PRIVACY POLICY Last updated: 2022-01-12 VpLab LTD, FIRST FLOOR OFFICE 3 HORNTON PLACE, London, UK (”We”) is committed to protecting and respecting your privacy. This policy (together with our Master Services Agreement, available at https://proxy007.com/privacyp.php and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting proxy007.com you accept that your personal data are processed as described in this policy. 1. INFORMATION WE COLLECT FROM YOU We may collect and process the following personal data about you: • Information you give us. This is information about you that you give us by filling in forms on proxy007.com and other vplab ltd websites (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, use our services, search for a product, place an order on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, email address and phone number, financial information, personal description and photograph, as well corporate information. • Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information, by means of cookies or similar technologies,: • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number. • Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, subcontractors in technical, payment and delivery services, analytics providers, etc.). We will notify you when we receive information about you from them and the purposes for which we intend to use that information. 2. COOKIES Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Where required, we will ask for your consent before placing the relevant cookie. More information about the cookies used on our website is available here. You can control and/or delete cookies as you wish – for details, see for example aboutcookies.org. Various web browsers offer ways to restrict and delete cookies. For more information, please visit the appropriate link below. Firefox Google Chrome Internet Explorer Safari 3. USES MADE OF THE INFORMATION We use information held about you in the following ways: • Information you give to us. We will use this information: • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us; • to manage our relationship with our customers which includes processing information for the purposes of customer administration, analysis and reporting on the basis of our legitimate interest to build and maintain strong customer relationships; • to incorporate your information in our databases for the purposes verification of customer identity and solvency, fraud detection and prevention on the basis of our legitimate interest to ensure that we only contract with trustworthy customers and/or legal obligations; • to provide you with information about other services or products we offer that are similar to those that you have already purchased or enquired about on the basis of our legitimate interest to market our products and services; • to provide you, or permit selected third parties to provide you, with information about services or products we feel may interest you. If you are an existing customer, we will only contact you by electronic means with information about services or products similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this; • to notify you about changes to our service on the basis of our legitimate interest to ensure a good client relationship or where necessary in the context of a contract entered into between you and us; • to ensure that content from our site is presented in the most effective manner for you and for your computer on the basis of our legitimate interest to provide users with a positive user experience; • Information we collect about you. We will use this information: • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; • to improve our site to ensure that content is presented in the most effective manner for you and for your computer; • to allow you to participate in interactive features of our service, when you choose, and therefore consent, to do so; • as part of our efforts to keep our site safe and secure; • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them. Where required we will obtain your consent for the abovementioned purposes. Otherwise, the use of your information for the abovementioned purposes is based on our legitimate interest to ensure the good performance of our site and to display advertising. • Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive). 4. DISCLOSURE OF YOUR INFORMATION You acknowledge that we may share your personal information, for the abovementioned purposes, with: • Any member of our group, which means our subsidiaries, our ultimate holding company, its subsidiaries, and other affiliates. • Selected third parties including: • business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you; • analytics and search engine providers that assist us in the improvement and optimisation of our site. We will disclose your personal information to third parties: • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets. • If Vplab LTD or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Master Services Agreement, available at https://proxy007.com/privacyp.php, or to protect the rights, property, or safety of Vplab LTD, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. We will not sell, purchase, provide, exchange or in any other manner disclose your account or transaction data, or personal information about you as a cardholder to anyone, except, the payment intermediaries, for instance, acquirer and Visa/Mastercard Corporations. We may use SSL and other security measures to protect such information. 5. WHERE WE STORE YOUR PERSONAL DATA The data that we collect from you may be transferred to, and stored at, a destination outside the UK Area (”UKA”) in the context of the processing activities described above. It will also be processed by staff operating outside the UKA who work for us or for one of our suppliers. The staff includes personnel engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you acknowledge that your personal data may be transferred outside of the UKA. Vplab LTD will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Furthermore, where required, Vplab LTD will put in place appropriate safeguards such as data transfer agreements based on the EU model clauses. For further information or to obtain a copy of the EU model clauses, please contact Vplab LTD at support@proxy007.com Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 6. YOUR RIGHTS You have the right (i) to obtain confirmation whether we hold your personal data and the right to access those data; (ii) to request correction of inaccurate personal data; (iii) under the conditions provided in the General Data Protection Regulation, to ask for deletion of your personal data, to request the restriction of the processing of your personal data and to portability. You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at support@proxy007.com Where processing is based on consent, you have the right to withdraw your consent You also have the right to lodge a complaint with the competent data protection authority. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. 7. HOW LONG WE KEEP YOUR DATA We keep personal data of our customers for the term of the customer relationship and an additional period which depends on the applicable statutory retention and limitation periods. Personal data collected by means of cookies are kept for the term indicated in the cookie table. Other personal data is kept for the term necessary to achieve the purpose for which the personal data was collected. For more information with regard to the retention of your data, please contact us at the email address given below. 8. CHANGES TO OUR PRIVACY POLICY From time to time this Privacy Policy can be modified by Vplab LTD. Such modifications will not apply retroactively. 9. MARKETING COUNTERS 9.1. Google Analytics functions are Used: remarketing. 9.2. The buyer may at any time disable the use of Google Analytics for display advertisers and customized Google display network using the ads preferences Manager. Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@proxy007.com 10.CONTACT Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@proxy007.com