EXPORT CONTROL AND SANCTIONS POLICY

Private Internet Access

Last updated: July 30, 2026

IMPORTANT NOTICE ABOUT YOUR PERSONAL LIABILITY FOR PROHIBITED EXPORTS AND SANCTIONS BREACHES

This software (the "Software") contains sophisticated encryption features. Because of those features, export control and sanctions laws in a number of jurisdictions restrict what you may do with the Software, and a breach of those laws may be a criminal offence for which you can be held personally liable, even where the breach is inadvertent. Ignorance of these laws does not reduce your liability. Please read the following guidelines carefully before downloading, installing, using, or otherwise dealing with the Software.

This Policy applies globally. Depending on where you are located, where you travel, where you are a national or resident, and to whom you provide the Software, more than one of the regimes described below may apply to you at the same time. Where two or more regimes apply, you must comply with all of them, and the strictest applicable restriction prevails.

1. SCOPE AND KEY CONCEPTS

1.1. This Policy governs the export, re-export, transfer, provision, and use of the Software and of any device or medium containing the Software.

1.2. In this Policy, the following definitions apply:

1.3. This Policy does not constitute legal advice. Export-control and sanctions rules change frequently. You are responsible for checking the current position under each applicable regime before you act, using the official sources referred to in clause 3.

2. APPLICABLE REGIMES

2.1. The Software and your dealings with it may be subject to the export-control and sanctions regimes of the United States, the European Union, the United Kingdom, and the United Nations, among others. You must comply with each regime that applies to you.

2.2. In particular:

3. OFFICIAL LISTS — CHECK BEFORE YOU ACT

3.1. The persons, entities, countries, and territories subject to these regimes change frequently. Rather than relying on any static list reproduced here, you must consult the current official lists before you export, transfer, or provide the Software to any person, or use it in or from any territory. The authoritative sources are:

3.2. Because these lists are updated regularly, you must rely on the version in force at the time you act, and not on any copy or summary that may be out of date.

4. PROHIBITED DESTINATIONS AND SANCTIONED JURISDICTIONS

4.1. You may not Export the Software, or use the Software, in, into, from, or through any Sanctioned Jurisdiction, except where such Export or use is permitted under all applicable regimes and any necessary licence or authorisation has first been obtained.

4.2. The prohibition on Export means that you may not send the Software itself to a Sanctioned Jurisdiction, and it also means that you may not carry a device or medium containing the Software into or through a Sanctioned Jurisdiction unless permitted under all applicable regimes.

4.3. The list of Sanctioned Jurisdictions changes from time to time. You must check the current position against the official sources in clause 3 before acting. As at the date of this Policy, jurisdictions subject to comprehensive or near-comprehensive measures under one or more of the applicable regimes include [insert current list of comprehensively sanctioned jurisdictions, to be confirmed against the official sources in clause 3 — for example, at the date of this Policy, Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine under US measures. This list is illustrative only and is not a substitute for checking the current official lists.

5. RESTRICTED PARTIES

5.1. Anywhere in the world, including within any single territory, you may not Export, transfer, deliver, or otherwise provide the Software (or any device or medium containing it) to any Restricted Party.

5.2. Before delivering or transferring the Software (or a device containing it) to any person or organisation, or to a national or resident of another country, you must screen the intended recipient against the applicable official lists referred to in clause 3.

5.3. If the intended recipient is named on, or is owned or controlled by a person named on, any applicable list, or belongs to a listed organisation, you must not proceed unless and until you have obtained any required licence or authorisation from the relevant competent authority. Proceeding without a required licence or authorisation may be a serious criminal offence.

5.4. A transfer of controlled technology to a national or resident of another country may constitute a Deemed Export and may itself require a licence, even where it takes place within a single territory.

6. LICENCES AND AUTHORISATIONS

7. OBTAINING LICENCES

7.1. Where an Export or transfer of the Software requires a licence or authorisation under any applicable regime, you must obtain that licence or authorisation from the relevant competent authority before you act. The relevant authorities include:

7.2. Some encryption items benefit from licence exceptions or general authorisations (for example, License Exception ENC under the EAR, or the treatment of publicly available or mass-market encryption software), which may be subject to conditions, notification, or reporting requirements. You may rely on such an exception or authorisation only where its conditions are fully satisfied.

8. ACCEPTANCE

8.1. By downloading, installing, and/or using the Software, you:

8.2. You acknowledge that a breach of applicable export-control or sanctions laws may expose you to personal civil and criminal liability, and that this Policy does not, and cannot, exhaustively state your obligations under every applicable regime.