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Bandwidth Sharing Terms (Opt-In)

ROOT VPN LTD · Version 1.0 · Effective 6 September 2026

These Bandwidth Sharing Terms ("Sharing Terms") are a separate, optional agreement between you and ROOT VPN LTD, a company registered in England and Wales ("ROOT VPN", "we", "us", "our"). We operate the ROOT VPN service.

These Sharing Terms apply only if, and only for as long as, you actively choose to enable Bandwidth Sharing. They are deliberately kept separate and unbundled from the ROOT VPN general Terms of Service and from the ROOT VPN Privacy Policy. You do not have to agree to these Sharing Terms to use ROOT VPN. If you do not enable Bandwidth Sharing, none of this document applies to you and the VPN works fully.

1. Plain-English summary of the exchange

ROOT VPN offers a free tier. The free tier is funded by an opt-in idle-bandwidth sharing arrangement, which works like this:

• What you give: while your device is idle and meets your conditions, you let a small part of your unused ("idle") internet bandwidth and your IP address act as a residential exit point for the requests of our verified business customers.
• What you get: free access to ROOT VPN premium features ("Rewards"), at no monetary cost, for as long as you keep sharing enabled and remain within fair-use limits (see section 8).

This is a value-for-value exchange: you contribute spare capacity; we give you premium features for free. If you prefer not to take part, you can either use the free tier without sharing where available, or take the paid subscription tier, on which sharing is disabled by default and not required.

Enabling Bandwidth Sharing means, in law, that you are giving your consent for us (and the business customers we route through your connection) to:

1. store and gain access to information on your device to the limited extent needed to operate sharing; and
2. use your internet connection to carry allow-listed commercial traffic,

as described below. This consent is required under the Privacy and Electronic Communications Regulations 2003 (PECR) and is the lawful basis (consent) we rely on under the UK GDPR. See section 6.

2. Exactly what IS shared

When Bandwidth Sharing is enabled and all of your conditions are met at the same time, we may use:

• (a) Idle upstream and downstream bandwidth: a portion of your unused network capacity, subject to the caps and controls you set (section 7); and
• (b) Your public IP address: used as a residential exit so that a verified business customer's allow-listed request appears to originate from your connection.

Sharing is only active while all of the following conditions you control are satisfied at once (defaults shown; all adjustable, see section 7):

• Connectivity: you are on Wi-Fi / an unmetered connection (mobile data excluded by default);
• Power: your device is charging (or above a battery threshold you set);
• Activity: your device is idle (you are not actively using it);
• Data cap: you are under the monthly data cap you have set.

If any condition stops being met, sharing pauses automatically and immediately.

3. Exactly what is NEVER shared or accessed

We want to be completely clear about the boundaries. When you enable Bandwidth Sharing we do not, and the arrangement does not, involve any of the following:

• We never access your files. No documents, photos, media, messages, or any stored content on your device.
• We never share, read, intercept, or log your own browsing or personal internet traffic. Your personal activity is not part of the pool and is not routed to business customers.
• We never sell or share your personal data as part of this arrangement beyond what is strictly necessary to operate sharing and comply with law (see the Privacy Policy).
• We do not read, inspect, or log the content of any peer's browsing. The traffic that exits via your connection belongs to KYC-verified business customers and is limited by policy (section 4); we do not use sharing as a means to look at what you do online.
• Your IP is used as a network exit only. It is not linked publicly to your identity by us as part of this arrangement.

If we ever needed to change these boundaries, that would require fresh, specific consent from you; we would not do it silently.

4. What your connection is used for

While sharing is active, your connection may be used to route requests made by our business customers who have completed identity verification (KYC). Those requests are restricted as follows:

• Allow-listed commercial destinations only. Traffic is limited to an allow-list of legitimate commercial destinations (for example retail websites, social platforms, ticketing platforms and similar) used for lawful business purposes such as market research, ad verification, price comparison, and brand protection.
• Per-person and per-destination limits. We apply rate and volume limits (for example, per-person purchase or request limits on ticketing/retail) to keep usage proportionate.
• Prohibited uses are blocked by policy. Uses that are unlawful or abusive are forbidden and are blocked at the network level wherever technically possible. This includes anything that could breach the Computer Misuse Act 1990 (e.g. unauthorised access), fraud, intrusion, malware distribution, attacks on infrastructure, accessing accounts that are not the customer's own, or targeting sensitive destinations. See the Acceptable Use Policy (AUP), which forms part of this arrangement.

The destination allow-list and the AUP exist specifically to keep the traffic that exits via your connection lawful and limited. We reserve the right to update the allow-list to remove destinations or tighten limits at any time.

5. Your rewards (free premium, not a cash payment)

• In return for sharing, you receive free access to ROOT VPN premium features ("Rewards"), described in-app.
• Rewards are provided as free service, not as a cash payment. You are not being paid money, and you should not treat sharing as a source of income. This is a deliberate product decision.
• Rewards are subject to fair-use caps (section 8) and to your continued eligibility and compliance with these Sharing Terms and the AUP.
• We may change the specific premium features included as Rewards from time to time (section 11).

6. Your consent: how it works

Enabling Bandwidth Sharing records your consent. We have designed the consent to meet the standards of PECR and the UK GDPR. Your consent is:

• Freely given: you are never required to enable sharing; the VPN works fully without it, and declining has no detrimental effect on the free tier features you already have;
• Specific: it covers only the storing/accessing of limited device information and the use of your connection as described here, and nothing more;
• Informed: these Sharing Terms and the in-app consent screen explain, in plain terms, exactly what happens;
• Unbundled: this consent is separate from accepting the general Terms of Service and Privacy Policy. Agreeing to use ROOT VPN does not switch sharing on. Sharing is a distinct, additional opt-in that you must deliberately turn on;
• An affirmative action: sharing is off by default; you must actively enable it. There are no pre-ticked boxes;
• Revocable at any time: see section 9.

Consent ledger. Each time you give, change, or withdraw consent we record an entry in a consent ledger, including the version of these Sharing Terms you agreed to and timestamps. You can request a copy of your consent history via privacy@rootvpn.app.

7. Conditions engine and your controls

Bandwidth Sharing is governed by a conditions engine with safe defaults. You can review and adjust all of the following in the app:

• Wi-Fi / unmetered only (default: on, mobile data excluded);
• Charging required (default: on) or a battery threshold;
• Idle-only: share only when the device is not in active use (default: on);
• Monthly data cap for shared traffic (a conservative default applies);
• Scheduling: optional quiet hours / allowed hours;
• Master toggle: a single control to enable or disable sharing entirely.

Defaults are chosen to be conservative and protective of you (your battery, your data allowance, your performance). You may make them stricter at any time.

8. Fair-use caps

To keep the pool healthy and to protect your device and data allowance, Rewards and sharing are subject to fair-use caps, for example maximum shared data per month, maximum concurrent sessions, and Rewards tier thresholds, as described in-app. Exceeding, attempting to game, or automating around these caps may result in suspension (section 10).

9. Withdrawing consent (one-tap, immediate)

• You can withdraw consent and stop sharing at any time using the one-tap toggle in the app. Withdrawal takes immediate effect. Active sharing sessions on your connection are terminated promptly.
• Withdrawing is easy and free, and it is as easy to withdraw as it was to give consent.
• Withdrawing consent does not affect the lawfulness of sharing that happened before withdrawal.
• After withdrawal you keep using ROOT VPN. Depending on the product rules in force at the time, some premium Rewards may end because they were funded by sharing; this will be made clear in-app before you confirm.
• You can also withdraw by emailing privacy@rootvpn.app, though the in-app toggle is faster.

10. Eligibility, integrity and suspension

• Eligibility: you must be 18 or over and the account holder for, or an authorised user of, the internet connection you are sharing. You must not enable sharing on a connection where doing so would breach your ISP contract, your employer's or landlord's rules, or any other person's rights. You are responsible for ensuring you are permitted to share the connection you use.
• Integrity of the pool: to protect the service, other users, and business customers, we may suspend or disable your sharing (and associated Rewards) if we reasonably believe there is fraud, abuse, breach of the AUP, circumvention of caps, or a security or legal risk.
• Suspension of sharing does not remove your right to use ROOT VPN itself, subject to the general Terms of Service.

11. Risks and responsibilities (disclosed honestly)

We want you to make an informed choice. You should understand the following:

• Other parties' traffic exits via your connection. When sharing is active, lawful, allow-listed requests made by verified business customers will leave the internet from your IP address. To an outside website, some activity may appear to originate from your connection.
• The controls that limit this: the KYC verification of customers (section 4), the destination allow-list, per-person and per-destination limits, policy-level blocking of prohibited uses, and the AUP. These exist to keep exiting traffic lawful and proportionate.
• No system is perfect. Despite these controls, we cannot guarantee that every request will always be free of misuse. If you are not comfortable with this, do not enable sharing, or disable it.
• How to stop instantly: use the one-tap toggle to withdraw consent (section 9). Sharing stops immediately.
• Your device and data: sharing is designed to use only idle capacity under your conditions, but you remain responsible for your own data allowance and device settings; use the controls in section 7 to stay within limits that suit you.
• We stand behind the model: where required by law, nothing here excludes any liability that cannot lawfully be excluded.

12. Changes to these Sharing Terms

• We may update these Sharing Terms. If a change is material (for example, it changes what is shared, what your connection is used for, or your consent), we will give you advance notice and, where the change alters the scope of what you consented to, we will ask you to re-consent. Continued sharing after a non-material update means you accept it.
• Each version is recorded in the consent ledger (section 6).

13. Contact

• Sharing / privacy questions: privacy@rootvpn.app
• Data Protection Officer: dpo@rootvpn.app
• Product support: support@rootvpn.app

Company details

ROOT VPN LTD
Registered in England and Wales
Company number: [to be added]
Registered office: [to be added]

Consent summary box (for the in-app consent screen)

ROOT VPN LTD, registered in England and Wales. Terms · Privacy · Acceptable Use