1. Who is responsible for your information
Smolux Technology Limited is responsible for the personal information it handles to operate its website, customer accounts, billing, support, and related services.
This Privacy Policy explains the information we process, why we process it, how it may be disclosed, and the choices and rights available to you.
2. Information we process
The information involved depends on the features you use.
Account and team information: Information you provide when creating or managing an account, such as your name, contact details, account identifiers, organization details, team membership, permissions, and authentication records.
Business verification information: Company registration information, supporting documents, representative details, and verification results where verification is required. If a verification process involves sensitive personal information, we will explain the specific collection and applicable choices before it occurs.
Order and payment information: Purchases, renewals, transaction references, payment status, invoices, prepaid balances, refunds, and related accounting records. Payment providers may collect additional information under their own notices.
Technical and service information: IP addresses, browser and device information, login events, API activity, service identifiers, traffic volumes, connection times, connection outcomes, and diagnostic or security records. Depending on the connection method and infrastructure used, connection records may include source and destination addresses, destination hostnames, ports, protocols, and visible HTTP method or status information.
Support information: Messages, attachments, and information you provide when requesting assistance, reporting abuse, disputing a charge, or exercising privacy rights.
We receive information directly from you, through your use of the services, and where relevant from your organization’s administrators, payment providers, verification providers, and infrastructure providers.
3. How we use information
We process information to:
- Create and administer accounts and team access.
- Verify eligibility and business details where required.
- Provision services, authenticate connections, measure usage, and maintain service functionality.
- Process payments, maintain balances, issue invoices, and handle refunds.
- Investigate errors, secure accounts, detect abuse, and enforce service rules.
- Answer support requests and communicate service-related information.
- Meet legal obligations and establish, exercise, or defend legal claims.
We rely on the legal grounds available under applicable law, including consent, processing necessary to enter into or perform a contract with you, and compliance with legal obligations.
We distinguish information required for a particular service from optional information. If you do not provide information necessary for a requested feature, we may be unable to provide that feature. Refusing optional processing will not by itself prevent access to unrelated services.
4. Proxy traffic and connection records
Providing a proxy service requires routing traffic through relevant network infrastructure. Connection metadata and information visible to that infrastructure depend on the protocol and encryption used.
Using a proxy does not make all activity anonymous or prevent destination websites, network providers, or other authorized parties from observing information available to them.
We use service and connection records for delivery, usage accounting, troubleshooting, security, and lawful compliance. This policy does not represent a promise that the services generate no logs.
5. Cookies and browser storage
We use cookies and similar browser storage to support functions such as authentication, security, language selection, and interface preferences.
You can manage cookies and local storage through your browser. Blocking or deleting essential storage may sign you out or affect service functionality.
Where optional tracking or marketing technologies require consent, we will obtain that consent before using them and provide a way to withdraw it.
6. How information is disclosed
We disclose information where necessary to:
- Service providers: Hosting, network and proxy infrastructure, payment, verification, communications, security, and technical support providers involved in delivering the services.
- Your organization: Administrators and authorized members who need access to shared account, service, order, or usage information within their permissions.
- Professional advisers and authorities: Where necessary for professional advice, legal obligations, valid legal requests, or the protection of legal rights.
- A business successor: Where a merger, restructuring, or similar transaction requires a transfer, subject to applicable notice and protection requirements.
We limit disclosures to what is necessary for the relevant purpose. Providers acting on our instructions must handle information within the scope of their engagement and applicable protection requirements.
Where disclosure to another independently responsible organization requires a separate notice or consent, we will provide that notice and obtain the required consent.
7. Cross-border processing
The location of proxy infrastructure and destination services can affect where connection information is processed.
Where we arrange a cross-border transfer of personal information, we will apply the notices, permissions, safeguards, and other procedures required by applicable law. Where required, this includes identifying the recipient, explaining the purpose and information involved, and obtaining separate consent.
Accepting our Terms of Service does not by itself constitute separate consent to a transfer for which separate consent is legally required.
8. Retention and security
We retain personal information for the shortest period necessary for its purpose, subject to applicable legal retention requirements.
Retention depends on the category of information, the duration of the account or service, accounting and transaction-record obligations, security needs, and unresolved complaints or legal claims. Closing an account does not necessarily require immediate deletion of records that must be retained for those purposes.
When information is no longer required, we delete it or anonymize it, subject to lawful retention and backup handling requirements.
We apply technical and organizational safeguards appropriate to the information and processing involved. No system can guarantee absolute security. If a personal information incident occurs, we will take remedial action and make notifications where required.
9. Your rights
Depending on applicable law, you may request access to or a copy of your personal information, correction of inaccurate information, deletion, restriction of processing, withdrawal of consent, or account closure. You may also have rights relating to information transfers and significant automated decisions.
You can submit a request through customer support and identify it as a privacy request. We may need proportionate information to verify your identity or authority before acting.
We will respond within the applicable legal period. If we cannot fully comply, we will explain the reason and available options, unless legally prohibited.
Withdrawing consent does not invalidate processing already lawfully carried out. If the information is necessary for a particular service, withdrawal may affect our ability to continue providing that service.
You may complain to the competent personal information protection authority. In Hong Kong, this includes the Office of the Privacy Commissioner for Personal Data.
10. Minors and policy changes
Our services are intended for adults. If you believe a minor has provided personal information in connection with an account, contact customer support so that we can investigate and take appropriate action.
We will give notice of material changes to this policy. A policy update does not replace any new or separate consent required by law.