Privacy Policy of 922S5 Proxy
922S5 Proxy is committed to protecting your personal information. This Privacy Policy applies to your use of all websites, software, and related services (collectively referred to as the "Platform") owned by 922S5 Proxy. It aims to disclose our privacy practices and clarify the rules for the collection, storage, use, transmission, and sharing of personal information. Please review this Policy regularly, as we may revise it without prior notice; if you do not fully agree to the content of this Policy, please do not access or use the Platform.
We strictly adhere to the principle of "minimum necessity" when collecting information, and only collect personal data required to provide IP proxy services to avoid excessive collection. Specifically, the collected information includes the following three categories:
Information you actively provide: When registering or using certain functions of the Platform, you may need to provide your name, email address, phone number, contact address, username, password, organizational information, and necessary payment information (which is stored and processed by third-party payment processors).
Automatically collected information: When you access or use the Platform, we may collect non-identifiable information related to your device and usage behavior, including but not limited to IP address, geographic location information, Internet Service Provider (ISP) information, browser and operating system type, access records, referral URLs, application interaction data, and data usage.
De-identified data: To meet the needs of statistical analysis, research, or Platform optimization, we may anonymize or de-identify the collected information. After such processing, the data is no longer directly associated with a specific user and cannot be used to identify your personal identity.
All collected information will be used and protected in accordance with the provisions of this Privacy Policy.
We may aggregate the personal information collected from the Platform and, through anonymization or de-identification, use it only for statistical analysis, business research, or internal optimization. Once the data is anonymized, it will be permanently unable to be directly associated with a specific user and cannot be used to identify your personal identity.
We only share and use your personal information within the scope stipulated in this Policy, and you agree that we may use your personal information for the following purposes:
Contract management: Use your personal information to establish a legally valid contractual relationship with you and ensure the normal performance of services.
Platform access and service communication:
Set up and manage your 922S5 Proxy account;
Interact with you through the Platform (such as sending service messages, Platform announcements, etc.);
Handle your inquiries (including technical, business, and management-related issues) and maintenance and support requests.
Platform usage support:
Ensure your normal use and easy browsing of the Platform's functions;
Analyze your needs and interests to provide you with a more tailored Platform experience.
Third-party sharing:
Share with partner companies or future affiliated companies for legal purposes ;
For lawful purposes such as research and marketing, we will obtain your explicit consent in advance for any data sharing based on these purposes, in accordance with the requirements of the GDPR.
Share with service providers you have contracted with (such as contractors, web hosting service providers, data suppliers, etc.) to ensure the normal provision of Platform services and your smooth access to the Platform.We will implement a series of technical and compliance measures to govern their data processing activities.
Training and improvement:
Use as training materials for employees or contractors to improve their service capabilities and provide you with a better Platform experience;
Optimize the Platform's functions and service quality based on the results of information analysis.
Marketing and inquiry response: Contact you regarding other products or services that may be of interest to you, or promptly respond to your inquiries.
Cooperation with legal procedures: If we believe that disclosing information is reasonably necessary, we will share your information in accordance with the law. Specific situations include:
Complying with laws, regulations, and legitimate requirements of government departments;
Responding to legal documents such as subpoenas, court orders, and arrest warrants;
Enforcing the Platform's Terms of Use or this Privacy Policy, including investigating potential violations;
Protecting the public, the safety, legal rights, and property of any individual;
Detecting, preventing, or resolving security issues, technical failures, and illegal or suspected illegal activities (including fraud);
Using as evidence in judicial or regulatory proceedings in which we are involved.
Special Note: Without your explicit consent, the Platform prohibits providing your personal data to any third party, except as otherwise specified by laws, regulations, and regulatory requirements.
922S5 Proxy retains your personal information only for a "necessary period", and the specific retention rules are as follows:
For the retention period specified by law;
Until there is no longer a reasonable reason to retain or use the information;
For a reasonable time required to achieve the purpose of information collection, fulfill contracts and legal obligations, or cover the applicable statute of limitations for asserting or defending claims;
Before receiving your request for erasure, deletion, or modification of the information.
Generally, the maximum retention period for your personal data is no more than 2 years (counted from the date of completion of information collection or termination of services). After the expiration of the period, the relevant data will be deleted or anonymized.
Meanwhile, we will retain your personal information for the period necessary to fulfill the purposes for which it was collected, or as required to comply with legal obligations (such as tax or commercial laws). To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for processing, and whether we can achieve those purposes through other means.
We process your personal data only for the limited and specific purposes explicitly stated in this policy and are committed to strictly adhering to the principle of "purpose limitation." All processing activities are based on clear legal grounds, and any subsequent processing will not be incompatible with these initial purposes.
The primary purposes for which we process your data include:
Service Provision and Contract Fulfillment:To establish and perform the service contract with you, we process your information to create and manage user accounts, provide and maintain stable IP proxy connections, calculate data usage, process payments and prevent fraud, as well as provide necessary customer support. The data processed for this purpose primarily includes your account information, IP address, connection logs, data usage, and payment information. The legal basis for this processing is the necessity for the performance of the contract with you.
Security and Compliance Assurance:To protect our services, users, and the public interest, we process data to monitor and prevent service abuse, fraudulent activities, and cyberattacks, ensure network and information security, and fulfill legal obligations we are subject to (such as responding to lawful requests from law enforcement). This purpose involves processing your IP address, connection timestamps, device information, and security event logs, among others. The legal bases for this processing are our need to comply with legal obligations and the legitimate interests we pursue in safeguarding service security.
Service Improvement and Analysis: To continuously optimize service quality and user experience, we analyze usage trends and data in an anonymized or aggregated form to improve server performance, develop new features, and conduct internal statistical research. The legal basis for this purpose is our legitimate interest in service optimization.
Marketing and Communication:Subject to your explicit consent, we may use your contact information (such as email address) to send you product updates or marketing communications that may be of interest to you, and to respond to your inquiries in a timely manner. Processing for this purpose is strictly based on your consent.
Within the legal framework, we process and use your personal information based on the following lawful purposes:
* Necessity for fulfilling requirements under this Privacy Policy or the Platform Terms of Use;
* Your explicit consent (which you may withdraw at any time);
* Necessity for complying with our legal obligations;
* Necessity for protecting your or another person's vital legitimate interests;
* Necessity for tasks carried out in the public interest;
* Necessity for realizing our (or a third party's) legitimate interests, including providing users and partners with secure, compliant, and sustainable services.
The purposes of all data processing activities are clearly defined within the agreement, and subsequent processing shall not exceed the scope of the established purposes.
Regarding Purpose Changes and Update Notifications:
If we need to use your personal data for a new purpose that is incompatible with the original purpose for which it was collected, we will clearly inform you of the new purpose and its legal basis via email or a prominent notice on the platform before commencing the new processing activity. In such cases, we will seek your explicit consent again (when consent is necessary). Any revisions to this policy will be communicated to you by updating the date at the top of this document and issuing a notice. You have the right to stop using our services if you object to such changes.
You can directly access and edit part of your personal information through the Platform's control panel; if you need to view, modify, or edit other collected personal information, or have questions about this, you can contact us through the Platform's customer service channels, and we will assist in handling it within the scope of compliance.
You can submit an information deletion request to us via email; if you need to know more details about the deletion or retention rules, you can contact customer service for consultation. All deletion requests shall comply with the provisions of Article 5 (Legal Basis for Information Processing) of this Policy and applicable laws.
We will comply with your request without condition, provided that:
• The data is no longer necessary for the purposes for which it was collected;
• You have withdrawn your consent on which the processing was based, and there is no other legal ground for the processing;
• You have exercised your right to object (see Section 16);
• The data has been processed unlawfully.
Meanwhile as outlined in Section 4, certain legal obligations may prevent us from deleting your data immediately. In such cases, we will inform you of the reason(s). Potential reasons may include:
Even if a deletion request is received, we may still retain and use your personal information within the necessary scope to fulfill legal obligations, resolve disputes, or enforce relevant agreements;
If your deletion/cancellation request meets the conditions specified in laws such as the General Data Protection Regulation (GDPR) (e.g., the data is no longer needed for the purpose of processing, you withdraw your consent and there is no other legal basis for processing, etc.), the Platform will delete the relevant data immediately; if the data has been made public, we will take reasonable measures (such as issuing a deletion notice) to inform other data processors to delete it together.
Other specific purposes that are lawful and necessary. For instance, to comply with the exercise of official authority or requirements from judicial/regulatory authorities; or when selective deletion is technically impossible (e.g., in backup data), we will implement segregation measures until the data can be safely deleted.
Currently, we use Cookies to achieve the following functions: track your usage behavior on the Platform, record payment-related information, and retain your account login status when you access the Platform. To ensure the normal use of the Platform's functions, it is recommended that you enable support for the Platform's Cookies in your web browser.
If you provide us with contact information, it means you agree that we may send you communications (such as service notifications, product information, etc.) via text messages and emails; you can choose to stop receiving such communications at any time or refuse to submit part of the non-essential personal information, and you can inform us of your relevant needs through customer service channels. However, you can manage your Cookie preferences through the [Link to Cookie Settings Panel] we provide or via your web browser's own built-in settings.
Currently, our website does not support the identification function of "Do Not Track" signals or lists, and cannot adjust information collection behavior based on such signals.
922S5 Proxy may provide links to third-party websites on the Platform. The information content and privacy policies of such websites are not under our control. When you access third-party websites through the Platform, you should be aware that we have not screened the privacy and security of these websites; 922S5 Proxy shall not be liable for the collection and use of your information by third-party websites. It is recommended that you carefully read the terms of use and privacy policies of third-party websites before accessing them to understand their information collection rules.
We adopt reasonable physical security measures (such as protection of data storage environments) and electronic security measures (such as data encryption, access permission control) in accordance with industry standards to protect your personal information from unauthorized access, use, or disclosure. However, it should be specially noted that the Platform's services are provided based on electronic networks, therefore, while we employ commercially acceptable means to protect your information, we cannot guarantee its absolute security.; it is recommended that you take your own security protection measures, including using anti-virus software, regularly checking credit records, setting complex passwords, enabling firewalls, etc., to deal with potential security and privacy threats.
We strictly comply with international laws related to children's privacy protection and do not collect or process personal information of any person under the age of 18; if you are under the age of 18, please do not access or use the Platform.
Please note that your personal information may be transmitted to regions outside the jurisdiction where you are located and processed on servers in such regions; we will ensure that such cross-border transmission complies with the requirements of applicable laws and guarantees the security of the information during transmission.
During the process of data storage and use, we will continuously evaluate the necessity of data processing and promptly delete or anonymize the data that is no longer needed for the realization of the established purposes.
If 922S5 Proxy is involved in situations such as bankruptcy, merger, acquisition, reorganization, or asset sale, your personal information may be sold or transferred as one of the transaction targets. After the information is transferred, your privacy rights may change in accordance with the privacy policy of the transferee, and we will fulfill the obligation of reasonable notification within the legal scope.
Consistent with the Platform's Terms of Use, we may revise this Privacy Policy from time to time. After the revision, we will update the revision date stated in this Policy or inform you through reasonable methods (such as Platform announcements, email notifications); if you continue to use the Platform, it shall be deemed that you agree to the revised Privacy Policy; if you do not agree to the revised content, you must stop using the Platform immediately and notify us of your refusal intention via email.
If you need to edit or delete your personal information, you can send an email to [email protected] to submit a request. In accordance with the General Data Protection Regulation (GDPR), you also enjoy the following additional rights:
Right to know: To understand the scope of your personal data and the specific processing methods;
Right to restrict processing: If the processing of personal data does not comply with legal requirements or there are other legal bases, you may request to restrict the processing of your personal data;
Right to data portability: To request the transfer of your personal data to another data controller, or to require us to provide it in a format that is easy for you to obtain (applicable to data actively submitted by you and processed through automated means based on consent);
Right to object: If personal data is processed based on legitimate interests, you may object to such processing (unless we have a more priority legitimate reason, or the processing is necessary for asserting, pursuing, or defending legal claims);
Right to withdraw consent: If the processing of personal data is based on your separate consent, you may withdraw such consent at any time;
Right to complain: If you believe that your personal data has been processed illegally or your relevant rights have been violated, you may file a complaint with the data protection authority in your usual place of residence, place of work, or the place where the alleged infringement occurred.
It is recommended that before submitting a formal complaint, you first contact us via [email protected], and we will give priority to negotiating a solution for you.