VPN Service Privacy Policy

COIHUB TECHNOLOGY LIMITED (hereinafter referred to as "VPN Service", "we" or "our") is the provider and operator of VPN Service application software and services (hereinafter referred to as "the Software"). We fully respect your privacy rights and will do our best to protect the security of your personal information. In providing you with products or services (collectively referred to as "the Service"), we may collect and use your personal information based on your consent or in accordance with applicable laws and regulations. This Privacy Policy (hereinafter referred to as "this Policy") aims to help you understand how we collect, use, disclose, process and protect the personal information you provide when using VPN Service products or services, your rights to this personal information, and how we protect these rights. This policy applies to all products and services provided by our VPN service, including applications, mini-programs, web pages, software development kits (SDKs) and application programming interfaces (APIs) for third-party websites and applications, or other forms that may appear in the future, applicable to computers and mobile smart terminals.

It is important to note that this policy does not apply to services provided to you by other third parties. You may receive content or web links from third parties; please carefully consider whether to access such links, content, products, and services. Before submitting personal information to third parties, please carefully read their privacy policies.

To ensure you fully understand this privacy policy and make your own choices, we strive to explain it to you in a clear and easy-to-understand manner, clearly marking or highlighting key points (especially bold, capital letters, underlines, etc.), and also providing pop-up prompts when you first use our services, guiding you to focus on and understand the core content of this privacy policy.

Please carefully read this policy before using our products or services, submitting personal information to us, or agreeing to our collection of your personal information. Understand our practices regarding your personal information, and please visit us frequently to stay updated on this policy. If this privacy policy is updated, we will post a notification on the relevant product or website to inform you of the updates. By accessing or using our services after we issue this notification, you agree to the updated Privacy Policy. You can check the "Update Date" at the top of the Privacy Policy to confirm when it was last updated.

If you have any questions, please feel free to contact us at: privacy@dlightek.com You can also access this Privacy Policy at:VPN Service > Settings > Privacy Policy

This Privacy Policy will help you understand the following:

1. How we collect and use your personal information
2. How we use cookies and similar technologies
3. How we store and protect your personal information
4. How we share, transfer, and disclose your personal information
5. How your personal information is transferred across borders
6. Your rights regarding your personal information
7. How we handle children's personal information
8. Third-party service providers and their services
9. Supplements and updates to this policy
10. How to contact us

1 How we collect and use your personal information

1.1 General Overview

VPN Service firmly believes that fundamental privacy rights should not differ based on where you reside in the world. Therefore, we consider any information relating to an identified or identifiable natural person, especially that person's name, identity information, location data, online identifiers, or data specific to that person's physical, physiological, genetic, or psychological state, or related to that person, as "personal information," regardless of where the natural person resides. We will only collect information necessary for specific, concrete, explicit, and lawful purposes, and will ensure that your information is not further processed in a manner inconsistent with these purposes. If we intend to use your personal information for purposes not explicitly stated in this Privacy Policy, we will obtain your consent again.

When collecting your personal information, we will collect it through the following three methods: 1) Information you provide directly to us; 2) Information generated during your use of this software through automated means (such as device information, service log information); 3) Information we obtain from other sources.

You have the right to choose whether to provide personal information when using the VPN service product or service, or when requested by us. You are not required to provide personal information to the VPN service, but in some cases, if you choose not to provide it, the VPN service will be unable to provide you with the relevant products or services, nor will it be able to respond to or resolve any problems you encounter. We will only collect and use your personal information for the purposes described in this policy. Examples of your personal information collected by us are provided below:

1.2 Main Business Functions and Collection and Usage Scenarios of the VPN Service

The main business function of this software is to provide you with VPN proxy connection services.

1.2.1 Providing VPN Proxy Connection Service

VPN service provides you with browser VPN proxy connection service. The personal information we collect depends on how you interact with us. In order to ensure that you can use our products and services normally, we will also automatically collect your device-related information, including:

1. Device-related information: When you start using this software service, we will receive and record the relevant information of your mobile device (including mobile phone model, operating system version information, system language, hardware device identifier (Google Advertising ID, MAC address, Android) according to your specific operations in the software and the specific permissions you grant during the installation and use of the software. (1) VPN service version number, and information related to the location of your mobile device (including the country or region of your authorized mobile phone and network access method).
2. Service log information: When you use the VPN service of this software, we will automatically collect detailed information about your use of our service and save it as a service log, including access time, usage duration, user traffic usage (transmission data volume, average connection speed), event information (errors, crashes, restarts, upgrades), and other log information generated by the device.

Please note that this individual device information and service log information cannot identify a specific natural person. If we combine this non-personal information with other information to identify a specific natural person, or combine it with personal information, then during the period of combined use, this type of non-personal information will be treated as personal information. If we do this, we will anonymize and de-identify this type of personal information. However, this does not apply if we obtain your authorization or if otherwise stipulated by laws and regulations. The above information is the basic information necessary to provide the services. If you refuse to provide the above information, we may not be able to provide you with the relevant services of this software.

In this business function and scenario, we need to obtain your BIND_VPN_SERVICE permission. If you refuse the aforementioned required permission, we may not be able to provide you with this service.

1.2.2 Other Circumstances Where Your Information May Be Collected

In some circumstances permitted by law, we may obtain your personal information from other individuals, commercial entities, public channels, or other third parties you instruct, other partners who provide our products or services and assist us in ensuring information security and preventing fraud, and other legitimate means. We will collect your personal information in accordance with the law. We will explain this to you and obtain your consent.

We may also collect other information about you, your device, or your use of the service through other means. These methods will be explained to you and your consent obtained at the time of collection.

To better improve our product offerings and provide you with better services, we may conduct research, statistical analysis, and prediction on the collected information in an anonymized manner (including using anonymized data for machine learning or model algorithm training). We will take technical measures and other necessary measures to process the collected personal information so that such data cannot be re-identified as a specific individual or restored. In accordance with applicable laws and regulations, the use of such processed data does not require further notification to you or your consent.

2 How We Use Cookies and Similar Technologies

This service does not use cookies or similar technologies.

3 How We Store and Protect Your Personal Information

3.1 How We Store Your Personal Information

Personal information collected based on your consent will be stored in accordance with the personal privacy and data protection laws and regulations of the relevant countries. Where not prohibited by local laws and regulations, we may also store collected personal information in countries or regions outside the country where we operate.

Currently, VPN Your personal information may be stored in Ireland. Specifically: Personal information collected and generated during our operations will be stored on servers located in Ireland.

Depending on business needs, we may introduce servers in other regions or countries in the future, at which time we will update this policy.

Whether personal information is stored in the country where we operate, or in other countries or regions without violating legal regulations, we will retain it in accordance with the relevant laws and regulations regarding data storage. We will also consider the characteristics, scope, purpose, potential risks during processing, and the serious consequences of any damage caused, and implement necessary security measures. For example, we will use encryption and de-identification methods to store collected personal information. We will also store information according to the minimum storage period required for business operations, unless you agree to an extended retention period or it is permitted by law. Data exceeding the storage period, or data you request us to delete, will be deleted or other appropriate measures will be taken without violating relevant laws and regulations.

3.2 How We Protect Your Personal Information

We will also take other necessary measures to protect the security of your personal information to prevent data misuse. Unauthorized access, modification, disclosure, or destruction of your personal information.

We implement security measures designed to protect your personal information and regularly monitor our systems for potential vulnerabilities and attacks. We utilize administrative, technical, and physical safeguards, taking into account the nature, processing, and security of your personal information, to protect it. We continuously strive to improve these safeguards to ensure the security of your personal data.

Of course, it is important to remind you that even the most comprehensive measures cannot absolutely guarantee the prevention of data storage security incidents. In the event of a data breach, we will report it to the relevant regulatory authorities in accordance with applicable laws and regulations, providing information such as the type of personal data involved, the number of data subjects, the potential consequences of the data breach, and the remedial measures we intend to take. We will take all possible measures to remedy or mitigate the damage and consequences of a data breach. Where permitted or required by laws and regulations, we will promptly inform you of the potential consequences or significant damages of a data breach so that you can take appropriate measures to protect your rights as much as possible. Since no website, internet transmission, computer system, or wireless connection is absolutely secure, in addition to our necessary security measures, users also need to strengthen their awareness of privacy and security risks. For example, when redirected to third-party websites, links, products, or services through our services, please be extremely cautious and carefully read the terms and conditions of the agreement for any data collected by these websites, links, products, or services. We assume no legal responsibility for data security issues caused by such third parties. If you find that certain content, advertisements, or functions of our website, products, or services may be provided by third parties and may endanger your personal privacy and security, please contact us promptly, and we will prioritize handling the matter in accordance with laws and regulations.

4 How We Share, Transfer, and Disclose Your Personal Information

Regarding the sharing, transfer, and disclosure of your personal information, we adhere to the principles and requirements of minimization, necessity, and legal compliance. Under normal circumstances, we will not share, transfer, or disclose your personal information to third parties. However, where applicable laws and regulations permit, we may share, transfer, or disclose your personal information in the following circumstances:

4.1 How We Share Your Personal Information

We will not sell any personal information to third parties. To provide you with timely services, your personal information may be shared with affiliated companies of the VPN service. We will only share your information with affiliated companies of the VPN service for legitimate and explicit purposes, and will only share information necessary to provide the service, subject to the purposes stated in this Privacy Policy. If a purpose is not included in this policy, we will explain it in the privacy policy or notice of the specific product or service.

We may share necessary personal information with authorized third-party partners (including technology service providers, data storage service providers, marketing and promotion service providers, etc.) to perform certain functions or provide you with better services and user experience. Specifically, we will use cloud services from cloud storage service providers to ensure the operation of this product. We adhere to the principles of minimization, necessity, and legal permission in such sharing activities. Before sharing information, we will sign strict confidentiality agreements with authorized partners, requiring them to comply with this policy and the jurisdiction of your country. We will handle personal information using relevant confidentiality and security measures in accordance with applicable laws in our jurisdiction. Furthermore, we will require them to provide data security features and information security qualifications (such as graded protection assessments, information security management systems, etc.). When we embed authorized partners' SDKs or other similar applications into this software, we will exercise due diligence to require the SDKs that access your information to protect your data security.

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4.2 How We Transfer Your Personal Information

1. With your explicit consent.
2. If the VPN Service involves a merger, acquisition, or sale of all or part of its assets that may affect your personal information, we will notify you of any changes to your ownership, rights, and choices regarding your personal information via email and/or our website or other appropriate methods.
3. Circumstances described in this Privacy Policy or otherwise notified to you.

4.3 How We Disclose Your Personal Informatio

VPN services may need to disclose your personal information as required by law, statutory procedures, litigation, and/or requests from government departments and authorities. We may also disclose information about you if disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance.

In addition, we may share your personal information with:

1. When we request professional advice from them, we may share your personal information with our lawyers, accountants, auditors, or similar advisors.
2. Investors and other relevant third parties if there is an actual or potential sale or other corporate transaction that relates to an entity within our group.
3. Other third parties, for example, to disclose specific information with your authorization.

5 How Your Personal Information is Transferred Across Borders

For the purposes described in this Privacy Policy, and after complying with applicable laws and regulations in your region and obtaining your authorization and consent, we may transfer your personal information to the resources or servers mentioned in Section 3 of this Policy for storage or processing. We may also transfer your personal information to third-party service providers and business partners, and therefore your data may also be transferred to other countries or regions. Privacy laws in these countries or regions may differ, and the jurisdictions where these servers are located may or may not protect personal information according to the same standards as your jurisdiction. However, we will strive to comply with our privacy policy to protect your personal information, and we will conduct cross-border transfers and other processing of personal information in accordance with the legal requirements of the country or region where the personal information is located.

If we transfer personal information to a region outside your jurisdiction, whether to our affiliated company or a third-party service provider, we will comply with applicable laws. We will take appropriate security and protection measures to ensure that all such transfers comply with applicable local data protection laws.

6 Your Rights Regarding Your Personal Information

As a data subject, you have a series of rights regarding your personal information, including the right to confirm, access, correct, delete, withdraw consent, and file complaints (hereinafter referred to as "requests"). We fully understand and respect these rights, and such rights are subject to specific exclusions and exceptions under applicable law. We will also take active measures to ensure that these rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your requests. In principle, we do not charge fees for your legitimate and reasonable requests. However, for repeated requests that exceed reasonable limits, we will charge a reasonable fee based on actual administrative expenses, within the scope permitted by applicable law. We may refuse requests that are unjustifiably repeated, require excessive technical means (e.g., developing a new system or fundamentally changing current practices), pose a risk to the legitimate rights and interests of others, are highly impractical, or violate mandatory legal provisions.

6.1 Right to Confirmation and Access:

We inform you how we collect and process personal information through this privacy policy, the privacy policy for specific product/service scenarios, or notices. You have the right to confirm or refuse this collection and processing by checking boxes or other means. However, if you refuse, some functions that require your explicit authorization and consent may become unavailable. You can directly query the personal information you have provided to us through the interface of our products or services. If you are unable to query, you can send an email to privacy@dlightek.com, and we will process it promptly upon receiving your email.

6.2 Right to Correction and Deletion:

When your personal information changes, or when you discover that the personal information we have collected and processed is incorrect or incomplete, you have the right to request us to correct or supplement it. For some of your personal information, you can directly correct or modify it on the relevant function page of the product or service. When we have achieved the purpose of collecting your personal information or it is no longer necessary, or when you discover that we have collected or processed your personal information in violation of the provisions of laws, administrative regulations, or this Privacy Policy, you have the right to request us to delete the relevant personal information. For personal information for which we have not yet provided you with a channel for correction or deletion, you can contact privacy@dlightek.com to request correction or deletion.

However, in some cases we may not approve your deletion request, such as when you request us to delete transaction data, and the VPN service is legally obligated to retain records of the transaction to comply with applicable local laws. Please also note that if you request the deletion of your information from our products and services, due to certain applicable local laws and technical limitations, we may not immediately delete the corresponding information from our backup system. However, we will securely store your personal information and prevent it from being further processed until the backup system is updated, your information can be deleted, or your information is anonymized.

6.3 Right to Withdraw Consent:

To achieve the functions of our various products or services, we require necessary personal information in accordance with applicable local laws. This is explained in the "How We Collect and Use Your Personal Information" section of this Privacy Policy. You can withdraw your previous consent granted to us for a specific purpose, including the collection, use, and/or disclosure of your personal information in our possession or control, by deleting information, disabling device functions, or withdrawing your consent request. You can contact us by email at privacy@dlightek.com to perform this action. We will process your request within a reasonable time after you send it, and thereafter will not collect, use, and/or disclose your personal information based on your request.

If you withdraw your consent, you may no longer be able to access some and/or all functions of the VPN service products and services. Withdrawing your consent or authorization will not affect the validity of our previous processing activities based on your consent.

6.4 Right to Complain:

You have the right to file a complaint by contacting us at privacy@dlightek.com. We will respond promptly upon receiving your complaint. If you are dissatisfied with our response, especially if our processing of your personal information infringes upon your legitimate rights, you may file a complaint or report with the local statutory personal data protection authority, or file a lawsuit with a court of competent jurisdiction.

6.5 Right to Manage Privacy Settings

You have the right to control your privacy settings. Through these privacy settings, you can restrict our collection, use, disclosure, or processing of your personal information. For example, you can choose to turn on or off the functions and permissions of "Location Access," "Camera," and "SMS." You can also obtain more detailed information about the security status of your device in "Settings." If you have previously agreed to enable the corresponding permissions or agreed to our use of your personal information based on the aforementioned business scenarios, you can turn them off through Settings > Application Management > Permission Management, or contact us at privacy@dlightek.com to change your decision.

6.6 Rights in Certain Jurisdictions

Please note that under the applicable laws of certain jurisdictions, you may have the following data subject rights:

1. Right to Restrict Processing. You have the right to request that we restrict the processing of your personal information. We will examine the reasons for your request for restriction. If the reason complies with applicable data protection laws, we will process your personal information only where such laws apply and will notify you before lifting the processing restrictions.
2. Right to Automated Decision Making. You have the right to refuse information processing based on automated decisions, including performance analysis and other automated processing that may have legal or similar effects on you.
3. Right to Data Portability. You have the right to request that your personal information be transferred to another data controller in a structured and commonly used format.

We have the right to refuse to process your request, and we have the right to refuse certain requests where applicable exemptions apply or where applicable laws apply. For example, certain requests may be clearly unfounded or obviously excessive, or require the disclosure of third-party information.

7 How We Handle Children's Personal Information

VPN services and products are not provided to children aged 14 or younger, or those under the equivalent age as defined by the laws of your jurisdiction (the definition of a child varies across different countries or regions; we will primarily define a child according to the laws and regulations of the country or region where we operate). We do not proactively collect children's personal data, nor do we use children's personal information for marketing purposes. If you discover that your child's information has been transmitted to us, please contact us at privacy@dlightek.com, and we will remove the relevant information as soon as possible. If we discover that we have collected children's personal information, we will also attempt to remove the relevant content as soon as possible.

8 Third-Party Service Providers and Their Services

When you use VPN services or products (such as lifestyle services, online customer service, etc.), you may receive website links or content and services provided by third parties other than us. Some third-party products or services may be provided through SDKs and other means. You can choose whether to access or accept websites, products, and services provided by third parties based on your own judgment. Our privacy policy does not apply to any products and services provided by third parties. Because we cannot substantially control third parties, we cannot be responsible for the collection and processing of your personal information by such third parties. When you submit any information to such third parties, please carefully understand their privacy policy and take care to protect your personal information.

9 Supplements and Updates to This Policy

We reserve the right to update or modify this policy from time to time in accordance with changes in our business, technology, applicable laws, and operations. If this policy is modified, we will post the latest policy here (on this page), or through our official website https://www.afmobiapp.com, or notify you individually. Please check this page regularly or any notifications we send you to stay informed of updates to this Privacy Policy. While this Privacy Policy may be adjusted, we will not diminish your rights under this Privacy Policy without your express consent.

When we collect other personal information from you or when we use or disclose your personal information for new purposes, we will seek your explicit consent again in accordance with applicable law. Your continued use of the products and services on the website, mobile devices, and/or any other devices will be subject to the updated Privacy Policy.

The VPN service products or services described in this agreement may vary depending on the type of product you use, your system version, or local laws and regulations.

10 How to Contact Us

If you have any suggestions, questions, or concerns regarding our privacy policy or our personal information protection practices, please contact us through the following methods: Email: privacy@dlightek.com (Note: This email address is only for receiving emails related to our privacy policy or our personal information protection practices)

We will review your privacy or personal information request as soon as possible and respond to you within 15-30 days after verifying your user identity. If your request involves complex or significant issues, we may request more information from you.

If you are not satisfied with our response, especially if your legal rights have been infringed upon by us, you can seek a solution from the relevant data protection regulatory body in your jurisdiction. If you make the above inquiries to us, we will provide information on applicable complaint channels based on your circumstances.

Thank you for taking the time to read our privacy policy!