Abuse & DMCA Policy

1. Introduction

Akca Network OÜ (Registry Code 17404115), operating as AkcaVPN, is committed to preventing the misuse of our service. We believe in providing a private, secure VPN while maintaining responsibility toward the broader internet community.

We operate a strict no-logs VPN, meaning our ability to identify individual users based on network traffic is extremely limited. This is a deliberate architectural decision to protect the privacy of all our users.

This policy explains how we handle abuse reports, DMCA copyright notices, and law enforcement requests, and what actions we can and cannot take given our infrastructure.

2. Our No-Logs Architecture

To understand our response capabilities, it is important to understand what we do and do not record:

• We do not log traffic content or destinations
• We do not log connection timestamps
• We do not log user IP addresses
• We do not log browsing activity or DNS queries
• We do not log bandwidth usage per user

This means we generally cannot identify which user was responsible for specific traffic that passed through our servers. This is not a loophole or an oversight. It is by design, to protect the privacy and security of all our users.

3. Abuse Reports

We take all abuse reports seriously and review each one carefully.

3.1 How to Submit an Abuse Report

Send your report to abuse@akca.network with the following information:

• Date and time of the incident (include timezone)
• IP address involved in the abuse
• Description of the abusive activity
• Evidence such as log excerpts, screenshots, or packet captures

3.2 What We CAN Do

3.3 What We CANNOT Do

4. DMCA & Copyright Notices

We respect intellectual property rights and take copyright infringement seriously.

4.1 Submitting a DMCA Notice

Send DMCA notices to abuse@akca.network with the subject line "DMCA NOTICE". Per the Digital Millennium Copyright Act, your notice must include:

1. Identification of the copyrighted work claimed to have been infringed
2. Identification of the infringing material and information sufficient to locate it (IP address, date, time, protocol)
3. Your contact information including name, address, telephone number, and email
4. A good faith statement that the use of the material is not authorized by the copyright owner, its agent, or the law
5. A statement of accuracy that the information in the notice is accurate, and under penalty of perjury, that you are authorized to act on behalf of the copyright owner
6. Your physical or electronic signature

4.2 Our Response

Due to our no-logs architecture:

• We cannot identify specific users who may have been involved in copyright infringement through our network
• We cannot provide user data, traffic logs, or connection records because they do not exist
• We may block specific traffic patterns at the server level if technically feasible and if a persistent pattern of infringement is identified on a particular server
• We cooperate with valid court orders issued under Estonian or EU law

5. Law Enforcement Requests

We comply with valid legal processes under Estonian and EU law.

5.1 What We Require

• A valid court order or legal process issued by an Estonian court, or through applicable EU mutual legal assistance treaties
• Requests must be sent through official channels to our registered address
• We verify the authenticity and legal validity of all requests

5.2 What We Can Provide

We can only provide data we actually possess, which is minimal. See our Privacy Policy for a complete list of what data we hold.

• We cannot provide traffic logs, browsing history, or connection data (never collected)
• We can confirm whether a specific account exists
• We can provide payment-related blockchain transaction data (which is already publicly available on-chain)

5.3 Transparency

• We publish transparency reports detailing the number and nature of requests received
• We will notify users of requests targeting their accounts if legally permitted to do so
• We will challenge requests that are overbroad, legally deficient, or that we believe infringe on user rights

6. Prohibited Activities

Users must not use AkcaVPN for any of the following activities:

• Terrorism or violent extremism - Planning, promoting, or facilitating terrorist acts or violent extremist content
• Active hacking or unauthorized access - Attempting to gain unauthorized access to computer systems, networks, or data
• Distribution of malware - Creating, distributing, or deploying malicious software, ransomware, or viruses
• Spam or mass unsolicited communication - Sending bulk unsolicited emails, messages, or other communications
• Denial of service attacks - Launching or participating in DDoS or DoS attacks against any target
• Fraud or identity theft - Engaging in fraudulent activities, phishing, or impersonation for financial gain or to cause harm

This list is not exhaustive. Any activity that violates applicable law or our Terms of Service is prohibited.

7. Network-Level Actions

Even without the ability to identify individual users, we can take the following server-level actions to address abuse:

• Block specific ports or protocols - Disable certain ports on a server if they are being exploited for abuse (e.g., SMTP port 25 to prevent spam)
• Rate-limit certain traffic patterns - Throttle traffic that matches known abuse signatures
• Null-route specific destination IPs - Block outbound traffic to specific targets that are being attacked from our infrastructure
• Temporarily take a server offline - In severe cases, remove a server from service entirely until the issue is resolved

8. Account Termination

We reserve the right to terminate or suspend access to our service if we become aware of Terms of Service violations through means other than traffic monitoring, including but not limited to:

• User self-reporting or admission of prohibited activity
• Publicly available information linking an account to prohibited activity
• Valid court orders requiring account termination
• Reports from other service providers with credible evidence

8.1 NFT-Based Users

NFT ownership on the blockchain is separate from service access. We can revoke the ability of an NFT to authenticate with our servers without affecting the NFT itself. The NFT remains the user's property on-chain, but it will no longer grant access to AkcaVPN services.

8.2 Serial Number Users

Access associated with a serial number (account number) can be revoked immediately and without refund if the account is found to be involved in prohibited activities. No refund will be issued for terminated accounts.

9. Transparency

We are committed to transparency about how we handle abuse reports and legal requests.

• Annual transparency reports - We will publish yearly reports detailing the number of abuse reports, DMCA notices, and law enforcement requests we receive, along with our responses
• Challenge overbroad requests - We will legally challenge any request we believe to be overbroad, legally insufficient, or an infringement on user privacy rights
• User notification - We will notify users of legal requests targeting their accounts whenever we are legally permitted to do so
• Warrant canary - We will maintain public indicators of categories of legal demands we have not received

10. Estonian & EU Legal Framework

Akca Network OÜ operates under Estonian law as an EU member state. The following regulations are relevant to our operations and this policy:

10.1 EU E-Commerce Directive (2000/31/EC)

The E-Commerce Directive provides liability protections for intermediary service providers. While VPN providers are not explicitly categorized as "mere conduits" under EU law because we operate encrypted tunnels rather than simply transmitting data, our no-logs architecture means our practical obligations regarding user data disclosure are inherently limited.

10.2 Estonian Electronic Communications Act

As an Estonian entity, we comply with the Estonian Electronic Communications Act. This legislation governs data retention obligations for communications providers. Our no-logs architecture is designed to minimize retained data to only what is strictly necessary for service operation.

10.3 General Data Protection Regulation (GDPR)

GDPR governs our processing of personal data. Our data minimization approach aligns with GDPR's principles of purpose limitation and data minimization. See our Privacy Policy for full GDPR compliance details.

10.4 Jurisdiction

Any disputes arising from this policy shall be governed by Estonian law and resolved in Estonian courts. International requests must be processed through applicable mutual legal assistance treaties (MLATs) or EU cooperation mechanisms.

11. Contact for Abuse Reports