Surfshark POLITICAL

Corporate Communications & Public Stance

• Surfshark’s public materials describe its mission in terms of online privacy, security, and an open internet. ¹

• Its Emergency VPN programme offers six months of free VPN access to journalists, NGO representatives, and activists facing censorship or surveillance, without an Israel-, Palestine-, or Gaza-specific programme description on the reviewed page. ²

• Surfshark’s facial-recognition research treats “Palestine” separately because it identified Israeli-government use of facial recognition to monitor Palestinians in the West Bank. ³

• That facial-recognition reference appears in a surveillance-and-privacy research methodology and does not itself state a position on military operations, settlements, civilian harm, or the wider armed conflict. ³

• No public evidence identified of a Surfshark statement specifically addressing Israel–Palestine, Gaza, the 7 October attacks, a call for peace, support for either party, or conflict-related humanitarian assistance.

• No public evidence identified in the focused domain searches of dated Israel/Palestine-related statements, donations, lobbying or advocacy roles, military-welfare or settlement-organisation support, or conflict-related asset mobilisation by Nord Security co-founders Tomas Okmanas, Eimantas Sabaliauskas, and Jonas Karklys, or by the identified Surfshark and Nord Security executives. ^{1, 4, 5}

Operations in Occupied or Contested Territories

• Surfshark continues to market eight Israeli VPN servers and directs users to select Tel Aviv to obtain an Israeli IP address. ⁶

• The Israel-facing product page describes encrypted traffic and RAM-only, high-speed VPN infrastructure as features of this consumer privacy service. ⁶

• Surfshark’s general VPN location list includes Israel among its advertised server locations and labels the Israel entry with Dynamic MultiHop, P2P, Static, and Dedicated IP features. ⁷

• Surfshark’s server documentation distinguishes virtual from physical servers, explaining that a virtual server can provide an IP address different from its actual location; accordingly, Tel Aviv-labelled or Israeli-IP marketing does not by itself establish that the endpoint is physically located in Israel or in occupied or contested territory. ^{6, 7}

• The Israel-specific page depicts Jaffa and identifies no Israeli government partner, state customer, defence, police, intelligence, settlement entity, or conflict-specific use case. ⁶

• Surfshark’s app remains listed in Apple’s Israel App Store, where Apple identifies the provider as “SURFSHARK LTD”; Apple states that the listed privacy disclosures are developer-supplied and not verified by Apple. ⁸

• Storefront availability establishes consumer-app availability in Israel, not an Israeli corporate establishment, state relationship, physical infrastructure location, subscription volume, local revenue, tax residency, workforce, distributor terms, or public-sector use. ⁸

• The available Surfshark materials do not disclose individual server addresses, physical host, IP ranges, hardware ownership, hosting contracts, reseller arrangements, local contracting party, public-sector customers, or infrastructure in the West Bank, East Jerusalem, the Golan Heights, or Israeli settlements. ^{6, 7}

• DataPacket advertises dedicated-server capacity at the Bareket Data Center in Petah Tikva, but no direct record establishes Surfshark as a DataPacket customer. ⁹

• Surfshark’s privacy policy identifies Surfshark B.V. as controller and describes group-company transfer locations as the EEA, United States, and United Kingdom, while listing the United States for its reseller, distribution, and app-store-partner category; it does not identify an Israeli group company, processor, reseller, or data-transfer recipient. ¹⁰

• This policy disclosure does not establish that no other Israel-related commercial arrangement exists. ¹⁰

• Deloitte’s 10 June 2025 reasonable-assurance report was addressed to Surfshark B.V.’s board and concerned IT-system configuration and supporting IT operations; the retrieved report identifies Surfshark B.V.’s Amsterdam address but does not identify an Israeli host, endpoint location, public-sector customer, or Israeli operating entity. ¹¹

• The supplied document-scoped checks found no mention of Surfshark in the 2023 OHCHR settlement-business database, the 2024 OHCHR progress report, or the UN Human Rights Council report A/HRC/59/23. ^{12, 13, 14}

• These document-scoped results do not establish absence from all UN, civil-society, procurement, regulatory, territorial-presence, or infrastructure records. ^{12, 13, 14}

• No public evidence identified of Surfshark equipment, services, resellers, or facilities in the West Bank, East Jerusalem, the Golan Heights, or settlement locations. ^{6, 7}

• No public evidence identified of legal, regulatory, UN-database, international-body, boycott, divestment, or sanctions scrutiny naming Surfshark for Israel- or settlement-related conduct.

Internal Governance, Content & Retail Policies

• Surfshark’s identified Israel-facing product is a VPN service rather than a physical retail product, and the reviewed Israel page does not describe product-origin labelling or settlement-origin categorisation. ⁶

• No public evidence identified of Surfshark employee discipline, employment litigation, union disputes, or enforcement of political-speech or symbol rules concerning Israel–Palestine.

• No public evidence identified of Surfshark platform moderation, app-distribution restrictions, enterprise-device deployment, or suppression of Palestine- or Gaza-related content.

• No public evidence identified of a Surfshark retail, supply-chain, sourcing, or product-labelling controversy connected to Israel–Palestine.

Brand Heritage & State Partnerships

• Surfshark states that it is based in the Netherlands and has offices in Vilnius and Kaunas, Lithuania; Warsaw, Poland; and Berlin, Germany. ¹

• Surfshark’s privacy policy identifies Surfshark B.V., Kabelweg 57, 1014BA Amsterdam, as the service provider and GDPR data controller, with Dutch Chamber of Commerce number 81967985 and VAT number NL862287339B01. ¹⁰

• The UK Information Commissioner’s Office registers Surfshark B.V., trading as Surfshark, as a data controller at the Amsterdam address under reference ZB412009 for the period from 18 October 2022 to 17 October 2026. ¹⁵

• No public evidence identified in the reviewed entity materials of an Israeli Surfshark or Nord Security legal entity, branch, office, distributor, or franchisee; this does not establish the absence of Israeli customers, servers, contractors, vendors, or service availability. ^{1, 10, 5}

• No public evidence identified of Israeli defence-sector origins, military heritage, state-security branding, Israeli state honours, formal Israeli governmental or academic partnerships, or state-backed public-relations sponsorship.

Lobbying, Advocacy, Financing & Logistics

• Surfshark announced on 1 February 2022 that it and Nord Security would form a group while retaining autonomous operations, separate infrastructure, management, and product-development plans; Surfshark’s current page states that they merged under one holding company in 2022 without identifying that holding company. ^{1, 16}

• Nord Security reported a $100 million April 2022 financing round led by Novator Ventures, with Burda Principal Investments and General Catalyst participating, and stated that Novator managing partner Birgir Már Ragnarsson would join its board. ¹⁷

• Nord Security reported a further $100 million financing round in September 2023 from Warburg Pincus, with Novator and Burda participating, and stated that Warburg Pincus managing director Chandler Reedy would join its board. ¹⁸

• The published financing announcements do not disclose equity percentages, voting rights, founders’ continuing stakes, board tenure, continuing board status, or evidence that any named investor or board appointee held a controlling interest. ^{17, 18}

• No public filing or official disclosure retrieved establishes that Tomas Okmanas, Eimantas Sabaliauskas, Jonas Karklys, Vytautas Kaziukonis, Dovydas Godelis, a named investor, or a named board appointee controlled Surfshark, Nord Security, or the unnamed common holding company at the time of any identified act. ^{1, 17, 18, 4, 5}

• No public evidence identified of an Israeli government, IDF, Ministry of Defense, police, intelligence, settlement-entity, or military-welfare contract, donation, crisis deployment, or hosting arrangement involving Surfshark or Nord Security.

• Surfshark’s 14 April 2026 transparency report describes fulfilment of one legally binding warrant issued by the Amsterdam District Court in a criminal inquiry and states that only account-existence and payment-related information available under its no-logs policy was disclosed; it identifies no Israeli requesting authority, Israel-related order, or Israel/Palestine conflict matter. ¹⁹

• No public evidence identified of Surfshark contracts, donations, sponsorships, lobbying, crisis asset mobilisation, or other support involving the Israeli government, IDF, Ministry of Defense, settlement entities, military-welfare organisations, or reservist-support bodies.

• The verified Tel Aviv VPN service evidence does not identify a public-sector, defence, police, intelligence, or settlement customer. ^{6, 7}

• Because no qualifying individual act was identified in the reviewed record, there is no evidence that such an act was adopted, funded, publicised, or otherwise institutionalised by Surfshark, Nord Security, or their unnamed common holding company. ^{1, 16, 4, 5}

Corporate Structure & Primary Mission

• Surfshark’s current public materials identify Dovydas Godelis as CEO, Vytautas Kaziukonis as founder and Chairman of the Board, and Laurynas Zabulis as CFO. ¹

• Surfshark’s February 2022 announcement identified Kaziukonis as its founder and CEO at the time of the Nord Security merger agreement. ¹⁶

• Nord Security’s current leadership materials identify Tomas Okmanas, Eimantas Sabaliauskas, and Jonas Karklys as co-founders, and list Dina Lurje as General Counsel and Head of Public Policy, Laurynas Zabulis as CFO, Karina Dirvonskienė as COO, and Toma Sabaliauskienė as CMO. ^{4, 5}

• Nord Security’s current public website presents NordVPN, NordLayer, NordPass, NordLocker, NordStellar, Coveron, and Saily as products, but does not provide a legal-entity chart or identify the contracting entity for each product. ⁵

• A 15 May 2025 Paris court judgment named both Surfshark B.V. in Amsterdam and Surfshark Ltd at Vistra Corporate Services Centre in Road Town, Tortola, BVI, as parties to the proceeding. ²⁰

• The third-party-hosted judgment copy establishes that the two entities were litigants, but does not establish their ownership relationship, operating roles, or whether Surfshark Ltd remains active. ²⁰

• A 19 November 2024 U.S. District Court memorandum opinion described NordSec Ltd as an England-and-Wales holding company that “once owned” Nord-brand intellectual property and NordSec B.V. as a Netherlands holding company that “currently owns” that intellectual property; the opinion attributed those facts to party declarations, which were not independently obtained, and did not state that either entity owns Surfshark B.V. ²¹

• A federal-court docket filed in April 2024 identifies Nord Security Inc., NordSec Ltd, NordSec B.V., nordvpn S.A., and Tefincom S.A. d/b/a NordVPN as defendants, but being named in that litigation does not establish their ownership or control relationships. ²²

• An official Lithuanian Register bulletin records UAB “Nord Security,” entity ID 305475420, with a Vilnius address and address-and-board registration changes on 10 August 2020. ²³

• A record-history page associated with Lithuanian Register entity ID 305475420 identifies UAB “Nord Security” as a previous legal name, records a transition to Tesonet Global, UAB effective 24 February 2022, and displays Tesonet fhc, UAB as the current active entity with a Vilnius address. ²⁴

• That name history does not establish that Tesonet fhc, UAB is the unnamed post-merger holding company, that it owns Surfshark B.V., or the ownership percentages of any founder, investor, or board member. ²⁴

• No public evidence identified that Surfshark’s corporate charter, founding mandate, or primary mission advances Israeli state geopolitical objectives or infrastructure.

Executive & Leadership Footprint

• The targeted searches identified no verified Israel/Palestine-related statements, IDF/FIDF/JNF/KKL donations, settlement-organisation support, anti-BDS roles, or Israel-linked defence or surveillance investments by Kaziukonis or Godelis. ¹

• No dated public record was identified in the reviewed materials documenting Israel/Palestine-related statements, donations, lobbying or advocacy roles, military-welfare or settlement-organisation support, or conflict-related asset mobilisation by Tomas Okmanas, Eimantas Sabaliauskas, Jonas Karklys, or the additional identified Surfshark and Nord Security executives. ^{1, 4, 5}

• The available public materials do not provide a complete group legal-entity chart, subsidiary list, shareholder register, beneficial-ownership disclosure, or named holding-company identity following the Nord Security combination. ^{1, 16, 5}

• No Dutch Chamber of Commerce extract identifying Surfshark B.V.’s shareholders, directors, authorised representatives, historic changes, or ultimate beneficial owners was obtained in the reviewed record. ¹⁰

• No official record was obtained identifying the complete legal-entity chain between Surfshark B.V., Surfshark Ltd, NordSec Ltd, NordSec B.V., and the Nord Security corporate brand. ^{20, 21, 5}

• The disclosed investment announcements identify investors and two announced board appointments but do not establish individual ownership stakes, voting control, or whether named investors, founders, or directors were controlling principals. ^{17, 18}

• No public SEC proxy, beneficial-ownership filing, audited group annual report, cap table, shareholders’ agreement, or official state-ownership or golden-share disclosure was located in the reviewed record. ^{17, 18}

Named-principal supplementary checks - 7 September 2026

• Exact-name conduct searches covered Tomas Okmanas (also Tom Okman), Eimantas Sabaliauskas, Jonas Karklys, Laurynas Zabulis, Donatas Budvytis, Saulius Maslinskas, Tomas Stamulis, Gytis Malinauskas, Dina Lurje, Karina Dirvonskienė, Toma Sabaliauskienė, Chandler Reedy, and Birgir Már Ragnarsson, using Israel, Palestine, Gaza, IDF, FIDF, donation, and advocacy/lobbying terms. No public evidence identified in these bounded searches of Israel/Palestine advocacy, Israeli military-welfare or settlement support, or conflict asset mobilisation by those named people. This supplements the earlier Kaziukonis and Godelis checks; it is not an exhaustive search of private donations or non-indexed records.

• Lithuania’s Ministry of Culture reported on 12 June 2024 that Tomas Okmanas and Eimantas Sabaliauskas, identified as Tesonet Global shareholders, were awarded National Patron titles for a EUR 1,022,500 donation to Blue and Yellow supporting Ukraine. This is documented public Ukraine-related conduct and a Lithuanian honour, not an Israeli state honour or documented contribution to an Israeli recipient. The announcement does not specify either person’s ownership percentage or establish Surfshark corporate funding of that donation. ²⁵

• No public evidence identified in the supplementary checks of an Israel/Palestine-related act requiring a finding about corporate adoption, recurrence, or cessation. The ownership uncertainty described above remains; holding a founder or executive role is retained in scope without requiring proof of a particular equity percentage.