Echo VPN

Privacy Policy

Date of Update

Effective date of policy: April 23, 2024

Date of update: April 23, 2024

Introduction

Welcome to the Echo VPN app (hereinafter collectively referred to as: Echo VPN)

GalaxNet Ltd. (hereinafter referred to as “we”) values the privacy and security of our users. When you use our services, we may collect and use your relevant information. We have formulated this privacy policy in accordance with relevant laws and regulations to protect the security of your personal information.

We hope that this policy will explain to you the information we may collect, the method of collection, the scope of collection, the purpose of collecting this information, and how we and you can protect the security of this information. Please read this policy carefully (especially the bolded content) and make sure you understand our rules for processing your personal information before using our products and services.

If you have any questions about this privacy agreement, you can contact us for consultation. If you do not agree to any of the terms in this privacy policy, you should immediately stop using our products and services.

We will try our best to express the relevant technical terms involved in this “Privacy Policy” in a concise and clear manner and provide further explanations for your understanding. Your use or continued use of our services means that you agree to our collection, use, storage and sharing of your relevant information in accordance with this “Privacy Policy”. If you have any questions, comments or suggestions about this “Privacy Policy” or related matters, you can contact us at any time.

Information Collection

We collect data depending on the scenario in which you interact with us. When we provide services, we will collect, store and use the following information related to you.

The main sources of personal information we collect are: information you provide to us, information we obtain during your use of our products or services, and your information shared by third parties. Generally, we will collect and use your personal information for the purposes of the following product functions. If you do not provide relevant information or do not agree to our collection of relevant information, you may not be able to enjoy some of the services we provide, or you may not be able to achieve good service results.

We usually collect personal information including: email address, phone number, IP address. “Echo VPN” may receive and collect your personal information in a variety of different ways.

These methods may include:

Information you actively provide

  1. To provide you with account registration, login functions and services, you may need to provide the following account registration information:

SMS verification login: If you choose this method to log in, you need to enter your mobile phone number and the corresponding verification code, and you can log in after verification. We will collect the mobile phone number you fill in for account management and login verification

Mobile phone, email login: You can register an account with your email or mobile phone number and create a password. When you use your email to register, we will verify your identity through your email; when you use your mobile phone number to register, we will send a text message verification code to your mobile phone number, and you need to provide us with the text message verification code to verify your identity before you can successfully register.

(1) To provide you with better services through account management. By logging in to your account, you can better use our services on your mobile phone, computer, TV, and browser. By logging in to your account, you can continue to view and use the relevant information you have synchronized, and the data will not be lost due to changing devices.

(2) When you encounter problems such as losing your registered account or forgetting your password, you can easily retrieve your account and password.

  1. Information you upload when using our products and services or provide to us when participating in activities we hold.

Mainly including: to prevent cheating, your IP address and device information will be verified; other information you upload when using our products and services is subject to the privacy policy of the specific product or service. The purpose of collecting the aforementioned information is to realize the corresponding specific functions. If you do not provide relevant information, the corresponding functions may not be realized.

Some specific functions of our products and services may require you to provide specific personal sensitive information to achieve. Before collecting personal sensitive information, we will inform you in a prominent way and obtain your consent. If you choose not to provide this type of information, you may not be able to use the corresponding function normally, but it will not affect your use of other functions in the service. If you actively provide your personal sensitive information, it means that you agree that we will process your personal sensitive information in the manner and for the purposes described in this policy.

Information we obtain when you use the service

  1. Device Information

We are committed to providing you with a safe and trustworthy product and use environment. Providing high-quality and reliable services and information is our core goal. In order to maintain the normal and stable operation of related products or services and protect the safety and legitimate interests of you or other users or the public, we will collect the following necessary information:

(1) In order to ensure the safe operation of software and services, the quality and efficiency of operations, we will collect your device’s hardware model, operating system version number, device identifier (such as IMEI, AndroidID, OAID, IMSI, ICCID, MEID, hardware serial number for Android), network device hardware address (MAC address), IP address, WLAN access point (such as SSID, BSSID), Bluetooth, base station, software version number, network access method, type, status, network quality data, operation, usage, service log, and device sensor data (including in the background).

(2) In order to prevent malicious programs and ensure operational quality and efficiency, we will collect information about installed applications or running processes, the overall operation, usage and frequency of applications, application crashes, overall installation and usage, performance data, and application sources.

(3) We may use your account information, device information, service log information, and information that our affiliates and partners have obtained your authorization or can legally provide to us to determine account security, transaction security, conduct identity verification, identify illegal and irregular situations, detect and prevent security incidents, and take necessary recording, analysis, and disposal measures in accordance with the law.

(4) In order to identify your device ID, prevent malicious programs and anti-cheating, improve service security, and ensure operational quality and efficiency, we will collect your device information (including IMEI, MEID, Android ID, IMSI, GUID, MAC address), and information about the applications you have installed or the processes that are running.

(5) When you share or receive shared information, participate in activities, etc., we need to access your clipboard locally and read the passwords, share codes, and links contained in it to realize functions or services such as jumping, sharing, and activity linkage. We will only upload the content of your clipboard to our server when we locally identify that it belongs to instructions such as jumping, sharing, and activity linkage. In addition, we will not upload other information from your clipboard to our server.

(6) In order to identify your device ID, prevent malicious programs and anti-cheating, improve service security, and ensure operational quality and efficiency, we will collect your device information (including IMEI, MEID, Android ID, IMSI, GUID, MAC address), and information about the applications you have installed or the processes that are running.

  1. Log Information

For service security purposes, when you use our products and services, the system may automatically collect certain information and store it in server logs. Such information may include: device event information, including crashes, system activity information, and other related information.

Sharing, Transfer, and Public Disclosure of Information

Sharing

We will do our best to protect user privacy, but when we have reason to believe that only by disclosing personal information can we comply with current judicial procedures, court orders or other legal procedures or protect the rights, property or safety of “Echo VPN”, “Echo VPN” users or third parties, we may disclose personal information.

Transfer

We will not transfer your information to any company, organization or individual, except in the following cases:

  1. Obtain your express consent or authorization in advance;

  2. In transactions involving mergers, acquisitions, asset transfers or similar transactions. If personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this statement, otherwise, we will require the company or organization to re-seek your authorization and consent.

Public Disclosure

Please understand that in the following situations, according to laws, regulations and national standards, we may share, transfer, and publicly disclose your personal information without your prior authorization and consent:

  1. Related to the personal information processor’s performance of obligations stipulated by laws and regulations;

  2. Related to national security and national defense security;

  3. Directly related to public safety, public health, and major public interests;

  4. Directly related to criminal investigation, prosecution, trial, and execution of judgments;

  5. For the purpose of safeguarding your or other individuals’ major legitimate rights and interests such as life and property, but it is difficult to obtain your consent;

  6. Personal information that you disclose to the public on your own;

  7. Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

Please be aware that according to applicable laws and regulations, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot restore it, the sharing, transfer, and public disclosure of such processed data does not require separate notification to you and your consent.

Protecting Your Information Security and Measures

  1. GalaxNet attaches great importance to your information security. We strive to take various reasonable physical, electronic and administrative security measures to protect your personal information. Prevent personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will use encryption technology to improve the security of personal information; we will use trusted protection mechanisms to prevent personal information from being maliciously attacked; we will deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we will hold security and privacy protection training courses to strengthen employees’ awareness of the importance of protecting personal information.

  2. When you use Echo VPN products, we encrypt all your access information to ensure its security and reliability. All communications on the official website of Echo VPN are encrypted and transmitted via HTTPS, and user passwords are encrypted one-way. No one, including Echo VPN employees, can know the user’s password. However, please understand that due to technical limitations and various possible malicious means, in the Internet industry, even if we do our best to strengthen security measures, it is impossible to always guarantee 100% information security. You need to understand that the system and communication network you use to access our services may have problems due to factors beyond our control.

  3. You should pay attention to protecting your personal information security. For example, do not share your account or disclose your personal password.

  4. You can choose to cancel your account on the “Me” page, “Account Settings”, and submit an account cancellation application.

  5. After you actively cancel your account, we will stop providing you with products or services, and delete your personal information or anonymize it in accordance with applicable laws.

Location and Duration of Information Storage

(1) Location of Information Storage

We comply with the provisions of laws and regulations and store the collected user personal information within the territory of the user’s location.

(2) Duration of Information Storage

Generally speaking, we only retain your personal information for the minimum time necessary to achieve the purpose. However, in the following cases, we may change the storage time of personal information due to legal requirements:

· To comply with applicable laws and regulations;

· To comply with court judgments, rulings or other legal procedures;

· To comply with the requirements of relevant government agencies or legally authorized organizations;

· We have reason to believe that we need to comply with relevant laws and regulations;

· To implement relevant service agreements or this policy, maintain social public interests, and protect the personal and property safety or other legitimate rights and interests of our customers, us or our affiliates, other users or employees.

When our products or services cease to operate, we will notify you by, for example, push notifications, announcements, etc., and delete or anonymize your personal information within a reasonable period of time.

Filtering and Deleting Harmful Information

“Echo VPN” prohibits users from using products or services to publish any harmful information, including:

(1) Violating the basic principles established by the constitution;

(2) Endangering national security, leaking state secrets, subverting state power, and undermining national unity;

(3) Damaging national honor and interests, and attacking the party and government;

(4) Inciting ethnic hatred, ethnic discrimination, and undermining ethnic unity;

(5) Undermining friendly relations between countries and regions;

(6) Violating traditional virtues, social ethics, and socialist spiritual civilization;

(7) Undermining the state’s religious policies and propagating cults and feudal superstitions;

(8) Spreading rumors or false information, disrupting social order, and undermining social stability;

(9) Inciting, organizing, or abetting terrorist activities, illegal assemblies, associations, processions, demonstrations, or gatherings to disrupt social order;

(10) Spreading obscenity, pornography, gambling, violence, terror, or abetting crime;

(11) Insulting or slandering others and infringing on the legitimate rights and interests of others;

(12) Infringing on others’ portrait rights, name rights, reputation rights, privacy rights, or other personal rights;

(13) Using uncivilized language such as cursing, insulting, slandering, intimidating, or cursing;

(14) Conducting activities in the name of illegal non-governmental organizations;

(15) Infringing on the legitimate rights and interests of others such as copyright and information network dissemination rights;

(16) Containing other content prohibited by laws and administrative regulations.

If a user of “Echo VPN” fails to perform and abide by the provisions of the agreement, “Echo VPN” has the right to close the account of the user who violates the agreement, and at the same time reserves the right to pursue the legal responsibility of the party concerned in accordance with the law. In addition, “Echo VPN” shall not be liable for breach of contract or other legal liabilities to the user who violates the agreement after taking corresponding measures. “Echo VPN” obtains the right to deal with illegal and irregular content in accordance with this agreement. This right does not constitute an obligation or commitment of “Echo VPN”. “Echo VPN” cannot guarantee timely detection of illegal acts or corresponding treatment.

Permission Statement

Network permission: The application function needs to request the network

Protection of Minors

Our website, content, applications or services are not suitable for anyone under the age of 14 (“children”). Minors over 14 (inclusive) and under 18 should read this “Privacy Policy” under the guidance of their parents or guardians, and complete the use of related services with the consent of their parents or guardians. We do not knowingly collect personally identifiable information from anyone under the age of 14. If you believe that your child has provided us with information, please contact customer service immediately via our email or QQ so that we can delete the child’s information.

Information Security

We provide corresponding security guarantees for your information to prevent information loss, improper use, unauthorized access or disclosure.

We strictly abide by laws and regulations to protect users’ communication secrets.

We will use various security protection measures within a reasonable security level to ensure the security of information. We use encryption technologies (for example, IPSec, Wireguard, TLS), anonymization processing and other means to protect your personal information.

We have established special management systems, processes and organizations to ensure information security. For example, we strictly restrict the scope of personnel who can access information, require them to abide by confidentiality obligations, and conduct audits.

If a personal information leakage or other security incident occurs, we will activate an emergency plan to prevent the security incident from expanding. We will promptly inform developers and/or you of the basic situation of the security incident, the disposal measures and remedial measures we are about to take or have taken, and our response suggestions in the form of push notifications, emails, etc.

Changes to the Privacy Policy

With the development of Echo VPN’s business and in order to provide you with better services, we may revise the content of this “Privacy Policy” from time to time. Such revisions constitute a part of this “Privacy Policy”. If such revisions result in a substantial reduction of your rights under this “Privacy Policy”, we will notify you by prompting you in a prominent position on the software announcement, website page, or by sending you an email or by other means before the revision takes effect. In this case, if you continue to use our services, you agree to be bound by the revised “Privacy Policy”.

Contact Us

We have set up a dedicated personal information protection team and a person in charge of personal information protection. If you have any questions, complaints, or suggestions about this privacy policy or personal information protection related matters, you can contact us in the following ways:

Send your questions to [email protected];

We will review the issues involved as soon as possible and give feedback within 15 working days or the time limit stipulated by laws and regulations.

Appendix: Keyword Definition

Personal information: refers to various information recorded electronically or in other ways that can identify a specific natural person’s identity or reflect a specific natural person’s activities alone or in combination with other information.

User: A natural person who entrusts the personal information he holds to the control of the data controller by using the products and/or services.