We take your privacy very seriously. We want you to know that Cherry Proxy will process your personal data fairly and lawfully. This Privacy Policy is intended to inform you of the purposes and conditions under which we process your personal data.

Our policy addresses only the use and disclosure of information we collect from you. If you disclose your information to other parties or websites on the internet, they may apply different rules regarding the use or disclosure of the information you disclose to them. Therefore, we recommend that you read the terms and conditions and privacy policy of each third party to which you choose to disclose your information.

By accessing or using any of the services on this site, you are deemed to have fully accepted all of the terms and conditions of this Agreement. If you disagree with any of the terms and conditions of this Agreement, please immediately cease accessing this site and using the relevant services. If these Terms constitute an offer from Cherry Proxy, your acceptance is strictly limited to the terms and conditions set forth herein.

If you have any questions about this Policy or any requests regarding the processing of your personal data, you can contact us at [email protected].

1. Information Collection

We adhere strictly to the Principle of Minimum Necessity when collecting information, gathering only the personal data essential for providing the IP proxy service and avoiding excessive collection. This specifically includes the following three categories:

Information You Actively Provide: When registering for or using certain platform functions, you may need to provide information such as your name, email address, phone number, contact address, username, password, organization information, as well as necessary payment information (which is stored and processed by third-party payment processors).

Information Collected Automatically: When you access or use the platform, we may collect technical information related to your device and usage behavior, much of which constitutes personal data. This includes, but is not limited to, IP address (considered personal data), geolocation information (considered personal data), Internet Service Provider (ISP) information, browser and operating system type, access records, referring URL, application interaction data, data usage volume, etc.

De-identified Data: To meet the needs for statistical analysis, research, or platform optimization, we may anonymize or de-identify the collected information. Once processed, this 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 according to the provisions of this Privacy Policy.

2、Contexts of Data Processing

a Data Processing During Registration

When you register, we ask you to enter your email address so that we can create an account that allows you to access the Cherry Proxy dashboard and our services.

b Data processing when you contact us

You can contact us by sending an email to our dedicated address, or through a real-time chat platform or social media.

If you contact us, we will process your personal data in order to respond to your inquiries and manage the matter. The legal basis for processing your data is your express consent (contacting us is regarded as an explicit affirmative action, indicating your consent to our processing of your personal data).

We may also process personal data for the purpose of fulfilling contractual obligations and based on legitimate interests to ensure the good reputation and solvency of the customer.

c Data processing when we contact you

Cherry Proxy may use your personal data to introduce our services to you.

If applicable laws permit us to contact you without obtaining your separate consent, we will contact you based on the legal interest and provide you with our services.

d Data processing when you visit our website

When you visit our website, we process your personal data using cookies and other similar technologies. Cookies are small text files (typically no larger than a few KB) that your web browser stores on your device when you access our website. The collection of such data is based on GDPR requirements and/or enabled after obtaining your explicit consent.

Cookies fall into the following categories:

**Essential Cookies.** Without these cookies, we would be unable to provide many of the services you require on the website. These cookies are necessary for the website to function and enable basic features such as secure login and billing. They are based on the legal ground of "necessary for the performance of a contract" and cannot be disabled, as doing so would affect core service functionality.

**Analytical Cookies.** These cookies track website visit information, allowing us to improve the website and report on its performance. For example, they analyze visitor and user behavior to provide more relevant content or suggest certain activities.

**Functional Cookies.** These cookies are used to remember information you entered or choices you made on the website (such as your username, language, or region) so that you do not have to reconfigure them on your next visit. For instance, functional cookies help remember your preferences as you browse the site.

**Targeting and Advertising Cookies.** These third-party cookies are placed by third-party advertising platforms or networks to deliver ads and track their effectiveness. In some cases, these cookies enable advertising networks to display ads that may be relevant to you based on your activities on our website and other sites (in such instances, ad delivery may involve automated decision-making).

**Supplementary Note on Automated Decision-Making**

If ad delivery involves fully automated decision-making (such as user profiling), we will ensure you have the following rights:

- To obtain an explanation of the decision-making logic;

- To request human intervention to review the decision;

- To object to the decision and request a re-evaluation.

You can disable cookies entirely through your browser settings (which may affect website functionality).

3. Purposes of Data Processing and Update Notifications

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.

**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.

4. Data Disclosure

Cherry Proxy will use certain service providers (data processors) to handle your personal data. These data processors include: CRM software providers, business development service providers, email and email tracking service providers, online real-time chat service providers, customer support experts, network hosting companies, data analysis service providers, payment service companies, and other service providers. In any case, your personal data will only be disclosed to the extent necessary to provide the services. If you interact directly with our service providers, please refer to the terms and privacy policies of the respective providers to understand the personal information they collect and store.

Your personal information may be transmitted to computers located outside your state, country, or other government jurisdictions and maintained there. The data protection laws in these places may be different from those in your jurisdiction. Please rest assured that we will take all reasonable necessary measures to ensure that your data is handled securely and complies with this privacy policy.

If you are located in the European Economic Area (EEA). Most of our service providers are located in the European Economic Area (EEA) and the United States. Many companies registered in the United States are members of the EU-US Privacy Shield framework and publicly commit to complying with the mandatory EU privacy standards. In other necessary cases, we will enter into agreements with the European Commission using standard data protection clauses to ensure that our data processors located in the United States and non-US comply with the EU privacy standards.

We follow industry standards and implement reasonable physical and electronic security measures to protect your information. However, as our platform is hosted electronically, we cannot guarantee the security and privacy of your information. Therefore, we recommend that you use antivirus software, regular credit checks, reliable passwords, firewalls, and other preventive measures to protect yourself from security and privacy threats.

Additionally, if we determine that disclosing information is reasonably necessary, we will share your information in accordance with the law under the following specific circumstances:

• To comply with laws, regulations, and lawful requests from government authorities;

• To respond to legal documents such as subpoenas, court orders, or arrest warrants;

• To enforce the Platform Terms of Use or this Privacy Policy, including investigating potential violations;

• To protect the safety, legal rights, and property of the public or any individual;

• To detect, prevent, or address security issues, technical faults, and illegal or suspected illegal activities (including fraudulent behavior);

• To serve as evidence in judicial or regulatory proceedings in which we are involved.

Special Note: Without your explicit consent, the platform is prohibited from providing your personal data to any third party, except as otherwise required by laws, regulations, or regulatory authorities.

5. Data Retention

Cherry Proxy retains your personal information only for the "necessary period," with specific retention rules as follows:

• For durations that comply with legally prescribed retention periods;

• Until there is no longer a reasonable basis for retaining or using the information;

• For a reasonable period necessary to achieve the purposes of collection, fulfill contractual and legal obligations, or cover applicable limitation periods for asserting or defending claims;

• Until receiving your request for erasure, deletion, or modification of the information.

Generally, the storage period for your personal data shall not exceed 2 years (calculated from the date of information collection completion or service termination). Upon expiration, relevant data will be deleted or anonymized. We retain your personal information for as long as necessary to achieve the purposes for which it was collected or to comply with legal obligations (such as tax and commercial laws). To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the data, potential risks, processing purposes, and whether we can achieve those purposes through alternative means.

6. Rights of Data Subjects

If you wish to edit or delete your information, you can send an email to [email protected].

For your personal data, you have the following additional rights granted by the General Data Protection Regulation (GDPR):

To be familiar with your personal data and the way it is processed;

To request restrictions on the processing of your personal data when such processing does not comply with legal requirements or there are other legal grounds;

To request the transfer of your personal data to another data controller or to provide it to you in a convenient format (applicable to the personal data you submitted and processed through automated means with your consent);

If the processing of your personal data is based on legitimate interests, you have the right to object to such processing, unless such processing has a legitimate basis or is for the purpose of bringing, pursuing or defending a legal claim;

If your personal data is processed based on your consent alone, you have the right to withdraw your consent at any time;

If you believe your data has been illegally processed or your rights related to data processing have been violated, you have the right to contact the relevant data protection authority in your habitual place of residence, workplace, or the location where the infringement occurred and file a complaint. We recommend that you contact us ([email protected]) before submitting a formal complaint to ensure the correct solution to the problem.

When the processing of personal data does not comply with legal requirements or there are other legal grounds, request restrictions on the processing of your personal data;

Only authorized personnel can access personal data, and authorized personnel must abide by confidentiality obligations.

In the event of a personal data breach, the data processor should immediately notify the data controller.

To provide and optimize self-service functions for you, we may process the personal information you provide based on legal grounds. Such information includes your name, email address, phone number, address, company name, industry category, the last four digits of your credit card number, account credentials (including username and encrypted password), and usage data (including but not limited to access logs, activity history, and preference settings).

7. Social Media

Based on our legitimate interest in maintaining brand exposure in the market, we may utilize social media features to make it easier for you to share information. Please note that even if you are not a member of the specific social media platform, these social media widgets may collect certain information, such as IP addresses.

8. User Activity Monitoring and Data Usage Transparency

To ensure the security, stable operation, and service quality of our website, we conduct necessary monitoring of your usage activities. Such monitoring aims to:

* **Ensure Service Security and Compliance:** Detect, prevent, and address fraud, abuse, security risks, and violations of the Terms of Service.

* **Maintain System Stability and Performance:** Analyze system load, diagnose technical issues, and optimize service performance.

* **Fulfill Contractual Obligations:** Ensure your use of the service complies with agreed-upon limitations such as data usage volume and connection numbers.

Data potentially collected during monitoring includes, but is not limited to: IP addresses, connection timestamps, data usage volume, device identifiers, and log information related to service stability and security incidents. We are committed to conducting such monitoring and data processing in an anonymized or de-identified manner wherever possible, strictly limiting it to the explicit purposes stated above.

9. Children's Information

Our services are not directed to children under the age of 16, or under the age required in your member state to provide valid consent for the processing of their data (hereinafter referred to as the "Minimum Age"). We do not knowingly collect or solicit personal data from children below the Minimum Age.

As the data controller, we take reasonable efforts (such as age verification during registration) to identify the age of users. If you have not reached the Minimum Age, please do not use our services or provide us with any personal data.

If you are a parent or guardian and discover that your child has provided us with personal data without your consent, please contact us immediately at [Insert contact information, e.g., [email protected]]. If we discover that we have collected personal data from a child below the Minimum Age without verified parental consent, we will take immediate steps to delete such information from our records.

10. Policy Update

This privacy policy will remain valid until a new policy takes its place. We may decide to update this policy at our discretion, so you should regularly check this page as the terms may change from time to time. By continuing to use our website and/or services, you acknowledge the current version of this policy and understand its terms.