Privacy Policy

1.3.1 The Company provides multiple IP address proxy infrastructure solutions, including IP addresses for the Clients to connect to the internet, and access to the Company's data gathering and proxy management solutions (”Services”). The Services can be reached and used via System.

1.10.1 Processing shall be performed lawfully, fairly, and in a transparent manner.

1.10.2 Personal data must be adequate and limited to what is necessary in relation to the purpose for which it is processed.

1.10.3 Personal data shall be accurate and, where necessary, kept up to date.

1.10.4 This Privacy Policy is adopted in accordance with the Hong Kong laws, rules and regulations, as well as with the best practices and principles of data protection.

1.10.5 With regard to the terms used in this Privacy Policy, such as ”Processing” or ”Controller”, we refer to the definitions of the PDPL.

3.5.1 Data transfers. The Company shall not transfer personal data to country or territory outside the Hong Kong unless that country ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

3.5.2 Data processing records. The Company shall keep data processing records upon its own decision, unless such record keeping is mandatory legal requirement.

3.5.3 Data protection officer appointment. The company shall assign a data protection officer (”DPO”) to ensure proper data protection requirement implementation and optimization of procedures. The DPO shall be equipped with the skills and know-how for safeguarding personal data.

3.5.4 Data breach notification. The Company strives to protect your personal data in the best way possible. However, sometimes data breaches occur and such events can happen for various reasons.

3.5.5 Data retention. The Company shall not store personal data after the completion of the purpose for which such data was processed unless the identity of the data subject is no longer identifiable through the use of anonymization techniques.

3.5.6 Sensitive personal data protection. In general, the Company does not process any special categories of personal data from Clients. This includes data that reveal racial or ethnic origin, political opinions, religious or ideological convictions or trade union membership, as well as genetic and biometric data. In some cases, during verification, in addition to the actual verification data (e.g. screenshots of ID documents and identification data from them, place of residence, status of politically exposed persons, video data, etc.), biometric data (e.g. personal data resulting from specific technical processing in connection with the physical, physiological or behavioral characteristics of a person and data for the clear identification of a person, e.g. facial images, fingerprint data) are recorded. Such processing of biometric data takes place exclusively based on your express consent, which you can revoke at any time.

3.5.7 Proper agreements between controller and processor. The processor shall perform and implement the processing of personal data based on the instructions of the controller and in accordance with the agreements entered into between them, which shall specifically set out the scope, subject-matter, purpose and nature of the processing, the type of personal data, and categories of data subjects. The Company, either acting as a controller or the processor, shall make sure beforehand those agreements are concluded and are proper for planned data processing.

4.2.1 Contact data. When creating a new user Account or communicating with the Company (for example, by contacting our support team), we may process basic details, such as Your name, date of birth, title, employers, and your contact information (such as your email, address, mob.).

4.2.2 Verification data. if an Account/other details are verified, also depending on the verification level, we may therefore process, for example: screenshots of identity documents such as passport, driver's license, ID card and identification data from these documents, utility bill details for residence verification, data about the status of political exposed persons, data from the video authentication procedure, biometric data for verification, as well as information collected from publicly available resources to verify the same.

4.2.3 Order data. In the context of ordering Services, we might process information relating to the matter on which you are seeking our Services.

4.2.4 Financial data. In the context of ordering Services and accepting payments, as well as making refunds or processing withdrawals in relation to the Affiliate program (or any other applicable program / offer) we might process, for example: bank details (IBAN, BIC), information about the payment service provider, payment details, transaction-ID, etc.

4.2.5 Log data. During activities on the System (website) and while using Services, we might process, for example: IP-address, Your location, location data, traffic data, transaction data (like deposit, payment, refund withdrawal address), computer or mobile device information, frequency, time, length of visit and other page interaction data, operating system, browser type, device type, unique device identification number, identification cookies, optionally form data, crash reports, performance data, third-party cookies, etc. At all times when using System / Services, we collect and process the following log data:

4.2.6 Company details. If you use a Services /enter into commercial agreement with the Company as a legal entity, we might process, for example: commercial register reports, data of or concerning beneficial owners, records or additional information about recent, past or planned business activities, other data required to determine / validate the structure, the beneficial ownership or any power of attorney from the company, etc.

4.2.7 Marketing data. If you visit System or our social media sites, we might process statistical and marketing data, for example: number of visitors, frequency, clicks, time, places, target groups, data from cookies and similar technologies, consumer's behavior, interests and preferences, data on market research and target group surveys, etc.

4.2.8 Photo, video and audio data. When we attend or organize events or fairs or conduct interviews with people, or you visit our offices or our meetings and events, we may take photos and other recordings of such events and process photo, video and audio data, as well as data on time, location, participant list, etc. However, we will always inform you separately about any such recordings by photographic or video images and/or audio recordings.

4.2.9 Hiring data. If you apply for a job on our System, social media we may process data that is necessary for the recruitment process, for example: contact details, curriculum vitae, qualifications, police clearance certificate, credit report, national identity documents such as passport, driver's license and the data from all of these documents, links to Your portfolio or social media platforms, etc.

5.1.1 Performance of the contractual obligations under the Agreement. A controller (the Company) / processor may process personal data without the consent of the data subject (You) to which the data relates where processing is necessary for the performance of a contract (the Agreement) to which the data subject is party or in order to take steps at the request of the data subject for entering into, amending or terminating a contract.

5.1.2 Consent. We may ask you to provide your consent if the data subject's (Yours) consent is relied upon as a lawful basis for the processing of your personal data. For example, we may ask you to express consent prior to using the System before the Agreement is concluded or when you are using the System without logging-in, as well as before collecting / processing any other personal data not described in this Privacy Policy. If you have given us your consent to the processing of your personal data, the processing will only occur for the defined purposes and to the extent agreed in the declaration of consent. A given consent can be revoked at any time without giving reasons with effect for the future if you no longer agree to the processing. With Your consent, we process data for the following purposes, for example:

5.1.3 Compliance with legal obligations. Processing of personal data may also be necessary to abide by various legal obligations. Such legal obligations include, for example, the following data processing operations: contract management, accounting, and invoicing, monitoring to prevent fraud, misuse, money laundering and terrorist financing, providing information to criminal authorities in context of fiscal criminal proceedings or prosecution to official orders, assessing the working capacity of the employee or the provision of health/social care, etc.

5.1.4 Protection of legitimate interests. Where necessary, data processing can occur beyond the performance of the contract to ensure the legitimate interests of the Company or a third party. Such a legitimate interest includes the following data processing operations: Prevention of fraud, misuse, money laundering and terrorist financing. Risk management and risk minimization, e.g. through inquiries to credit agencies, debtor directories or providers of business analysis. Identification and examination of potentially incorrect or suspicious business cases and access to our websites. Data transfer within the Company for internal administrative purposes. Account management and processing of general Client requests and inquiries. Measures to protect our customers and partners as well as to ensure network and information security; also measures to protect our employees and property, e.g. through video surveillance and external data centers and service providers. Processing of inquiries from authorities, lawyers, collection agencies in the context of legal prosecution and enforcement of legal claims in the context of legal proceedings. Market research, business management and further development of services and products. Processing of statistical data, performance data and market research data via the website, the app or social media platforms. Processing of customer preferences via cookies on our website. Direct marketing and advertising. Use of audio, video and photo data from public spaces (e.g. public events, fairs, etc.) for marketing and other representing purposes on our social media channels or our website.

5.1.5 The Company may also process personal data without the consent of the data subject to which the data relates where the data has been made public by the data subject.

7.1.1 Right to withdraw your consent and right to opt-out. In all cases you are entitled to object to and suspend to the processing of your personal data where the processing is performed for direct marketing purposes; and the processing is performed for statistical survey purposes. If You disagree to give Your consent / wish to withdraw Your consent to receive direct marketing and advertising material in any scope or way, You must either: Not complete the creation of the Account, or after creation of the Account, withdraw Your consent (that was given by creating an Account) by clicking ”Unsubscribe” button in the email received from the Company after Your Account was created, or at any other time, withdraw your consent by clicking ”Unsubscribe” button indicated in any other email from the Company which was sent by the Company as a direct marketing and/or advertising material. By checking the respective box during the registration process (creating an Account) or when updating after logging into Your Account, You expressly confirm that you have read the Agreement together with Privacy Policy and that You agree to the data processing described therein. By checking the respective box during the registration process (creating an Account) or when updating after logging into Your Account, You expressly confirm that you have read other policies as indicated in such notice. By creating an Account, You expressly consent to receiving direct marketing and advertising material, as well as other electronic communication. By checking the respective box (boxes) during the use of System for use of Cookies, You expressly consent to usage of Cookies as indicated in this Policy, the notice and as per your preferences expressed by checking all/any boxes.

7.1.2 Right prior to the start of processing activities, to get information on the purpose of the processing, sectors or entities inside or outside the Hong Kong with whom Your personal data will be shared, the appropriate safeguards used by the Company in the context of cross-border processing.

7.1.3 Right to receive a copy and have your personal data transmitted to another controller, if technically feasible. You shall have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format where the processing is based on your consent, or is necessary to fulfill a contractual obligation and implemented by automated means. You also shall have the right to have this data transmitted directly to another controller named by you, insofar as this is technically feasible and the rights and freedoms of others are not impaired. The right to data portability can only be exercised if the processing is based either on your consent or on a pre-contractual necessity and where the processing is automated. The right to data portability does not apply to processing which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7.1.4 Right to object to decisions based on automated processing. The Company usually does not use any personal data for automated decision-making including profiling. In case we would make such a decision in any scope, you shall be entitled to object. Additionally, you have the right to object to the processing of your personal data at any time if the processing is based on your legitimate interests. If you object to the processing, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. The objection does not affect the legality of the processing of your personal data based on legitimate interests until you withdraw your consent.

7.1.5 Right to restriction of processing.

7.1.6 Right to lodge a complaint with the Office of Communications.

7.1.7 In all cases we encourage you to contact us directly. We at the Company believe that best decisions can be made by mutual agreement and effort.

7.1.8 As a general principle of the Company, we process personal data only for the purposes for which they were collected. In exceptional cases, however, we may process your personal data that we have collected for another purpose. In this case, before the intended processing, we will inform you of this purpose, the duration of the storage of your personal data, the exercise of data subject rights, the possibility of revoking consent, the existence of a right to complain to the data protection authority, whether the provision of the data was necessary on legal or contractual grounds and possible consequences of non-provision and whether automated decision-making or profiling is carried out.

10.1.1 To provide you with the Services You have ordered and to ensure proper use of System/Account;

10.1.2 To comply with laws, including mandatory data collection periods.

10.1.3 To support a claim or defense in court or to act in other judicial proceedings.

10.1.4 In all cases the log data shall be saved for at least 6 months from the moment such data was collected. Log data is kept by the Company after the Account is terminated or suspended for the same period starting from the termination or suspension moment. The Company shall be entitled to keep this data for a longer period if it is necessary for a legitimate purpose.

10.1.5 In all cases Account data as per of the Agreement, including identification data (if applicable) shall be saved for the whole duration of You being the Client, and for at least 6 month period from the day the Account was terminated.

11.3.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server every time the browser requests a page from the server.

11.3.2 Cookies may be either ”persistent” cookies or ”session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiration date, unless deleted by the user before the expiration date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

11.3.3 Cookies may not contain any information that identifies a user personally, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

11.4.1 Authentication and status - we use cookies to identify you when you visit our System and as you navigate our System, and to help us determine if you are logged into our System/Account.

11.4.2 Security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to secure our System and Services generally.

11.4.3 Analysis - we use cookies to help us to analyze the use and performance of our System and Services.

11.4.4 Other cookies – we might also use other cookies that are not listed in above.

11.4.5 Cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

11.4.6 Our service providers use cookies and those cookies may be stored on your computer when you visit our System.

11.4.7 Managing cookies. Most browsers allow you to reject and delete cookies. The methods for doing this depend on the browser and its version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

11.4.8 Cookies preferences. You can manage your preferences relating to the use of cookies on our System.