Shiild DNS Privacy Policy

1. Controller Information

The controller responsible for the processing of personal data under this Privacy Policy is:

General Code LTD
British Virgin Islands
Email: [email protected]

This Privacy Policy applies to the Shiild DNS service (the “Service”), which is provided to end users via compatible network devices (including routers) and associated web interfaces. The Service is offered globally and is intended for consumer (B2C) use only.

2. Roles and Processing Structure

General Code LTD acts as the data controller, determining the purposes and means of processing personal data in connection with the Service.

DNS resolution and filtering are performed by AdGuard, which acts as a data processor on behalf of General Code LTD under a data processing agreement. AdGuard processes DNS-related data solely in accordance with our instructions and applicable data protection law.

3. Categories of Data Processed

The categories of data described below represent typical processing activities and may vary depending on configuration, features enabled, and applicable legal requirements.

3.1 DNS and Network Data

To provide the Service, we process network and DNS-related data that may include IP addresses, domain name requests, timestamps, and technical information necessary to resolve and filter DNS queries, ensure network security, and prevent abuse.

DNS-related data is processed solely to operate, secure, and improve the Service. It is not used for advertising, profiling, or resale.

DNS data processing, anonymization, and retention are handled in accordance with the practices of our DNS infrastructure provider acting as a data processor on our behalf.

3.2 Aggregated Service Usage Metrics

The Service processes aggregated and anonymized service usage metrics relating to the integration and operation of the Service. These metrics may include information such as the number of integrated devices, service activations, opt-in and opt-out status, subscription tiers, and regional distribution.

Aggregated metrics are used for operational monitoring, capacity planning, product improvement, and contractual reporting. They do not include individual browsing histories or allow identification of individual end users.

3.3 Account and Configuration Data

Depending on the configuration of the Service, DNS usage may be associated with an account, a device or router identifier, or an anonymous token used to enable the Service.

3.4 Operational Telemetry

We process limited operational and technical data necessary to maintain the reliability, security, and availability of the Service. This may include service health information, integration status, and technical diagnostics.

Such data is processed solely for operational purposes and retained only for as long as necessary.

3.5 Email Communications and Engagement Data

When we send emails related to the Service, we may process data such as your email address, account identifiers, partner or integration identifiers, subscription or entitlement status, country or region where available, message template, campaign or lifecycle stage, delivery events, bounce events, unsubscribe events, and link-click events.

Links in emails may use a Shiild-controlled tracking domain, redirect link, random token, or pseudonymous identifier so that we can measure whether Service communications are delivered, clicked, unsubscribed from, and whether they help users understand or use the Service. These identifiers are not intended to contain directly readable email addresses, account IDs, or other direct personal identifiers.

Server and HTTP logs connected with email links may include technical request data such as timestamp, requested URL, redirect token, truncated or otherwise minimized IP address, user-agent information, and basic security or error information. We seek to minimize these logs, use aggregated or anonymized reporting where practical, and use pseudonymous identifiers where user-level attribution is needed for a limited period.

4. Purposes of Processing

• DNS resolution and delivery of the Service
• Malware, phishing, and harmful domain blocking
• Ad and tracker blocking
• Parental control and content category filtering
• Network security and abuse prevention
• Service reliability, performance monitoring, and debugging
• Aggregated analytics and product improvement
• Subscription and entitlement management (where applicable)
• Service, account, security, support, billing, verification, and operational communications
• Product education, feature, upgrade, lifecycle, and promotional communications where permitted by law or where any required consent has been provided
• Managing email preferences, unsubscribe requests, suppression lists, delivery, bounce handling, and communication performance measurement

DNS and browsing-related Service data is not used for advertising targeting, behavioral advertising, profiling for resale, or resale to advertisers.

5. Legal Basis for Processing

• Performance of a contract
• Legitimate interests in operating, securing, and improving the Service
• Legitimate interests in sending Service-related communications, measuring communication performance, preventing abuse, and maintaining email suppression records
• User consent, where required for specific features or configurations
• Compliance with legal obligations

6. Data Sharing and Disclosure

• Processing by AdGuard as a data processor
• Processing by email delivery, hosting, logging, analytics, and infrastructure providers acting on our behalf
• Compliance with legal obligations or lawful authority requests
• Protection of the security, integrity, and availability of the Service
• Prevention of abuse, fraud, or malicious activity

Where paid features are offered, payment-related personal data such as purchase identifiers, billing metadata, and transaction records may be processed by our payment platform provider Stripe on behalf of the seller, LRK Technology Limited, Hong Kong. We do not receive or store full payment card details, which are handled directly by Stripe.

7. International Data Transfers

The Service operates globally using distributed infrastructure. Personal data may be processed outside the user’s country of residence, including outside the EU/EEA.

Where required, appropriate safeguards are applied, including standard contractual clauses and equivalent protections. Processing by AdGuard follows its established international data protection mechanisms.

8. Data Retention

DNS-related data retention and anonymization follow AdGuard’s published DNS privacy policy.

Aggregated service usage metrics are retained for as long as necessary for operational and contractual purposes.

Operational telemetry is retained only for as long as required to maintain service reliability and security.

Email delivery, click, bounce, unsubscribe, and suppression data is retained for as long as necessary to send Service communications, manage preferences, honor unsubscribe requests, prevent abuse, troubleshoot delivery issues, and measure communication performance. Raw HTTP logs related to email link redirects are minimized and retained only for as long as necessary for security, troubleshooting, attribution, and operational reporting.

Aggregated, de-identified, or anonymized email performance reporting may be retained for longer where it no longer identifies an individual user. Suppression records may be retained for as long as needed to ensure that users who have unsubscribed are not sent non-essential communications.

9. User Rights

• Request access to personal data
• Request correction or deletion of personal data
• Object to or restrict certain processing
• Withdraw consent where processing is based on consent
• Unsubscribe from or object to non-essential communications where applicable
• Lodge a complaint with a supervisory authority

Requests may be submitted to [email protected] and will be handled within the timeframes required by applicable law (normally within 30 days).

10. Children and Family Use

The Service is not directed at children under the age of 16.

DNS requests originating from devices used by children may be processed where such devices are part of a household or network using the Service. Such data is processed in the same manner as other DNS data and is not knowingly used to identify or profile children. Parental control features are intended to be configured and managed by parents or legal guardians.

11. Web Interfaces and Cookies

Web interfaces associated with the Service may use cookies or similar technologies for authentication, session management, analytics, and router integration. Cookies are not used for third-party advertising purposes.

Email links may use redirect tokens or similar technical mechanisms to route users to Shiild pages, process unsubscribe requests, measure link performance, prevent abuse, and maintain the security and reliability of the communication system.

12. Changes to This Policy

This Privacy Policy may be updated from time to time. Material changes will be reflected by an updated “Last updated” date.

13. Contact

For privacy-related questions or requests, contact [email protected].