Privacy Policy

Last updated: October 19, 2026

1. General​

This policy describes the processing of personal data by AdaptGroup LLC, registered in Wyoming, USA (the “Company”), when using the AdaptGroup platform and its services.

The policy covers partners, dashboard users, and end users of the Company's services, including the Adapt Mail email service.

The Company processes account data and information about service usage, payments, and support requests to provide services, fulfil contractual and legal obligations, protect services, and handle requests.

Processing the contents of customer systems, messages, attachments, and user files on the customer's behalf is additionally governed by the Data Processing Agreement (DPA). For this data, the customer determines the purposes of processing and the Company acts within the corresponding instructions.

This policy informs users about data processing. Where applicable law requires consent, the Company requests it separately. Using the service does not itself replace consent where consent is mandatory.

2. Partner Data​

2.1 Registration and Account​

The following data is collected upon registration:

• Email — when registering via email or Google/Yandex authorization
• Google or Yandex account — when signing in via the corresponding OAuth provider (only the necessary minimum is shared: name, email, account identifier)
• Telegram account — Telegram ID and username when linking the account

2.2 Platform Usage​

During dashboard usage, the Company collects:

• active session data (IP address, device, sign-in date)
• financial transaction history (top-ups, withdrawals, transactions)
• data on integrations and connected modules

2.3 Identity Verification​

When completing KYC, personal and biometric data is processed through Didit. The categories of data, purposes of verification, access, retention, and deletion are described in the Policy on the Processing of Personal and Biometric Data During KYC.

3. End User Data​

3.1 VPN Bots and VPN API Module​

When an end user's device connects to the VPN, the Company stores:

• hwid — hardware device identifier
• user_agent — client application identification string
• device_os — operating system
• device_model — device model
• os_version — operating system version
• ip_address — IP address at the time of the subscription request

Destination IP addresses (where the user connects through VPN) are stored by the Company. Traffic content is not analyzed or stored by the Company.

3.2 Support Bots Module​

Within the support bots module, the Company stores correspondence between operators and end users. Correspondence is not deleted automatically. Upon user request, data deletion is possible — contact support to do so.

3.3 Adapt Mail Email Service​

When providing Adapt Mail, the Company processes the following categories of data:

• information about the account, its owner, and associated mailboxes;
• logins, email addresses, and data needed to verify access;
• connected domains and information used to verify their configuration;
• IP addresses, client application information, sessions, and authentication events;
• service parameters, paid periods, storage capacity, and usage;
• technical information about sending and delivery, errors, and application of limits;
• information provided in support requests.

This data is used to provide access, manage the service, handle billing, protect accounts, investigate technical problems, and fulfil applicable obligations.

On the customer's instructions, the Company also processes message and attachment contents, separately uploaded files, contacts, drafts, signatures, templates, filter settings, and other mailbox data.

Automated content processing is performed for delivery, storage, search, display of correspondence, application of user settings, and checks for spam and viruses. This processing is governed by the DPA.

The Company does not use message or user file contents for its own advertising or sale of data.

If the service is connected through a partner, the data available to that partner depends on the permissions granted and the integration used. When using a partner's interface or application, the partner's own processing is also governed by its documents.

4. Third-Party Data Sharing​

The Company does not sell or share user data with third parties, except where necessary for service operation:

• Payment systems — when processing payments, the minimum set of data required to create a payment is shared
• Hosting providers — the platform's server infrastructure is hosted by third-party providers; data is physically stored on their servers, however access to it by providers is not provided for under the hosting terms
• Didit — data necessary for identity verification is transferred when the user completes KYC; details are provided in the specific policy

When email is sent, message contents, attachments, and necessary technical headers are transmitted to the designated recipients' email systems. When a message is received, the corresponding data comes from the sender's email system. This transmission is necessary to carry out sending or receiving email.

When a third-party email client or application is connected, data is provided within the authorized access. The user or authorized account owner is responsible for selecting those applications and managing their access.

If the service is provided through a partner, the Company shares information needed to manage the service, handle billing, and provide support within the contractual relationship and permissions granted.

The Company's engagement of other processors to process customer data is governed by the DPA.

5. Analytics​

The Company uses Google Analytics to collect aggregated traffic statistics for the dashboard and documentation. The collected data is anonymous and does not allow identification of a specific user.

6. Data Storage​

The Platform's primary data is stored on a dedicated server in Germany.

Adapt Mail messages, attachments, and user files are stored on servers managed by AdaptGroup and located in the United States.

When email is sent, a copy is transmitted to the recipient's email system and may be stored in another country. Deleting a message from Adapt Mail does not remove copies already delivered to the recipient or saved by the user in third-party applications.

Retention of mailbox contents is governed by the Adapt Mail Terms and the DPA. Access is blocked when the paid period expires; if the service is not renewed, deletion begins after 24 hours.

Account, payment, support, and security information is retained for the period needed for the corresponding processing purpose and applicable obligations. The need to retain accounting documents or incident information does not mean indefinite retention of mailbox contents.

The Company takes technical and organizational measures to protect data from unauthorized access, alteration, and loss. These measures do not constitute a backup service.

7. User Rights​

Users have the right to:

• request information about stored data
• request deletion of their data

To exercise these rights, contact support through Telegram or at [email protected]

Please note that the self-service data deletion feature through the dashboard is currently under development.

In Adapt Mail, users can manage messages and files within their permissions. Available actions depend on whether the user is logged into the owner's account or an individual mailbox.

Requests concerning data processed by the Company on a customer's behalf are handled with the involvement of the relevant customer or partner in accordance with the DPA. The requester's authority is verified before data is disclosed, changed, or deleted.

A request to delete individual messages or files is not equivalent to cancelling the paid service. Service termination and mailbox deletion follow the procedure established for that service.

8. Policy Changes​

The Company may amend this policy. The current version is published in the Platform documentation. Continued use of the Platform after changes take effect constitutes acceptance of the updated policy.

9. Contact​

For questions related to personal data processing, contact us through Telegram or at [email protected]

Company Details​

AdaptGroup LLC
30 N Gould St Ste R
Sheridan, WY 82801, USA