OpenVPN Access Server is mixed licensed. The product is the most transparent of any commercial enterprise grade VPN solution on the market.
The python part of the OpenVPN Access Server is closed source but does not handle the VPN data itself.
The OpenVPN process that does handle all VPN connections is covered by the General Public License. The only data to/from the OpenVPN process to the python script only occurs over an unix socket using a limited set of management interface commands which are explained here:
https://openvpn.net/community-resources ... interface/
The python script itself only will ever make a network connection back to the vendor for licensing purposes, if even then (more on that later).
You have four options for licensing which impact that degree to contacting the vendor.
(1) AWS tiered instance - I have no experience with this licensing mode so I'm going to skip discussing it
(2) Subscription key / Flex licensing - I believe this is usually the prefer licensing method at this point. It will make short network connections over HTTPS to licensing.openvpn.net By nature of how this license mode works, the vendor keeps track of the total number of active VPN connections each server using the subscription key is using to make sure you aren't exceeding what you are paying for. The amount of data sent can be tracked by using "tcpdump" and this is the licensing method I am currently using. If you are paranoid about confidentiality, then this probably is not the licensing mode for you.
(3) Fixed License (Online activation) - This contacts licensing.openvpn.net over HTTPS once a year during activation of the license. Again, you can track the amount of data sent via tcpdump. This is the one I would recommend using for your situation.
(4) Fixed License (Offline activation) - This is an option available that involves working with vendor support to perform activation of the license offline. I have never gone through the process but it seems like it would be more involved and less convenient than just doing the online activation.
More details on the license modes are here:
https://openvpn.net/faq/which-licensing ... ss-server/
More details on fixed license activation is here:
https://openvpn.net/vpn-server-resource ... ense-keys/
You should be able to use an external firewall to block outgoing network connections (it will still need to allow established UDP connections) to make sure it doesn't ever send information somewhere in the world. For fixed license online activation, you will have to allow the connection specifically to the license server but whenever you aren't activating/renewing your license you can block all outgoing connections.
Lastly, they have a GDPR compliance FAQ available here:
https://openvpn.net/openvpn-compliance/
If this doesn't answer your question enough to raise your level of comfort, then your next best step is to use the community edition of OpenVPN which comes with no web interface for management and comes with no support.