Hula Link Technology Co., Ltd. is committed to protect your privacy. Our guiding principle toward data collection is to collect only the minimal data required to operate a world-class VPN service at scale. We want you to understand what information we collect, what we don't collect, and how we collect, use, and store information. We do not collect logs of your activity, including no logging of browsing history, traffic destination, data content, or DNS queries. We also never store connection logs, i.e., no logs of your IP address, your outgoing VPN IP address, connection timestamp, or session duration. We designed our systems not to have sensitive data about you; even when compelled, we cannot provide data that we do not possess.

This Privacy Policy describes how Hula Link Technology Co., Ltd. and its affiliates ("we," "our" or "us") collect, use, and share information in connection with your use of our websites, services, and applications (collectively, the "Services"). This Privacy Policy (the "Privacy Policy") does not apply to information you may process when using our Services.

We do not collect logs of your online activity while you are connected to our Services, including no logging of browsing history, traffic destination, data content, or DNS queries. We also never store connection logs, meaning no logs of your IP address, your outgoing VPN IP address, connection timestamp, or session duration.

1. COLLECTION OF INFORMATION

We collect information about the product and services that you use and how you use them in order to properly provide the core or important features of our product and service, or to improve our product and service, or to provide additional features to our product (such as socializing functions or value-added services and promotions, etc.).Some of the typical reasons that we collect personal data include:

When you open the APP seeking for our VPN services, the APP assigns a unique identifier to you for the service (such unique identifier just binds up with your device identification code, but does not tie to any other personal information of users). When you use the VPN services, we will check your account information through this unique identifier to determine the level of service you have signed up for before establishing your VPN connection.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.

2. USE OF INFORMATION

We will be able to use the information collected to 1) improve and develop our products and services; 2) communicate with users; 3) support advertising and related activities. E.g:

3. DATA RETENTION

We may retain information about you and your use of the Services, including personally identifiable information, as long as you are required to provide the services and uses described in this Privacy Statement. This usually means that we will retain information for the duration of your account.

4. SECURITY MEASURES

We take adequate protective measures to prevent loss of information, misuse, unauthorized access, disclosure, alteration or destruction. While we strive to protect your information and privacy, there is no guarantee that data transfer or storage is 100% secure.

5. DIRECT MARKETING

Hula Network is committed to user privacy globally, and personal information under users' control and minimal collection of data are our existing practices. According to the requirements of the General Data Protection Regulation (GDPR) of the European Union (EU), we collect and process the data in a specific manner of users in EU outlined in this Privacy Policy on one of the following bases, depending on the circumstances:

You can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. As well, you have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.

You can exercise your rights under the GDPR to access, transfer, correct, delete, or object to the processing of your personal information by contacting us at [email protected].

6. INTERNATIONAL DATA TRANSFERS

Hula Network is a global business. We may transfer personal information to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy.

7. CHANGES TO THIS PRIVACY POLICY

For the purpose to consist with applicable privacy laws and principles, this Privacy Policy may be modified from time to time without prior notice to you, so please review it frequently. Your continued use of our VPN services constitutes your acceptance of our Privacy Policy. Changes to this Privacy Policy will be posted on our websites. If we materially change the ways in which we use or share personal information previously collected from you through our VPN services, we will notify you through our APP, email, or other communication.

Revision date of this agreement: January 1, 2020