Export Policy

1. Overview

Wire Path LLC ("WirePath") is a California company that provides a personal VPN service designed to help individuals access the open internet securely and privately — including in countries where internet access is restricted, monitored, or censored. WirePath is subject to United States export control and economic sanctions laws and regulations, and the WirePath software, service, and related technology (collectively, the "Service") may not be exported, re-exported, transferred, or accessed in violation of those laws.

Consistent with longstanding US policy supporting the free flow of information, WirePath is authorized to provide the Service to individuals in certain sanctioned countries for personal communications and circumvention use, as described in Section 4 below.

2. Applicable Laws

The Service is subject to, and your use must comply with:

• The Export Administration Regulations (EAR), administered by the U.S. Department of Commerce, Bureau of Industry and Security (BIS)
• Economic sanctions programs administered by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
• Any other applicable US laws and regulations relating to the export or re-export of technology or services

3. General Prohibitions

Except as expressly permitted by applicable law or as described in Section 4, you may not use, export, or re-export the Service to, or for the benefit of:

• Any country or territory subject to comprehensive US economic sanctions, including Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk People's Republic (DNR), and Luhansk People's Republic (LNR) regions of Ukraine
• Any person or entity on the US Treasury Department's Specially Designated Nationals (SDN) list, the Commerce Department's Denied Persons List or Entity List, or any other US government list of prohibited or restricted parties
• Any government, government-owned entity, or government official of a comprehensively sanctioned country
• Any person or entity for any end use prohibited under US export control laws, including nuclear, chemical, biological, or missile weapons applications

4. Authorized Use in Certain Sanctioned Countries

Notwithstanding Section 3, WirePath is authorized under specific OFAC general licenses to provide the Service to private individuals in certain sanctioned countries for personal communications and internet access purposes. WirePath's Service is intentionally offered as a tool for personal circumvention of censorship and government surveillance, consistent with US policy supporting the free flow of information to people in restricted environments.

Iran

WirePath is authorized to provide the Service to individuals ordinarily resident in Iran for personal, non-commercial use under OFAC General License D-2, codified at 31 C.F.R. § 560.540 (Iranian Transactions and Sanctions Regulations). General License D-2 specifically authorizes the export and supply of services incident to the exchange of personal communications over the internet — including VPN services — to persons in Iran.

This authorization does not extend to: the Government of Iran or any entity owned or controlled by it; persons on the SDN list; or use in connection with any commercial or government operation.

Cuba

WirePath is authorized to provide the Service to private individuals in Cuba for personal communications use under 31 C.F.R. § 515.578 (Cuban Assets Control Regulations), which permits services that enable the free flow of information to, from, and within Cuba.

This authorization does not extend to: the Cuban government or Cuban Communist Party officials; entities on the Cuba Restricted List; or commercial operations.

Syria

WirePath is authorized to provide the Service to private individuals in Syria for personal communications use under 31 C.F.R. § 542.526 (Syrian Sanctions Regulations), which permits services ordinarily incident to personal communications.

This authorization does not extend to: the Government of Syria; persons on the SDN list; or commercial operations.

North Korea

No general license currently authorizes the provision of VPN services to individuals in North Korea. The Service may not be accessed from or provided to persons in North Korea.

5. User Representations and Warranties

By using the Service, you represent and warrant that:

1. If you are located in Iran, Cuba, or Syria, you are a private individual using the Service solely for personal communications and internet access, and not acting on behalf of any government, government-owned entity, or sanctioned party.
2. You are not located in or a resident of North Korea, and are not accessing the Service for the benefit of any person located in North Korea.
3. You are not listed on any US government list of prohibited or restricted persons or entities, including the SDN list.
4. You will not use the Service for any purpose prohibited by US export control laws or regulations, including but not limited to the development, design, manufacture, or production of nuclear, chemical, or biological weapons.
5. You understand and acknowledge that the Service incorporates encryption technology subject to export controls under the EAR.

6. Encryption Notice

The WirePath service uses WireGuard, an open-source VPN protocol that implements state-of-the-art cryptography. WireGuard is classified under Export Control Classification Number (ECCN) 5D002 and is eligible for export under License Exception ENC pursuant to 15 C.F.R. § 740.17. WirePath has made the required annual self-classification report filings with BIS where applicable.

7. Consequences of Violation

Any use of the Service in violation of this Export Policy may result in immediate termination of your account without refund, and may expose you to civil and criminal penalties under applicable US law. WirePath reserves the right to deny service or terminate accounts where we have reason to believe that applicable export control or sanctions laws may have been or are at risk of being violated.

8. Updates

Export control laws are subject to change. We reserve the right to update this policy at any time to reflect changes in applicable law or our compliance obligations. Updated versions will be posted on this page with a revised effective date.

9. Contact

Questions about this Export Policy may be directed to: