"Every user is exit node" concept in addition to legal question raises more practical questions. What are you going to do if majority for your users (and when you call something "free" the chance increases) will be from countries like China, Russia, Iran and other where government controls and blocks a lot of the websites and services? And I'm talking not about surveillance but about actual block of the IP subnets like Russia did to AWS, DO and GC when they tried to block Telegram.
Also on the website you declare
> No bandwidth caps. No throttling. Stream all day, and download away. Unlike other VPNs, FreePN will never bottleneck your connection.
Sorry but this is simple lie. If we will take Turkmenistan (their internet censorship is better than China's one if you wonder why I take this unknown country) max bandwidth you can get as average citizen is about 2mbps. And there will be users (exit nodes) from TM for sure so for external users there will be bottleneck.