Last edited: 06 April 2021
1. GENERAL INFORMATION
Here you can find some general information about us and ProxyTales.
1.2 About ProxyTales. ProxyTales provides proxies (IP’s) from various cell phone operators from a range of countries that allow you to stay anonymous on the Internet.
1.3 Data controller. ProxyTales is owned and operated by ProxyTales LTD having a registered address at 31 Rickliffe rd, Bacup OL13 9QG, the United Kingdom, and the registration number 12479695 (“we”, “us”, or “our”).
1.4 Minors. ProxyTales is not intended for use by persons under the age of 18. We do not knowingly collect personal data belonging to persons younger than 18. If you become aware that such a person has provided us with his or her personal data and you are a parent or a legal guardian of that person, please contact us immediately and we will remove child’s personal data from our systems.
2. WHAT DATA DO WE COLLECT?
Here we explain in detail what personal data we collect from you, for what purposes we use it, what technical data is collected automatically when you use ProxyTales, and how we communicate with you.
User account. When you register your user account, we collect your username, email address and password. We use the said information to register and maintain your user account, enable your access to ProxyTales, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate interests’ (i.e. operate, analyse, grow, and administer ProxyTales). We will store this data until you delete your user account.
Payments. When you make a payment for your use of ProxyTales, we collect your first name, email address, and payment information of your selected payment method (e.g. PayPal, cryptocurrency wallet, or bank account information). The payments are processed by our payment processors, so we do not have full access to your payment details. We use the data available to us to issue invoices, process payments, and maintain our accountancy records. The legal bases on which we rely are ‘performing our contractual obligations’ and ‘pursuing our legitimate interests’ (i.e. to administer our business). We store such data for the time period prescribed by law.
Enquiries. When you contact us by email, we collect your first name, last name, email address, and any information that you decide to include in your message. When you contact us through WhatsApp or Telegram, we collect your username. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e. to grow and promote ProxyTales) and ‘your consent’ (for optional personal data). We will store this data until you stop communicating with us.
Newsletter. When you subscribe to our newsletter, we collect your email address. We use your email address to deliver our newsletter and inform you about the new features of ProxyTales and our offers. The legal basis on which we rely is ‘your consent’. We will store your email address until you unsubscribe from our newsletter.
2.2 Sensitive data. We do not collect or use any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.
2.3 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use the full functionality of ProxyTales, receive the requested information, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.
2.4 Collection of non-personal data. When you browse ProxyTales, we may have access to certain technical non-personal data collected from you by our analytics service provider. Such data does not allow us to identify you in any manner. The non-personal data includes the following information:
Your operating system;
Your device type;
Your activity on ProxyTales (time of visit, pages visited, time spent on each page, clicks, scroll depth, interaction with widgets);
URL addresses from which you access ProxyTales; and
Your other online behaviour.
2.5 Purposes of non-personal data. We use non-personal data to ensure the proper functioning of ProxyTales, analyse what kind of users use ProxyTales, improve our content and services, investigate and prevent security issues and abuse.
2.6 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).
2.7 Aggregated and de-identified data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any legitimate purpose.
2.8 Newsletters. If you subscribe to our newsletter or conclude a contract with us, we will send you a newsletter about our new services, features of ProxyTales, and special offers. The legal bases on which we rely are ‘your consent’ (if you subscribe to our newsletter) and ‘pursuing our legitimate interests’ (if you conclude a contract with us). You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters or by contacting us directly.
2.9 Important service notices. If we have your email address and it is necessary to do so, we may send you important informational messages, such as technical or administrative emails. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.
3. HOW LONG DO WE STORE YOUR DATA?
Here we explain for how long we keep your data in our systems and how we delete it.
3.3 Storage as required by law. In seldom instances when we are obliged by law to store your personal data for certain period of time (e.g. for keeping accountancy records), we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.
4. HOW DO WE DISCLOSE YOUR DATA?
Here you can find information about third parties that may have access to your personal data.
4.1 Disclosure to data processors. We keep your personal data in strict confidentiality. However, if necessary for the intended purpose of your personal data, we will disclose your personal data to entities that provide services on our behalf (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting, payment processing, and email distribution services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to the situations when it is required for the following purposes:
Ensuring the proper operation of ProxyTales;
Responding to your enquiries;
Pursuing our legitimate interests;
Enforcing our rights, preventing fraud, and security purposes;
Carrying out our contractual obligations;
Law enforcement purposes; or
If you provide your prior consent to such a disclosure.
Our hosting service provider SiteTide located in United Kingdom;
Our analytics service provider Google Analytics located in the United States;
Our email service provider Amazon.com, Inc located in United States;
Our marketing and newsletter service provider Amazon.com, Inc located in United States;
Our chat service provider Chatra located in the United States;
Our payment service providers PayPal located in the United States and NOWPayments located in Seychelles; and
Our banks, independent contractors and consultants.
4.3 International transfers. We and some of our data processors may be based outside the country where you reside. For example, if you reside in a country belonging to the European Economic Area (EEA), we may need to transfer your personal data outside the EEA. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre-approved standard contractual clauses).
4.4 Disclosure of non-personal data. Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it with prospects or partners for business or research purposes, for improving ProxyTales, responding to lawful requests from public authorities or developing new products and services.
4.5 Legal requests. If requested by a public authority, we will disclose information about the users of ProxyTales to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
5. HOW DO WE PROTECT YOUR DATA?
Here you can find information on how we protect your data against breaches.
5.1 Security measures. We implement technical and organisational information security measures that protect your personal data from loss, misuse, unauthorised access and disclosure. The security measures taken by us include secured networks, encryption, strong passwords, limited access to your personal data by our staff, anonymisation of personal data (when possible), and carefully selected data processors.
5.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.
6. HOW CAN YOU MANAGE YOUR PERSONAL DATA?
Here you can find detailed information about the rights that you have with regard to your personal data and how to exercise those rights.
6.1 The list of your rights. You have the right to control how we process your personal data. Subject to any exemptions provided by law, you have the following rights:
Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
Right to rectification: you can rectify inaccurate personal data that we hold about you;
Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
Right to restriction: you can ask us to restrict the processing of your personal data;
Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
Right to object: you can ask us to stop processing your personal data;
Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
Right to complaint: you can submit your complaint regarding our processing of your personal data.
6.3 Complaints. If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 2 weeks). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
Email: [email protected]