes to this policy
The Warren team may change this policy. Changes are dated and announced on
https://beta.warren.ro and on the forum. The applicable version is the one in
force at the time of processing.
14. Contact
For any question about your data: contact@warrenbrowse.com.