1.Information Collection
1.1 Details on the Collection of Technical Data: To ensure our VPN application provides an efficient and secure service, we elaborate further on the specific technical data collected when you connect and use our VPN service. This includes detailed information about your Network Protocol address (IP address) for identifying your network connection. Moreover, we delve into the device attributes you are using, such as the device model, operating system version, and its type (e.g., Android or iOS) and the type of web browser (like Chrome, Firefox). We also log your connection timestamps and traffic data to analyze usage frequency and optimize the service experience.

1.2 Further Explanation on Cookies and Other Technologies: We use cookies and similar technologies to perform a more thorough data collection aimed at enhancing your personalized experience and service response speed when using our VPN application. These technologies not only help us save your preference settings and login information but also allow us to perform performance analytics. Details on how to set these cookies and other technologies can be explored by reviewing our detailed Cookie Policy, which includes methods for managing settings, ensuring you can adjust them according to personal preferences.

1.3 Detailed Description of the Automated Data Collection Process: We collect technical data generated when using our VPN service via automated technologies, such as server log recordings. This includes, but is not limited to, monitoring your service use, detecting the quality of connections, and identifying any possible service issues or security threats. These monitoring and tracking mechanisms ensure that we can respond promptly and continually improve service quality.

1.4 Detailed Explanation on Third-party Data Sources: We only obtain supplementary information from third-party platforms, such as social media websites when you expressly agree. This is aimed at deepening our understanding of your interests and preferences, thereby allowing us to offer a more customized service experience. Your participation not only helps us design features that better meet your needs but also occurs with your thorough understanding and control over personal data.

1.5 Expanded Explanation on Legal Basis and Purpose of Collection: By reiterating that our collection and processing of data are based on your consent, we also emphasize that this process aligns with our contractual obligations to provide you with VPN services. Besides, our data collection also ensures our operations comply with relevant laws and regulations, as well as the intrinsic need to improve service quality and develop new features. Within this framework, we remain committed to protecting and respecting your privacy.

1.6 Further Clarification on the Policy for Protecting Minors: We clearly state that children under the age of 13 should not use our VPN services, and we do not intentionally collect personal information from minors. If you are under 13, we strongly advise against attempting to register for our services or send any personal information to us. This principle follows our strict commitment to the privacy and safety of young users and underscores the responsibility of guardians to ensure minors under their supervision use internet resources appropriately.

2. Information usage
In our efforts, what we adopt is not solely technological solutions but also a suite of refined services and personalized experiences. This ensures that when you use our VPN service, you not only enjoy the convenience of seamless connectivity but also obtain a more tailored customization that better suits your needs. Initially, we delve deep into analyzing and utilizing the collected data with the aim of optimizing and enhancing the service quality from multiple perspectives. This includes technical troubleshooting, comprehensive analysis of usage patterns, and continuously improving performance while maintaining a user-friendly interface and practical functionality.

We place great importance on your personalized experience. Therefore, based on your usage history and preference settings, we have designed a series of customized recommendations for you. This includes content that matches your interests and behavioral patterns, introductions to new features, and advertisements that may catch your attention, all intended to enhance your user experience and satisfaction.

When processing collected data, we never infringe upon the personal privacy of any user.

3. Detailed Introduction to the Data Retention Policy

3.1 Data Retention Period: To ensure the proper management of user data collected in the process of implementing the purposes described in this Privacy Policy, we commit to retaining user data only for the duration necessary to achieve these purposes, or as required by relevant legal obligations. It is notable that based on the type of data and the specific circumstances of its collection, we have different retention periods aimed at ensuring that data is handled and used appropriately while also safeguarding user privacy.

3.2 Requests for User Account Deletion: Within our system, users have the right to actively manage their data. If a user decides to stop using our services for any reason and wishes to delete their account and all related data, they can do so by directly contacting our customer support team with a deletion request. We will process the request as per the user's instructions. However, it is important to note that even after an user account is deleted, we may still need to retain some data due to legitimate business operations or specific legal obligations (for example, but not limited to, legal retention requirements or resolving potential disputes). In such cases, the retained data will continue to be protected under this Privacy Policy until all external obligations are fulfilled, after which it will be further deleted.

3.3 Data Backup and Security Measures: To prevent data loss or system failures, we have implemented a data backup policy aimed at creating backup copies of data to ensure its rapid and accurate recovery in the event of unforeseen disasters. These data backups are conducted within defined time windows and are protected by strict privacy and security controls on par with those applied to real-time operational data. It is important to clarify that these backup copies are only used for restoring system integrity and availability when necessary, and we ensure the prompt recovery of data and services without compromising user privacy protection.

4. Data Security:
4.1 Specific Measures for Data Protection: In order to ensure the safety of your personal information, we have adopted a multi-layered protection strategy which includes, but is not limited to, encryption technologies, secure protocols, and access control mechanisms. These advanced technologies and strategies aim to construct a solid defense system to prevent unauthorized access and data breaches.

4.2 Emergency Response Mechanism: Our response plan encompasses detailed evaluation, identification of the source of the leak, and prompt remediation actions. Upon the detection of a data breach event, a professional team will be immediately mobilized to investigate and take all necessary measures to control the situation and minimize damage. Furthermore, we commit to maintaining transparency and issuing timely alerts and recommendations to the affected parties in accordance with relevant policies and regulations.

4.3 Management of Third-party Collaborations: When selecting third-party service providers to collaborate with, we consider not just their technical capability and service quality, but also rigorously review whether their data processing and protection measures meet high standards of security requirements. We ensure all collaborating parties strictly adhere to our privacy protection policies in order to safeguard our clients' data from compromise.

5. User Rights
5.1 Right to Rectification: As a valued user, you have the right to correct or update your personal information if you believe it is inaccurate or incomplete. To request a correction, please submit a correction request through our official contact channels, along with the relevant supporting documents (if applicable). We commit to processing your correction request as quickly as possible and maintaining communication with you to ensure the accuracy and up-to-dateness of the information.

5.2 Right to Object: You have the right to object to certain ways in which we process your personal information, especially those processes that are based on our legitimate interests rather than your consent, the performance of a contract, or compliance with legal obligations. To exercise this right, please provide us with detailed reasons for your objection. We will carefully consider your request and respond after taking into account our legal obligations and your legitimate interests.

6.advertising
While Flashup VPN offers a completely free Virtual Private Network service, we partner with carefully selected third-party advertisers to cover our operational costs. Importantly, we promise not to use your personal data for targeted advertising. Unless we have your explicit permission, we will never reveal or use your information with these third-party advertisers.

It is worth noting that, to display advertisements, our third-party partners may deploy cookies, pixel tags, and other tracking technologies when you use our service. This could mean they collect information about you at different times across multiple online platforms. However, this process is beyond our control and knowledge. Ensuring that your key information remains private without your consent is our top priority.

7.Contact
Contact us with  zhengyun.chen@hkflashup.com