<p>
<b>Last updated:28 September, 2020</b>
</p>
<p>We, LEMON CLOVE
PTE.
LIMITED and its affiliates, are committed
to protecting your privacy.
We limit the collection of your data.
We only
collect data that is required to maintain the service.</p>
<p>This Privacy Policy describes how
we collect, use, and share your data in connection with your use of our
websites (including www.vpnproxymaster.com), services, and applications
(collectively, <b>"VPN Proxy Master </b>").
The Privacy Policy does
not apply to data that you send and/or receive from third party websites that
you may process through VPN Proxy Master.</p>
<p> </p>
<p>
<b>1.  .
</b>
<b>COLLECTION
OF DATA</b>
</p>
<p> </p>
<p>
<b>1.1  .
</b>
<b>Data we
do not collect</b>
</p>
<p>We do not
collect the following data: </p>
<p>1)  .
Names
(including subscriber names, user names, and screen names);</p>
<p>2)  .
Addresses
(including residential addresses and business addresses);</p>
<p>3)  .
Telephone
numbers.
and</p>
<p>4)  .
Payment
details:</p>
<p>a)  .
We do not
collect your payment details for VPN Proxy Master.
We do not collect or store
credit card numbers, bank account numbers, or billing records.</p>
<p>b)  .
When you make
payments to us, VPN Proxy Master may redirect you to the website of a third
party payment processor to complete the transaction.
To understand what
personal data the third party processor collects and stores, please refer to
the respective processor's terms and privacy policy.
</p>
<p> </p>
<p>We do not
collect sensitive data as we’ve engineered our systems to categorically
eliminate the storage of sensitive data.</p>
<p> </p>
<p>We do not
collect any data related to your online activities.
We do not collect data logs
of your activity, including:</p>
<p>1)  .
Browsing history;</p>
<p>2)  .
Traffic destination;</p>
<p>3)  .
Data content.
and</p>
<p>4)  .
DNS queries.</p>
<p> </p>
<p>We do not
collect data of your connection logs, including:</p>
<p>1)  .
Your IP address;</p>
<p>2)  .
Your outgoing VPN IP address;</p>
<p>3)  .
Connection timestamp.
and</p>
<p>4)  .
Session duration.</p>
<p> </p>
<p>As we do not
collect data logs of your activity or connection logs, we do not know: </p>
<p>1)  .
The websites you visit;</p>
<p>2)  .
The time you connected to VPN Proxy
Master.
and</p>
<p>3)  .
The set of original IP addresses of
your computer or the temporarily assigned network addresses.</p>
<p>
<b> </b>
</p>
<p>
<b>1.2  .
</b>
<b>Data we
collect</b>
</p>
<p>We limit the collection of your
data.
We only collect data that is required to maintain VPN Proxy Master.</p>
<p>1.2.1  .
<u>Data that
you give us</u>
</p>
<p>We collect the data that you give
us through your interaction with VPN Proxy Master.
When you register for an Account,
we may ask for your email address.
The amount of data you give us depends on
your privacy settings.</p>
<p>We use your email to:</p>
<p>1)  .
Communicate with you;</p>
<p>2)  .
Send you updates and announcements.
and</p>
<p>3)  .
Send marketing information, such as
our offers, surveys, invitations, and other content.</p>
<p>If you contact us directly, we may
receive data such as your name, email address, phone number, the contents of
the message and/or attachments you may send us, and any other personal data you
may choose to provide to us in your communication to us.</p>
<p>You may withdraw your consent to
our use of your email address for the above purposes.</p>
<p>1.2.2  .
<u>Data
necessary for us to maintain the quality of VPN Proxy Master</u>
</p>
<p>We collect the following data
related to your use of VPN Proxy Master:</p>
<p>1)  .
Data related to versions of VPN
Proxy Master: we collect data related to your version of VPN Proxy Master.
This
allows us to efficiently identify and eliminate technical issues that you may
face.</p>
<p>2)  .
Data related to VPN connection: we
collect abstracted data related to your use of VPN Proxy Master.
This includes
the success of VPN connections, the VPN location you connected,
your country, and your internet service provider.
You cannot be identified from
this abstracted data.</p>
<p>3)  .
Amount of data transferred: we
collect the aggregate sum of data transferred to ensure individual users do not
use too much data at the expense of other users.
</p>
<p>4)  .
Anonymous data for network
diagnostics, study and analysis: We collect anonymised data to operate VPN
Proxy Master, including diagnostic data VPN connection failures, speed test
data, and crash reports.</p>
<p> </p>
<p>
<b>2.  .
</b>
<b>USE OF
DATA</b>
</p>
<p>We use, combine, and process your
data for the following purposes:</p>
<p>
<b> </b>
</p>
<p>
<b>2.1  .
</b>
<b>Security</b>
</p>
<p>We authenticate your use of VPN
Proxy Master by assigning a unique identifier to you while you register for the
service via your email address.
This unique identifier identifies you through
your device identification code without reference to other data.
The purpose of
the unique identifier is for us to determine the level of service you have signed
up for before we establish your VPN Proxy Master connection.</p>
<p>We do not use other forms of your
data to verify your identity.</p>
<p> </p>
<p>
<b>2.2  .
</b>
<b>System
diagnostics</b>
</p>
<p>We use your data related to your
VPN Proxy Master usage to perform internal operations necessary to maintain VPN
Proxy Master.
This includes troubleshooting operational problems, conducting
data analysis, and analysing activity trends.</p>
<p> </p>
<p>
<b>2.3  .
</b>
<b>Customer
support</b>
</p>
<p>We use your data to resolve
customer support issues.
For example, we may investigate and address concerns,
monitor and improve our customer support responses, respond to your questions
and feedback, and inform you of steps taken to resolve customer support issues.</p>
<p>We may communicate with you to
provide you with updates relating to VPN Proxy Master, and for marketing and
promotional purposes.</p>
<p> </p>
<p>
<b>2.4 .
Research and development</b>
</p>
<p>We use your data to understand and
analyse your use of VPN Proxy Master to develop new products, services,
features, and functionality.</p>
<p> </p>
<p>
<b>2.5 .
Service providers</b>
</p>
<p>We use data from service providers
and third-party vendors to provide and market VPN Proxy Master.</p>
<p> </p>
<p>
<b>3.  .
</b>
<b>SHARING
AND TRANSFER OF DATA</b>
</p>
<p>We share and transfer your data in
various ways, including the following:</p>
<p> </p>
<p>
<b>3.1 .
Aggregated anonymous data</b>
</p>
<p>We use and share your data with our
partners in aggregated or anonymised form that cannot be used to identify
individual users.</p>
<p> </p>
<p>
<b>3.2 .
Referral</b>
</p>
<p>If you sign up for VPN Proxy Master
through a referral from a friend, we may let your friend know that you used
their referral to sign up for VPN Proxy Master.</p>
<p> </p>
<p>
<b>3.3 .
Analytics</b>
</p>
<p>We share and transfer your
anonymised statistics and analytics data for network diagnostics.</p>
<p> </p>
<p>
<b>3.4 .
Business transfers</b>
</p>
<p>Your data may be disclosed and
otherwise transferred to any potential acquirer, successor, or assignee as part
of any proposed merger, acquisition, debt financing, sale of assets, or similar
transaction, or in the event of insolvency, bankruptcy, or receivership.</p>
<p> </p>
<p>
<b>3.5 .
With your consent</b>
</p>
<p>With your consent and instruction,
we may share your data.</p>
<p> </p>
<p>
<b>3.6  .
</b>
<b>International
data transfers</b>
</p>
<p>
<b>3.7  .
</b>We may process your data to any
countries in which we engage service providers.
You
acknowledge the transfer of your data outside of the country where you reside.
We will ensure your data is protected before transferring the data.
</p>
<p> </p>
<p>
<b>4.  .
</b>
<b>SECURITY
MEASURES</b>
</p>
<p>We implement robust security
measures to protect your data from unauthorised access, collection, use,
disclosure, copying, modification, disposal, or similar risks.
We ensure that
our computer networks are secure.
We adopt access control measures.
Our staff’s
access to your data is restricted to a need-to-know basis.</p>
<p>We do not collect or store any
traffic data or personal data in our data centres.</p>
<p> </p>
<p>
<b>5.  .
</b>
<b>DATA
RETENTION</b>
</p>
<p>We retain your data when we have an
ongoing legitimate business need to do so, such as providing you with a service
you requested, or complying with applicable legal, tax, or accounting
requirements.</p>
<p>When we have no ongoing legitimate
business need to process your data, we will delete or anonymise it.
If it is
not possible to delete or anonymise your data (for example, because it has been
stored in backup archives), then we will securely store it and isolate it from
any further processing until deletion is possible.</p>
<p> </p>
<p>
<b>6.  .
</b>
<b>RIGHT TO
BE FORGOTTEN</b>
</p>
<p>We will erase your data when:</p>
<p>1)  .
Your data is no longer
necessary for the purpose which we originally collected or processed it for;</p>
<p>2)  .
You withdraw your
consent to us holding your data, and we are relying on your consent as the
lawful basis for holding on to your data;</p>
<p>3)  .
You object to our
processing of your data, and there is no overriding legitimate interest for us
to continue such processing.
or</p>
<p>4)  .
We are processing your
data for direct marketing purposes and you object to that processing.</p>
<p> </p>
<p>
<b>7.  .
</b>
<b>THIRD
PARTY SERVICES</b>
</p>
<p>You may access other third party
services while using VPN Proxy Master, for example, by clicking on links of
third party services from within VPN Proxy Master.
We are not responsible for
the privacy policies and/or practices of these third party services.
We
encourage you to carefully review their privacy policies.</p>
<p> </p>
<p>
<b>8.  .
</b>
<b>ADVERTISING</b>
</p>
<p>1)  .
Paid VPN Proxy Master </p>
<p>For paid
VPN Proxy Master, we do not work with third party advertising partners.</p>
<p>2)  .
Free VPN Proxy Master </p>
<p>For
free VPN Proxy Master, we work with third party advertising partners to offset
the cost of providing our services.
We do not target advertisements based on
your data.
We do not share or use your data in connection with third party
advertisers without your prior consent.</p>
<p>Third
party advertising partners may set and access their own cookies, pixel tags,
and similar technologies on our services, and may otherwise collect or have
access to data about you which they may collect over time and across different
online services.</p>
<p> </p>
<p>
<b>9.  .
</b>
<b>CHILDREN’S
PRIVACY</b>
</p>
<p>We encourage parents and guardians
to teach their children about privacy and how their information may be used on
the Internet.
Children should never disclose their name, address or phone
number, or any personal information, without their parents’ or guardian's prior
permission.</p>
<p>We consider a user to be a child if
they are under the age of 13, unless more stringent regulation applies in their
state of residence.</p>
<p>If we consider that any of our
services are directed at users under the minimum legal age required in their
country of residence, we can block such users from using the services or from
providing information and/or limit the collection of information from such
users as described below in more detail.</p>
<p>No personal information should be
submitted to VPN Proxy Master by users under the minimum legal age required in
their state of residence.
We apply the following limitations to personal
information collection for a user that is not of the minimum legal age required
in their state of residence.</p>
<p>Such a user cannot:</p>
<p>l .
display their real name or any
information in VPN Proxy Master</p>
<p>l .
access the chat, leaderboard,
forums, SNS (Facebook, Game Center, etc.)</p>
<p>l .
subscribe to newsletters</p>
<p>l .
use any other feature where users
could appear under their real names</p>
<p>With respect to such a user, we
will prevent the collection and use of their precise geolocation data and
display to them contextual advertising only (excluding any behavioral
advertising).</p>
<p>Children can be invited to take
part in testing our apps with their parents' or guardians’ authorization and/or
their parents' or guardians’ physical presence being required depending on the
state where the playtest is conducted.</p>
<p>Parents must exercise their privacy
rights for their children provided in this Privacy Policy.</p>
<p> </p>
<p>
<b>10.  .
</b>
<b>ORDERS
COMPELLING THE DISCLOSURE OF YOUR DATA</b>
</p>
<p>Our collection of your data is
limited.
We collect your device identification code, and other data you may
volunteer to us when you voluntarily contact us by way of email, phone, or interactions
on VPN Proxy Master’s application page on Google Play or App Store.
We do not
collect IP addresses, browsing history, traffic data, or DNS queries that could
be used to identify you.
As such, the extent of any disclosure of your data is
limited.</p>
<p>We are committed to safeguarding
your data.
Nonetheless, we may be compelled to disclose your data where we are
served with a valid court order that is enforceable in Singapore, an order from
law enforcement agencies, or where we are legally obligated to disclose your
data.
We will require the recipient of your data to undertake to protect your
data, to a standard that is at least comparable to the protection required
under Singapore’s Personal Data Protection Act (“<b>PDPA</b>”).</p>
<p> </p>
<p>
<b>11.  .
</b>
<b>ACCESS</b>
</p>
<p>When you become a user of VPN Proxy
Master, you may request to access your data that is associated only with you by
emailing vpnproxymaster@lemonclove.net . .
</p>
<p>To protect your privacy and
security, we may take reasonable steps to verify your identity before acceding
to your request.
Upon our approval of your access request, we will provide you
with your data that is in our possession or under our control.
Where
applicable, we will provide you with information about the ways in which your
data has been or may have been used or disclosed by us within a year of your
request.
We may charge you a fee for the access request.
</p>
<p> </p>
<p>
<b>12. .
CORRECTION</b>
</p>
<p>You may make a request to correct
an error or omission about your data that is in our possession or control, by
emailing vpnproxymaster@lemonclove.net.</p>
<p>We will consider whether the
correction should be made.
If such correction is to be made, we shall correct
your data as soon as practicable and send the corrected data to every other
organisation to which your data was disclosed by us within a year before the
date the correction request was made, unless that other organisation does not
need the corrected data for any legal or business purpose.</p>
<p>To protect your privacy and
security, we may take reasonable steps to verify your identity before correcting
your data.
Your data may be archived or stored periodically by us according to
backup processes conducted in the ordinary course of business for disaster
recovery purposes.</p>
<p> </p>
<p>
<b>12.  .
</b>
<b>GDPR</b>
</p>
<p>If you are a resident of the EEA,
we ask that you keep the information that you provide to us updated.
You can
correct any information you have provided by contacting us through this form.</p>
<p>You represent and warrant that all
information you provide us is true and correct, and relates to you and not to
any other person.</p>
<p>You can exercise your rights at any
time and ask VPN Proxy Master for access to, or rectification or erasure of,
your information.</p>
<p>Please note that other third
parties (our data partners) may be controllers of your information.
You can
obtain more details and opt out of the sharing of your personal information to
third parties for any purpose by contacting us by emailing vpnproxymaster@lemonclove.net.</p>
<p>If you have previously consented to
any direct marketing communication from us or subscribed to our newsletters,
you can unsubscribe by clicking on a link available in each communication and
newsletter we send you.</p>
<p>Please note that VPN functionality,
services and features can be affected by your actions.
Some of your information
and its processing is mandatory for VPN Proxy Master to provide the services.</p>
<p>Your actions may force VPN Proxy
Master to cease providing the services.
When the conditions below apply, it
will be reset:</p>
<p>-  .
If you ask for
the modification of this mandatory information, we may not be able to continue
to link VPN Proxy Master or our services to you.</p>
<p>-  .
If you request
limitations to processing that are mandatory for VPN Proxy Master, or you
object to such processing (in which case, we may not be able to provide you
with VPN Proxy Master or our services).</p>
<p>-  .
If you withdraw
your consent or ask for the deletion of your information.</p>
<p>-  .
If you withdraw
your consent or ask for the deletion of your information, we will not use or
process your information anymore but we will store it to answer regulatory or
police requests.
We also reserve the right to retain an archive of such
information for a commercially reasonable time to ensure that its deletion does
not affect the integrity of our data.
and we further reserve the right to
retain an anonymous version of such information.</p>
<p>Please specify your request by
emailing vpnproxymaster@lemonclove.net.</p>
<p>If you are the parent of a child
who is under 13 years of age (or under another age specified by applicable
regulations) and believe your child has provided us with information, please
fill out by emailing vpnproxymaster@lemonclove.net and we will delete the
information from our system.</p>
<p>To preserve the confidentiality of
your information, we must be able to correctly identify you.
For this reason,
please provide us with a copy of an official document to prove your identity.
This copy will be safely destroyed within two months of your request being
received and closed.</p>
<p>Our team will look into your request
and answer you within one month, unless your request requires further
investigation.
You’ll be specifically informed if that is the case.</p>
<p>
<b>13.  .
</b>
<b>CCPA</b>
</p>
<p>The California Consumer Privacy Act
of 2018 (CCPA) permits California residents to request from a business, with
whom the California resident has an established business relationship, certain
information about the types of personal information the business has collected,
shared with, and/or sold to third parties for a business or commercial purpose
during the immediately preceding calendar year.</p>
<p>As a Californian consumer, you also
have the right, at any time, to opt out of any type of selling of your personal
information.</p>
<p>Please note that we do not sell
your personal information to provide VPN Proxy Master or our services described
in this Privacy Policy.
Our partners and providers who work with us may have
access to your personal information in order to provide you with the services
within the limits and throughout the duration of our agreement, but they can’t
reuse your personal information for any other purposes.
Our contracts are
strictly drafted to protect your personal information and your privacy rights.</p>
<p> </p>
<p>
<b>13. .
BREACH NOTIFICATION</b>
</p>
<p>We will report serious breaches of
your data to the relevant supervisory authority to ensure your data is
protected.
</p>
<p> </p>
<p>
<b>14. .
CHANGES TO THIS PRIVACY POLICY</b>
</p>
<p>To ensure compliance with
applicable laws, this Privacy Policy may be modified from time to time without
prior notice to you.
Your continued use of VPN Proxy Master constitutes your
acceptance of our Privacy Policy.
Changes to this Privacy Policy will be posted
on our websites.
</p>
<p>If we materially change the ways in
which we use or share your data previously collected through VPN Proxy Master,
we will notify you through VPN Proxy Master, email, or other communication.</p>
<p> </p>
<p>
<b>15. .
GOVERNING LAW</b>
</p>
<p>This Privacy Policy is governed by
and construed in accordance with the laws of the Republic of Singapore.</p>
<p> </p>
<p>
<b>16. .
DATA PROTECTION OFFICER</b>
</p>
<p>HP Yeo is our Data Protection
Officer ("<b>DPO</b>").
The DPO may be contacted at DataPrivacyOfficer@lemonclove.net.</p>
<p>If you have any questions or
concerns about this Privacy Policy, please feel free to contact us at vpnproxymaster@lemonclove.net.</p>