Roma Belden Ltd. recognizes the importance of your privacy, and we take it seriously. This Roma Belden Privacy Policy (the "Privacy Policy") describes our privacy practices for the activities set forth in this Privacy Policy. In this Privacy Policy, "Roma Belden," "we," or "the Company" refers to www.lunaproxy.com. Please read this Privacy Policy carefully to understand how we collect, use, share, and otherwise process information relating to individuals ("Personal Data") and to understand your rights regarding our processing of Personal Data.
This Privacy Policy does not apply to situations where we process Personal Data on behalf of our clients as a processor, including, but not limited to, situations where we provide various services to our clients through which our clients (and/or their affiliates): create their own websites and applications; sell or offer their own products and services; send electronic communications to other individuals; or otherwise collect, use, share, or process Personal Data through our services.
If you have additional questions or require more information about our privacy policy, please feel free to contact us by email at [email protected].
The data we collect depends on your interactions with us. When we provide services, we may collect, store, and use the following information about you. If you do not provide relevant information, you may not be able to enjoy some of our services or experience the desired results.
Personal information we may typically collect includes: name, email address, phone number, and IP address. LunaProxy may receive and collect your personal information in a variety of ways.These methods may include:
1.1 Your Correspondence
When you email or write to us, you may provide your personal information, contact information, and other personal information in the email.
1.2 Customer Support
When you call or email us to request technical assistance or learn more about our products, you may provide us with personal information.
1.3 Product Registration
When you register for a LunaProxy account, you will be asked to provide information so that we can record you as the owner of the LunaProxy account. This information will help us provide you with services and information.
1.4 You understand and agree that LunaProxy will provide you with services based on the information collected from you and will analyze and process your information accordingly.
1.5 You are responsible for the integrity and confidentiality of the data you store on the LunaProxy platform and the information you enter and manage on the LunaProxy platform. You will be solely responsible for any losses and consequences resulting from the loss or disclosure of your information due to improper maintenance or confidentiality.
1.6 You will be solely responsible for any losses and consequences resulting from your negligence, misuse, or actions authorized by LunaProxy.
1.7 You will ensure that your use of the Service complies with legal requirements. LunaProxy only provides standard services to you based on your instructions and is not responsible for the legal compliance of your use of the Service.
1.8 Device Information
We may receive and record information about the device you use. For example: device model, operating system and version, client version, device resolution, package name, device settings, process and software list, device identifiers (MAC/IMEI/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information), software and hardware characteristics, and device location information (such as IP address, GPS location, Wi-Fi access point, Bluetooth, and base station sensor information). To collect this basic personal device information, we will request permission to access your device information. We collect this information to provide you with our basic services and basic features. If you refuse to provide the above permissions, you may not be able to use the LunaProxy service.
1.8.1 When you first open the LunaProxy app, after obtaining your authorization, we will receive and record information related to the device you are using, including device attributes (such as IMEI, IMSI, device model, operating system version, device settings, unique device identifier software and hardware characteristics), and device connection information (such as MAC address, IP address, telecom carrier, and access date and time) to protect the security of your account and transactions.
1.8.2 To achieve the purposes described in this Policy, we may integrate SDKs or other similar applications provided by third-party service providers and share some of your information collected in accordance with this Policy with such third-party service providers to provide better customer service and user experience.
1.9 Real-Name Requirements: To comply with national cybersecurity regulations, you are required to undergo static real-name authentication before using our services. We collect this information solely for identity verification and security management and associate it with your account.
Please note that personal device information and log information cannot identify a specific individual. If we combine such non-personal information with other information to identify a specific individual, or use it in conjunction with personal information, such non-personal information will be treated as personal information during the combined use. Unless we have your authorization or otherwise provide for compliance with laws and regulations, we will anonymize and de-identify such personal information. During the combined use, such information will be processed and protected as your personal information in accordance with this Policy.
When you use Roma Belden (www.lunaproxy.com) services, we may collect your personal data in the following ways:
1. Information You Provide
· When you establish a business relationship with us or use our services, including but not limited to:
· Personal information such as name, email address, and phone number you submit when registering an account
· Transaction information such as payment information and billing address you provide when completing a transaction
· Communication details you provide when contacting us through online forms, customer service channels, or email
· Voluntary feedback you provide when participating in surveys or marketing campaigns
2. Information Collected Automatically Through Technical Means
· When you visit our website or use our services, our systems may automatically collect the following information through technologies such as cookies and log files:
· Device identifiers (such as IP address, device ID, and browser type)
Usage behavior data (e.g., visit duration, clickstream, page response speed)
Geolocation information (based on IP address or device GPS location, requiring your separate authorization)
Diagnostic data (e.g., crash reports, system activity logs)
3. Information from Third Parties
Subject to applicable law, we may obtain supplemental information from the following sources:
Business partners (e.g., transaction verification information provided by payment processors)
Ad networks and analytics service providers
Social media platforms (when you choose to log in through a third-party account)
Publicly available databases or government registration information
4. Information Processing in Special Scenarios
When you authorize integrated services, basic account information from the relevant platforms may be collected.
ID card information collected for identity verification as required by law (this information will be stored in a strictly encrypted format)
We are committed to data minimization and only collect information necessary to achieve specific service purposes. You can manage the collection of certain information through your account settings or control automatic collection by clearing your browser cookies. For non-essential, optional information collection, we will obtain your explicit consent before collecting it.
Note: This clause does not apply to situations where we process personal data on behalf of our clients as a data processor. In such cases, we will strictly comply with the data processing agreement signed with our clients.
1.Clearly Defined Data Processing Purposes:We process your personal data only for the limited and specific purposes explicitly stated in this policy and are committed to strictly adhering to the principle of "purpose limitation." All processing activities are based on clear legal grounds, and any subsequent processing will not be incompatible with these initial purposes.
The primary purposes for which we process your data include:
（1）Service Provision and Contract Fulfillment:To establish and perform the service contract with you, we process your information to create and manage user accounts, provide and maintain stable IP proxy connections, calculate data usage, process payments and prevent fraud, as well as provide necessary customer support. The data processed for this purpose primarily includes your account information, IP address, connection logs, data usage, and payment information. The legal basis for this processing is the necessity for the performance of the contract with you.
（2）Security and Compliance Assurance:To protect our services, users, and the public interest, we process data to monitor and prevent service abuse, fraudulent activities, and cyberattacks, ensure network and information security, and fulfill legal obligations we are subject to (such as responding to lawful requests from law enforcement). This purpose involves processing your IP address, connection timestamps, device information, and security event logs, among others. The legal bases for this processing are our need to comply with legal obligations and the legitimate interests we pursue in safeguarding service security.
（3）Service Improvement and Analysis: To continuously optimize service quality and user experience, we analyze usage trends and data in an anonymized or aggregated form to improve server performance, develop new features, and conduct internal statistical research. The legal basis for this purpose is our legitimate interest in service optimization.
（4）Marketing and Communication:Subject to your explicit consent, we may use your contact information (such as email address) to send you product updates or marketing communications that may be of interest to you, and to respond to your inquiries in a timely manner. Processing for this purpose is strictly based on your consent.
Within the legal framework, we process and use your personal information based on the following lawful purposes:
* Necessity for fulfilling requirements under this Privacy Policy or the Platform Terms of Use;
* Your explicit consent (which you may withdraw at any time);
* Necessity for complying with our legal obligations;
* Necessity for protecting your or another person's vital legitimate interests;
* Necessity for tasks carried out in the public interest;
* Necessity for realizing our (or a third party's) legitimate interests, including providing users and partners with secure, compliant, and sustainable services.
The purposes of all data processing activities are clearly defined within the agreement, and subsequent processing shall not exceed the scope of the established purposes.
Regarding Purpose Changes and Update Notifications:
If we need to use your personal data for a new purpose that is incompatible with the original purpose for which it was collected, we will clearly inform you of the new purpose and its legal basis via email or a prominent notice on the platform before commencing the new processing activity. In such cases, we will seek your explicit consent again (when consent is necessary). Any revisions to this policy will be communicated to you by updating the date at the top of this document and issuing a notice. You have the right to stop using our services if you object to such changes.
2.Data Storage
We strictly limit the storage period of your personal data based on the legal basis and specific purposes of data processing, with specific standards as follows:
2.1 Based on your consent: With your consent for us to process data, we will store your data until you withdraw such consent. From the date you withdraw consent, we will stop processing and delete or anonymize related data, unless other legal bases allow us to continue retention.
2.2 Based on contract fulfillment: When necessary for fulfilling contracts signed with you, we will store your data during the duration of the contractual relationship. After termination of the contractual relationship, if there are statutory retention obligations (such as tax and business record keeping requirements), we will continue to store related data within such statutory periods. After the statutory period expires, we will delete or anonymize the data.We adhere to the principle of data minimization and will retain personal data only for as long as necessary to fulfill the processing purposes, provided that no specific legal requirements mandate a longer retention period. In no event shall the storage period exceed two years.
2.3 Based on legitimate interests: When we process your data based on legitimate interests, the storage period is the time necessary to achieve that specific processing purpose. Once the processing purpose is achieved, or when your deletion or anonymization interests outweigh our legitimate interests, we will promptly delete or anonymize related data.
2.4 Based on legal obligations: When processing data to comply with obligations stipulated by laws, regulations or regulatory authorities, we will store your data within the periods specified by relevant laws, regulations or regulatory requirements. After fulfillment of such legal obligations, we will delete or anonymize the data.
We adhere to the principles of data minimization and storage limitation. Throughout the entire data lifecycle, we continuously assess the necessity of data retention. Once it is determined that certain data is no longer necessary for the purposes for which it was originally collected, we will promptly and securely delete or anonymize such data through established systematized procedures.Following anonymization (e.g., through the removal of direct identifiers), the data can no longer be attributed to a specific individual. We utilize such anonymized data for statistical analysis to improve our products and services.
3. Data Anonymization and Statistical Analysis: We will anonymize data that has been stripped of personal identifiers (such as source IP addresses and user IDs). This anonymous data may be used for macro-level statistical analysis, business trend research, and service optimization. Such processing will not identify specific individuals.
4. Data Sharing and Disclosure: We value your privacy and strictly prohibit the sharing or sale of your personal data to any third party, except in the following circumstances:
Compliance with Laws and Regulations: Disclosure is necessary in response to regulatory requirements from government agencies, judicial bodies, or other legal requirements;
Protection of Rights and Security: When necessary to protect the rights, property, and safety of us, our users, or the public.
We respect your rights to your data and provide convenient channels for you to exercise them.
1. Right of Access, Correction, and Deletion: You have the right to access, correct, or delete the personal data we hold about you.
2.Account Deletion and Data Deletion (Right to Be Forgotten): You may request account deleting through the following channels. Once you submit a deletion request (account deleting) and the circumstances for deletion meet the requirements set forth in relevant laws (e.g., the data is no longer necessary for the processing purposes, you have withdrawn your consent, and there is no other lawful basis for processing), we will immediately initiate the deletion process and permanently delete your personal data，as if :
• The data is no longer necessary for the purposes for which it was collected;
• You have withdrawn your consent on which the processing was based, and there is no other legal ground for the processing;
• You have exercised your right to object (see Section 16);
• The data has been processed unlawfully.
If we have disclosed your personal data, and if required by law, we will take reasonable steps (such as posting a deletion notice on the relevant platforms) to notify other data controllers processing your data and request that they delete any links, copies, or replications of your data.
Furthermore, the erasure primarily constitutes measures to ensure that the data can no longer identify you or be used for such purposes. Technically, this may involve methods such as pseudonymization or anonymization. Residual data may be temporarily retained within backup systems until it is securely deleted in accordance with scheduled retention cycles.
3. Convenient Request Channel: We have established a dedicated customer service channel to handle any of your requests or questions:
Customer Service Email: [email protected] (Please use your registered email address and provide the necessary identification information so that we can verify your identity and process your request).
LunaProxy may use your personal information for the following purposes:
5.1 Product Registration
The information you provide during registration will be used to create your LunaProxy account and to assist LunaProxy in providing support when you contact LunaProxy customer service. LunaProxy will also use this information to notify you about any upgrades, new products, promotions, or other information that may be of interest to you.
5.2 Product Use
LunaProxy may use the information collected during product use to: regularly verify your right to use the product or service; confirm whether you have previously used the product/feature or whether it will benefit your use of LunaProxy before sending you notifications of new product/feature upgrades; and receive internal product information from LunaProxy upon your request.
5.3 Internal Analysis
We may use the information you provide us for internal statistical and analytical purposes to evaluate and enhance your experience using the LunaProxy website and software, including by identifying your preferences and operating and conducting related activities. LunaProxy does not require you to provide personal information (including but not limited to your mobile phone number and email address), but will collect other information (including but not limited to device information, log information, and similar feature records). LunaProxy's user experience improvement program is based on usage data statistics, diagnosing system issues, and optimizing the product experience. We may use tools such as Google Analytics to collect data generated during your use of LunaProxy products.
LunaProxy may combine the information you submit through your account with information from other leading services or third parties to provide you with a better experience and improve service quality.
Because "LunaProxy" has the function of hiding its real IP address, the vast majority of users use this function for legitimate purposes. However, there may be a small number of users who use this function for improper purposes. "LunaProxy" automatically records and receives your usage records and other information, which is only used to determine illegal use and abuse behavior and shall not be used for other purposes. Usage records include:
(1) Date and time
(2) Connection status
(3) User's original IP address and port number
(4) Protocol type
(5) Client software version number
(6) Web page URL records, cookies, and other information you requested.
"LunaProxy" will not share any personal information with third parties without your consent.
We promise that this data will not be shared with any third-party service agencies and will not be used for commercial purposes. This data is only used for the security of user accounts, the stability of software services, and whether users have found any abnormalities in our software servers. LunaProxy will strictly abide by relevant laws and regulations and the content set in this privacy policy to collect and use your information. LunaProxy's specific staff will not directly ask you for personal information unless they hold an official authorization document issued by LunaProxy. In this case, you can contact LunaProxy directly.
Third-party services
LunaProxy services can access or link to social media or other services (including websites or other forms of services) provided by third parties, including:
(1) You can use third-party services to log in to LunaProxy. Your information (including your log information) may be collected and cookies may be installed on your computer to operate normally;
(2) We provide you with links through advertisements or other means of our services to enable you to access third-party services or websites;
(3) Other situations of accessing third-party services. For example, to achieve the purposes described in this policy, we may access SDKs or other similar applications (such as embedded codes, plug-ins, etc.) provided by third-party service providers to provide you with better customer service and user experience. The third-party service providers we currently access are mainly the following:
1) For advertising-related services, including advertising display, advertising data monitoring/statistics, etc.;
2) For message pushFunctions, including push notifications from mobile phone manufacturers, reminders of specific events, personalized content recommendations, etc.;
3) For payment-related services, including order payment, transaction verification, revenue settlement, payment information summary statistics, etc.;
4) With your consent, for obtaining device location permissions, collecting device information and log information, etc.;
5) For optimizing product performance, including improving hardware distribution network capabilities, reducing server costs, and hot fix functions;
6) For account security and product reinforcement-related services, including network monitoring, domain name resolution, anti-hijacking, anti-spam and anti-cheating, encryption and decryption services, etc.
(4) For functions provided by third-party SDKs, the required permissions and user information collected are: SDK permissions and collected user information
The above-mentioned third-party social media or other services are operated by the relevant third parties. Your use of the third-party social media services or other services (including any information you provide to the third party) is subject to the third party's own terms of service and information protection statement (not this Privacy Policy), and you need to read its terms carefully.
This Privacy Policy applies only to any information collected by us and does not apply to any services provided by any third party or the third party's information usage rules. We are not responsible for any third party's use of the information provided by you.
8.1 Service Fees. The Company reserves the right, at its sole discretion, to determine the Service fees, the validity period of prices, applicable promotions and discounts, and other rules relating to payment for the Services.
8.2 The latest applicable price list for each Service category is available on the System at https://www.lunaproxy.com/pricing/residential-proxies/
8.3 The Company may change the price and scope of any Service without prior notice. Before placing an order, customers should always check the System to understand the applicable prices and features for each Service.
8.4 Upon expiration of your Service, your right to use the Service will be suspended until you pay for further Services.
8.5 The Company's Services are based on proxies/GB used (fees are calculated based on the number of proxies or GB used ordered by the customer).
8.6 The customer warrants that it will use and provide payment information that it owns or is authorized to use for the purposes described in this Agreement. The customer will update its payment information to keep it current at all times.
We will do our best to protect user privacy, but we will only disclose personal information when we reasonably believe disclosure is necessary to comply with existing judicial proceedings, court orders, or other legal process, or to protect the rights, property, or interests of LunaProxy, LunaProxy users, or third parties. We will disclose personal information in accordance with applicable law and procedures, where it is safe to do so.
We or our third-party partners may use cookies on the LunaProxy website. Cookies allow us or our third-party partners to automatically access and use the data entry features of our website, tailor promotions or marketing campaigns, and provide online ordering information related to your purchases.
In addition, we or our third-party partners may use cookies to track the use of our website to determine which features are useful or popular and which are not, and to help us improve and update our services effectively. Most web browsers will warn you about the use of cookies or refuse to accept cookies altogether. You can accept or refuse cookies by modifying your browser settings. However, if you disable cookies, you will not be able to use the various interactive features of this website.
We or our third-party partners use cookies for the following purposes:
1) Remembering you. For example, cookies help us identify you as a registered user or store information you provide us about your preferences or other information.
2) Analyze your use of our services. We may use cookies to understand your activities on LunaProxy services or which services are most popular.
3) Ad optimization. Cookies help us provide you with relevant ads based on your information, rather than generic ads.
While we use cookies for the purposes described above, we may provide advertisers and other partners with aggregated, non-personally identifiable information collected through cookies for purposes such as analyzing how you and other users use LunaProxy services and for advertising purposes.
1. We minimize the use of third-party services to minimize privacy breaches, and we strive to ensure that the third-party service providers we use have trustworthy security systems to protect user data.
2. When you use LunaProxy products, all your access information is encrypted for transmission to ensure its security and reliability. All communications on the LunaProxy website are transmitted using HTTPS encryption, and user passwords are one-way encrypted, making them inaccessible to anyone, including LunaProxy employees. However, please understand that due to technological limitations and the potential for malicious activity, even with our best efforts to strengthen security measures, 100% information security cannot always be guaranteed in the internet industry. Please understand that the systems and communication networks you use to access our services may experience problems due to factors beyond our control.
3. You should take care to protect the security of your personal information. For example, do not share your account or disclose your password.
"LunaProxy" prohibits users from using products or services to publish any harmful information, including:
(1) Violation of the basic principles established by law;
(2) Endangering national security, leaking state secrets, subverting the state power, and undermining national unity;
(3) Inciting ethnic hatred, ethnic discrimination, and undermining national unity;
(4) Undermining friendly relations between countries and regions;
(5) Undermining national religious policies, promoting cults and feudal superstitions;
(6) Spreading rumors or false information, disrupting social order, and undermining social stability;
(7) Inciting, organizing, or instigating terrorist activities, illegal gatherings, associations, parades, demonstrations, or assemblies, and disrupting social order;
(8) Spreading obscenity, pornography, gambling, violence, terror, or instigating crimes;
(9) Insulting or slandering others, infringing upon the legitimate rights and interests of others;
(10) Infringement of others' portrait rights, name rights, reputation rights, privacy rights or other personal rights;
(11) Use of foul language, insults, defamation, threats, curses and other uncivilized language;
(12) Impersonation of illegal non-governmental organizations;
(13) Infringement of others' copyrights, information network dissemination rights and other legal rights;
(14) Containing other content prohibited by laws and administrative regulations.
If the user fails to perform and comply with the agreement in "LunaProxy", "LunaProxy" has the right to close the user account that violates this agreement and reserves the right to pursue legal liability in accordance with the law. In addition, "LunaProxy" shall not bear any liability for breach of contract or other legal liability for users who violate the agreement after taking corresponding measures. "LunaProxy" obtains the right to deal with illegal content in accordance with the provisions of this agreement. This right does not constitute an obligation or commitment of "LunaProxy", and "LunaProxy" does not guarantee to discover illegal acts in a timely manner or take corresponding measures.
Our website, content, applications or services are not suitable for anyone under the age of 14 ("children"). Minors aged 14 years and above but under 18 years of age should read this Privacy Policy under the guidance of their parents or guardians and use the relevant services with their parents' or guardians' consent. We do not intentionally collect personally identifiable information from anyone under the age of 14. If you believe your child has provided us with information, please contact customer service immediately via email or online support so that we can delete your child's information.
As LunaProxy's business develops and we seek to provide you with better services, we may amend this Privacy Policy from time to time, and such amendments shall constitute part of this Privacy Policy. If such amendments result in a substantial reduction in your rights under this Privacy Policy, we will notify you prior to the amendment taking effect, such as through a prominent notice in the software, on our website, or by email. In such event, your continued use of our services constitutes your agreement to be bound by the revised Privacy Policy.
Company: ROME BELDEN LIMITED
Address: Room 401, 4/F, Wan Chai Central Building, 89 Lockhart Road, Wan Chai, Hong Kong
Contact: [email protected]
If you have any questions, comments, or suggestions about our Privacy Policy and how we handle your information, please feel free to contact us.
These Terms of Service and any separate agreements we provide you shall be governed by and construed in accordance with the laws of Hong Kong.