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Terms & Conditions

Last updated: 7 July 2026

Welcome to Noodle VPN!

Noodle VPN is operated by Underwater (“Underwater,” “we,” “us,” or “our”). Your use of the Noodle VPN application and any related apps or services we operate (the “Service”) is governed by this legal agreement (the “Terms”).

By using the Service, you are agreeing to these Terms. Please read them carefully.

You may use the Service only if you can form a binding contract with Underwater and are not barred under any applicable laws from doing so.

Eligibility

You must be at least 18 years old to use the Service. By using the Service, you represent and warrant that you are 18 or older and that you have the legal capacity to enter into these Terms.

Using our Service

You must follow any policies made available to you within the Service. You agree to use the Service only for purposes permitted by these Terms and by applicable law.

In order to use the Service, you need to establish an account. You are solely responsible for the security and confidentiality of your account and its authentication methods (such as Sign-In with Apple or any credentials you use). You are responsible for all activities that occur under your account, and you must immediately notify Underwater if you learn of any unauthorized use of your account. We may delete accounts (and all associated content) that have not been used for an extended period of time.

Using our Service does not give you any legal right, title, or interest in our Service or the content you access. You may not assign, sublicense, or otherwise transfer any part of your rights to use the Service. The Service, including the software used to provide it (the “Software”), is protected by copyright, trademark, and other intellectual property laws. These Terms do not grant you the right to use any Underwater trademarks, branding, or logos. No portion of the Service may be reproduced in any form except as expressly permitted in these Terms.

We may provide you with notices regarding the Service, including changes to these Terms, by email or by postings within the Service.

Acceptable Use and Prohibited Activities

The Service is a privacy tool intended for lawful personal use. You agree not to use the Service for any unlawful, harmful, or abusive purpose. Because a VPN routes your traffic through our servers and shared IP addresses, misuse harms other users and exposes our infrastructure — so we enforce this section strictly.

You agree that you will not (and will not permit anyone else to) use the Service to:

  • engage in, promote, or facilitate any illegal activity of any kind;
  • infringe intellectual property rights, including through peer-to-peer (P2P) file sharing, torrenting, or the unauthorized distribution of copyrighted material — P2P and torrenting are prohibited on the Service;
  • transmit, store, or access child sexual abuse material (CSAM) or any content that exploits or endangers minors — this is strictly and permanently prohibited and will be reported where required by law;
  • distribute malware, viruses, ransomware, spyware, or other malicious code;
  • send spam, bulk unsolicited messages, phishing, or engage in mail-bombing;
  • commit fraud, identity theft, or any deceptive or misleading activity;
  • gain or attempt to gain unauthorized access to any system, network, account, or data (hacking);
  • probe, scan, or test the vulnerability of any system or network, or breach or circumvent any security or authentication measures;
  • conduct denial-of-service (DoS/DDoS) attacks, flooding, or any activity that overloads or disrupts any system, host, or network;
  • harass, threaten, stalk, defame, dox, or harm any person, or engage in hate speech or the incitement of violence;
  • resell, redistribute, sublicense, or commercially exploit the Service or its bandwidth, or share your account beyond the device limits of your tier;
  • operate servers, relays, hosting, or other always-on services through the Service, or use the Service in any automated manner that is inconsistent with normal personal use;
  • reverse engineer, decompile, or attempt to extract the source code of the Software or the protocols used in the Service, unless required by law;
  • circumvent, disable, or interfere with any security mechanism, usage limit, device limit, or other restriction of the Service;
  • access or search the Service by any means other than the interfaces and instructions we provide;
  • otherwise violate the rights of any third party or the terms of any third-party service.

This list is illustrative, not exhaustive. If your use of the Service intentionally or unintentionally threatens our ability to provide the Service, or violates these Terms, we may take any reasonable steps to protect the Service and other users, including throttling, suspending, or terminating your access, with or without notice.

Free and Paid Tiers

The Service offers a free tier and one or more paid tiers.

  • The free tier includes a limited amount of data per month. The exact allowance is specified within the Service and may change at any time at our discretion. Once the allowance is reached, service may be paused or restricted until the next period.
  • Paid tiers provide unlimited data for normal personal use, subject to the Fair Use Policy below, and allow use across more than one device. The number of simultaneous devices permitted is specified per tier within the Service.

We may add, remove, or change tiers, allowances, features, and pricing at any time.

Fair Use Policy

“Unlimited” data on paid tiers is provided for ordinary personal use. It is not intended to support usage that is excessive, continuous, automated, or grossly disproportionate to what a typical individual consumer would use.

To keep the Service fast and reliable for everyone, the following are not considered fair use, including (but not limited to): sustained maximum-throughput usage over long periods (for example, streaming high-bitrate 4K video continuously, 24 hours a day, for weeks at a time); using the Service as a server, relay, or hosting platform; automated or scripted traffic generation; and reselling or sharing your bandwidth with others.

We record the total monthly data volume associated with each account solely to operate the Service and monitor fair use. We do not need, and do not keep, any record of what that data contains (see Privacy and Logging below).

Where we determine, at our reasonable discretion, that an account is breaching this Fair Use Policy, we may apply the following measures:

  1. First occurrence: temporary suspension of the account for 3 days.
  2. Second occurrence: temporary suspension of the account for 10 days.
  3. Third occurrence: permanent termination of the account.

In cases of serious or deliberate abuse, or activity that threatens the Service or other users, we may suspend or terminate immediately without following the steps above.

Privacy and Logging

Underwater takes your privacy seriously. Noodle VPN is designed as a no-activity-logs service:

  • We do not log your browsing history, the websites or services you connect to, your DNS queries, the contents of your traffic, or the destination IP addresses you visit. We cannot see, and do not record, what you do while connected.
  • We do record limited information necessary to operate the Service, including the total monthly data usage associated with your account, in order to enforce tier allowances and the Fair Use Policy, and to maintain and secure the Service.

Our full practices — including what we collect, why, and how we handle it — are described in our Privacy Policy, available within the Service. We share personal information only in the limited circumstances described there, such as where required to comply with valid legal process. By using the Service, you agree to the collection and use of information in accordance with that Privacy Policy.

Because your traffic exits through our servers and shared IP addresses, third parties (such as copyright holders, targeted services, or hosting providers) may send abuse or copyright complaints — including notices under the U.S. Digital Millennium Copyright Act (DMCA) — relating to activity seen from one of our IP addresses.

If you believe activity originating from the Service infringes your rights, or you need to report abuse, please contact us at support@underwwwater.com with sufficient detail (such as the relevant IP address, date, and time in UTC).

Please understand:

  • Consistent with our no-activity-logs design, we generally cannot attribute network activity to any individual user, and we do not retain the logs that would allow us to do so.
  • We will nonetheless review valid complaints and take reasonable action within our control, which may include blocking specific ports or protocols, applying network-level mitigations, and cooperating with valid legal process to the extent we are able.
  • Where we are able to identify an account engaged in activity that violates these Terms, we may suspend or terminate it.

We use both our own servers and servers rented from third-party providers, and we may take these measures on either in order to protect the Service and comply with our providers’ requirements.

About Software in our Service

The Software may from time to time automatically download and install updates from Underwater. These updates are designed to improve, enhance, and further develop the Service and may take the form of bug fixes, enhanced functions, or entirely new versions of the Software. You agree that Underwater may automatically deliver such updates to you as part of your use of the Service, and that you shall receive and install them as required.

Underwater grants you a personal, non-assignable, non-exclusive, limited license to use the Software provided as part of the Service, for the sole purpose of enabling you to use the Service in the manner permitted by these Terms. You may not (or permit anyone else to) copy, modify, rent, loan, distribute, sell, lease, sublicense, assign, grant a security interest in, or otherwise transfer any right in any part of the Service or Software, nor reverse engineer, decompile, or attempt to extract its source code, unless expressly permitted or required by law.

Modifying and Terminating our Service

We are constantly modifying and improving our Service. We may add or remove features or functionality, and we may temporarily suspend or discontinue the Service altogether. We may, at any time, change or impose fees for access to and use of the Service.

You can stop using the Service at any time. Underwater may also stop providing the Service to you at any time, with or without cause, and with or without notice. For example, we may immediately suspend or terminate your use if you are not complying with these Terms, or if your use would cause us legal liability or disrupt others’ use of the Service.

If we suspend or terminate the Service or your account, we will try to give you reasonable advance notice and a chance to delete your account yourself where practicable. After a period of time, however, Underwater may permanently delete the content associated with your account.

Refunds

If we terminate the Service (other than for your violation of these Terms), you may be eligible for a refund proportional to the unused portion of your subscription period, calculated based on the remaining days at the time of termination.

Payments made through Apple (App Store) are subject to Apple’s terms and conditions, and any refund must be requested through Apple in accordance with those terms.

Payments made through Google Play are subject to Google’s terms and conditions, and any refund must be requested through Google in accordance with those terms.

For payments made directly to us (for example, by card and not through Apple or Google), the following refund policy applies:

  • Full refund: If you cancel within the first 24 hours (1 day) from the start of the subscription, you are eligible for a full refund of the subscription fee.
  • Partial refund: If you cancel within the first half of the subscription period (from the start of the subscription to its midpoint), you are eligible for a refund of 50% of the price paid.
  • No refund: If you cancel after the midpoint of the subscription period, you are not eligible for a refund.

Additional conditions:

  • Users are entitled to this type of refund only once every 365 days.
  • To request a refund, you must notify us of your intention to cancel by contacting support@underwwwater.com.
  • It may take up to 30 days to process your refund request, plus additional banking time beyond our control.
  • If your account is suspended or terminated due to a violation of these Terms, no refund will be issued.

Exclusion of Warranties

NOTHING IN THESE TERMS, INCLUDING THIS SECTION, SHALL EXCLUDE WARRANTIES WHICH MAY NOT BE LAWFULLY EXCLUDED BY APPLICABLE LAW.

YOU EXPRESSLY UNDERSTAND AND AGREE THAT YOUR USE OF THE SERVICE IS AT YOUR SOLE RISK AND THAT THE SERVICE IS PROVIDED “AS IS” AND “AS AVAILABLE.”

UNDERWATER MAKES NO EXPRESS WARRANTIES AND DISCLAIMS ALL IMPLIED WARRANTIES REGARDING THE SERVICE, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WITHOUT LIMITING THE FOREGOING, UNDERWATER DOES NOT REPRESENT OR WARRANT THAT: (A) YOUR USE OF THE SERVICE WILL MEET YOUR REQUIREMENTS, OR (B) YOUR USE OF THE SERVICE WILL BE UNINTERRUPTED, TIMELY, SECURE, OR FREE FROM ERROR.

Limitation of Liability

NOTHING IN THESE TERMS, INCLUDING THIS SECTION, SHALL LIMIT UNDERWATER’S LIABILITY FOR LOSSES WHICH MAY NOT BE LAWFULLY LIMITED BY APPLICABLE LAW.

YOU EXPRESSLY UNDERSTAND AND AGREE THAT UNDERWATER SHALL NOT BE LIABLE TO YOU FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES, HOWEVER CAUSED AND UNDER ANY THEORY OF LIABILITY. THIS INCLUDES, BUT IS NOT LIMITED TO, ANY LOSS OF PROFIT (WHETHER INCURRED DIRECTLY OR INDIRECTLY), ANY LOSS OF GOODWILL OR BUSINESS REPUTATION, ANY LOSS OF DATA, COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, OR OTHER INTANGIBLE LOSS.

THE LIMITATIONS ON UNDERWATER’S LIABILITY ABOVE SHALL APPLY WHETHER OR NOT UNDERWATER HAS BEEN ADVISED OF, OR SHOULD HAVE BEEN AWARE OF, THE POSSIBILITY OF ANY SUCH LOSSES.

Indemnity

You agree to hold harmless and indemnify Underwater and its affiliates, employees, and partners from and against any third-party claim arising from or in any way related to (a) your breach of these Terms, (b) your use of the Service, or (c) your violation of any applicable laws, rules, or regulations in connection with the Service, including any liability or expense arising from all claims, losses, damages (actual and consequential), suits, judgments, litigation costs, and attorneys’ fees of every kind and nature. In such a case, Underwater will provide you with written notice of the claim, suit, or action.

About these Terms

These Terms may change from time to time. We will post notice of modifications within the Service or on our website. In the case of substantial changes, we may, at our discretion, provide a prominent notice (for example, a dialog in the app or an email with the updated Terms). If you use the Service after the date on which the Terms have changed, Underwater will treat your continued use as acceptance of the updated Terms.

Certain components of the Service may require separate software or other license agreements or terms of use. You must read, accept, and agree to any such separate agreements as a condition of using those components or features.

If you do not comply with these Terms and we do not take action right away, this does not mean we are giving up any rights we may have (such as taking action in the future).

These Terms control the relationship between you and Underwater. They do not create any third-party beneficiary rights.

Upon any termination of the Service under the section “Modifying and Terminating our Service,” these Terms will also terminate, except that the sections “Acceptable Use and Prohibited Activities,” “Abuse and Copyright (DMCA) Complaints,” “Exclusion of Warranties,” “Limitation of Liability,” “Indemnity,” and “About these Terms” shall continue to be effective after termination.

This is the entire agreement between you and Underwater with respect to the Service, and it supersedes and replaces any prior representations, discussions, undertakings, communications, or advertising relating to the Service. If any part of this agreement is found invalid or unenforceable, the remaining portions will remain in full force and effect, and an enforceable term will be substituted reflecting our intent as closely as possible.

This agreement will be governed by and construed in accordance with the substantive laws in force in South Korea.