Privacy Policy

Welcome to our services. Shallx VPN Inc. and its affiliates ("we", "our", or "us") provide this Privacy Policy to describe how we handle your information through our applications, websites, social media pages, and events (collectively "services"). This document explains what personal information we collect, how we use and share it, and your rights regarding your data.

1. INFORMATION WE COLLECT. "Personal data" refers to any information that can identify or relate to an individual. We collect:

• Information You Provide: When you create an account, register for services, or contact us, we collect details like your name, email, address, phone number, payment details, and business information.
• Information From Other Sources: We may obtain data from third parties, affiliates, or partners to supplement our records, which may include contact details, professional information, or preferences.
• Automatically Collected Information: When you use our services, we collect:
  • Device and system information like IP address, device ID, operating system, and network details
  • Information through cookies and similar technologies (see our Cookies Policy for details)

1. HOW WE USE YOUR INFORMATION. We process your data based on legal grounds such as consent, contract fulfillment, or legitimate interests. We use it for:

• Providing Services: To deliver requested services, respond to inquiries, and send administrative notices.
• Account Management: To maintain your user account according to our service terms.
• Communications: To contact you about products, services, or events that may interest you (with consent where required).
• Payment Processing: To verify payment information and complete transactions.
• Event Coordination: To manage event registration and follow-up communications.
• Security and Compliance: To prevent fraud, investigate illegal activities, and meet legal obligations.
• Service Improvement: To diagnose issues, analyze usage patterns, and enhance our offerings.
• Personalization: To tailor your website experience and display relevant content.

1. HOW WE SHARE INFORMATION.

• With Affiliates and Service Providers: To assist with IT services, data management, and analytics.
• With Advertisers: To display relevant advertisements through our services and third-party platforms.
• With Law Enforcement: When required by law or to protect rights, property, or safety.
• During Legal Processes: In response to subpoenas, court orders, or other legal requirements.
• During Business Transfers: In connection with mergers, acquisitions, or similar transactions.
• With Your Consent: When you authorize specific disclosures.

1. YOUR DATA RIGHTS.

• Depending on applicable laws, you may have rights to access, correct, restrict, or delete your personal data. These rights are not absolute and may be subject to limitations.
• To exercise your rights, contact us at chenwei@maoxuyanyan.com. If unsatisfied with our response, you may lodge a complaint with relevant data protection authorities.

1. INTERNATIONAL DATA TRANSFERS. Your information may be stored and processed globally. We implement appropriate safeguards for international transfers. Contact us with any transfer-related questions.

1. DATA RETENTION. We retain personal data as necessary for business purposes, legal obligations, or dispute resolution, considering factors like our relationship duration and legal requirements.

1. SECURITY MEASURES. We implement technical and physical safeguards to protect your data. However, no security method is infallible. Please exercise caution when sharing information online.

1. ADDITIONAL PROVISIONS.

• This policy doesn't cover third-party websites/applications linked from our services.
• We do not knowingly collect information from individuals under 16.
• We may update this policy periodically. Please review it regularly for changes.

1. CONTACT US. For privacy-related questions or concerns:

Attn: Legal & Compliance - Privacy Counsel

chenwei@maoxuyanyan.com

1. CALIFORNIA-SPECIFIC DISCLOSURES.

• CCPA Compliance: We adhere to the California Consumer Privacy Act. "Personal data" includes information that identifies, relates to, or could be linked to a California resident.
• Information Collection: In the past 12 months, we collected these categories of personal data:
  1. Identifiers (name, contact details)
  2. Personal records information
  3. Commercial information
  4. Internet activity
  5. Professional/employment information
  6. Inferences drawn from data
  7. Financial information
• Your CCPA Rights:
  1. Access and Portability: Request details about data collection and disclosure
  2. Deletion: Request deletion of your personal data (subject to exceptions)
  3. Exercising Rights: Contact us through the methods above. We'll verify your identity before processing requests
  4. Non-Discrimination: We won't discriminate against you for exercising your rights
• We do not sell personal data as defined by CCPA
• California residents may request details about third-party marketing disclosures
• We currently don't respond to "Do Not Track" browser signals

Effective as of March 25, 2025