Privacy Policy

This policy explains what personal data we collect, why we use it and what rights you have. It covers our website, your account, the proxy service, our emails and our support in Discord.

1. Who we are

1. We are Primed Project R Ltd, trading as Primed Proxies. We are registered in England and Wales, company number 13043119. Our registered office is 42-44 Bishopsgate, London, EC2N 4AH.
2. We are the controller of the personal data described in this policy. That means we decide why and how it is used.
3. To ask about your data, email hello@primedproxies.com or use our contact form. We are a small company and have no data protection officer.

2. What we collect

• Account. Your first name, last name, email address and password. We store the password as a hash, so we cannot read it. We keep your marketing choice and the time you made it. We keep a record of the codes we email to confirm your address.
• Orders and payment. What you bought, when, and the price. Any promotion code or referral code. Your billing country and tax details. Stripe's references for you and your payments. Stripe collects your card details. We do not see or store your full card number.
• Service. The gigabytes you use each day and the proxy lists you generate. Your proxy username and password. Any UK ISP addresses assigned to you.
• Proxy traffic records. See section 5.
• Support. Your emails and messages to us, including abuse reports and messages in Discord. If you buy through our Discord, we record your Discord user ID and username.
• Website. Your IP address and browser details. Every website receives these when you load a page.
• Error reports. If something goes wrong on one of our pages, your browser sends our own systems a short report: what went wrong, the page's address without anything after it, the type of browser and the time. The report holds no name, no account and no cookie.
• Buying steps. Which steps of buying you reach on our site, on which page and when: arriving from another site, opening "Create an account", creating it, confirming your email address, opening "Check and pay", going to Stripe's payment page, and coming back paid. With them, the product and amount you chose. We store nothing on your device for this, unless you accept advertising cookies. Then the tab keeps the numbers of the orders it has shown as paid, until it closes, so that each is counted once. The steps do not name you or your account. The step of coming back paid names the order. If you accept advertising cookies, they also carry the code of the advert you clicked.
• Advertising. Only if you accept advertising cookies: the code of the Google advert you clicked, its campaign tags, the page you arrived on and when. We keep them with your account and your orders. See our Cookie Policy.
• Cookie choice. Whether you accepted or rejected advertising cookies, when, and which version of the question you answered.

We do not ask for identity documents to open an account. Please do not send us sensitive data, such as health details.

3. Where we get it

1. Most of this data comes from you.
2. Stripe tells us whether a payment succeeded, your billing country, your tax details and the result of its fraud checks.
3. Discord gives us your user ID and username when you order or message us there.
4. You must give us your account and order details so that we can supply the service. Without them we cannot open an account or take an order.
5. Marketing emails and advertising cookies are your choice.

4. What we use, why, and our lawful basis

Where we rely on legitimate interests, we have checked that our reasons do not override your rights. You can object. See section 10.

Under UK law we may also rely on the "recognised legitimate interest" of detecting, investigating or preventing crime. This can include giving data to the police or another public body that lawfully asks for it.

5. Proxy traffic

1. Our service carries your traffic to the sites you choose. We do not choose the sites or the content.
2. For each connection, the proxy gateway records the time and the amount of data used.
3. We do not record the content of your traffic, and neither do our network suppliers. Traffic sent over HTTPS stays encrypted between you and the destination, so we cannot read it.
4. We use these records to count the data you use and to avoid charging for failed requests. We also use them to find faults, investigate misuse and answer lawful requests.
5. We keep these records for 30 days and then delete them.
6. You are responsible for any personal data you collect through the service. We do not use that data, and we do not handle it on your behalf.

6. Who we share it with

We do not sell your personal data. We share it with the suppliers below, and each gets only what its task needs.

Stripe, Google, Discord, Trustpilot and Cloudflare also use some data for their own purposes, such as fraud prevention. Their own privacy policies explain how.

We also share data when the law requires it, for example with HMRC, the police, a court or a regulator. We may share data with professional advisers. If we sell or merge the business, the buyer would receive customer records. We would tell you first.

7. Sending data outside the UK

1. Some of our suppliers are outside the UK, or keep data on computers outside the UK.
2. Brevo and Trustpilot are in the EU. UK law treats EU and EEA countries as giving adequate protection.
3. Stripe, Vercel, Cloudflare, Google and Discord are based in the USA or send data there. For these we rely on one of two safeguards.
4. The first is the UK-US data bridge. It covers US companies certified under the UK Extension to the EU-US Data Privacy Framework.
5. The second is the supplier's contract with us, where it includes the UK International Data Transfer Addendum or Agreement.
6. You can ask us which safeguard applies to a supplier. You can also ask for a copy of it.

8. How long we keep it

Your residential data balance does not expire. Your account therefore stays open until you or we close it under our Terms.

9. Automated checks on payments

1. Stripe checks every payment for fraud with an automated system called Radar.
2. Radar scores the risk of each payment. It looks at details such as the card, the device, the IP address and patterns seen across other businesses that use Stripe.
3. Radar can block a payment, or lead to an extra check by your bank. No person takes that decision at the time.
4. If a payment is blocked and you think that is wrong, email us. One of us reviews it, hears your side and tells you the outcome.
5. We make no other decisions by automated means alone that have a legal or similarly significant effect on you.

10. Your rights

You have the right to:

• ask for a copy of your data;
• ask us to correct it;
• ask us to delete it;
• ask us to restrict how we use it;
• object to our use of it where we rely on legitimate interests;
• object to marketing at any time, and we stop;
• receive the data you gave us in a common format, or have us send it to another provider;
• withdraw your consent at any time. This does not affect what we did before;
• ask for a person to review an automated decision.

How to use your rights:

1. Email hello@primedproxies.com from the address on your account, or use our contact form. Writing from your account address lets us confirm who you are.
2. We do not charge for this.
3. We reply within one month. If a request is complex we can take up to two more months, and we tell you.
4. We search the places where your data is reasonably likely to be.
5. We must keep some data, such as invoices that tax law requires. We tell you if that applies.
6. To stop marketing email, use the link in any email or the setting in your account.
7. To change your cookie choice, see our Cookie Policy.

11. How to complain

1. Please tell us first. Email hello@primedproxies.com with "Privacy complaint" in the subject line, or use our contact form.
2. We confirm that we have your complaint within 2 working days. We look into it and tell you the outcome without undue delay.
3. You can also complain to the Information Commission, the UK data protection regulator. It is still known as the ICO. Go to ico.org.uk/make-a-complaint or call 0303 123 1113. The ICO normally expects you to complain to us first.
4. If you live in the EU or EEA, you can also complain to the data protection authority in your country.

12. Security

1. We store your account password as a hash. We cannot read it.
2. Stripe takes your card details on its own page. We never see or store your full card number.
3. Our website uses encrypted connections (HTTPS).
4. We limit access to customer records to the people who need it to run the service.
5. Your proxy password is in every list you copy or download from your dashboard. On screen it is masked. Treat it like a key. Reset it if someone else may have seen it.
6. No system is completely secure. If a breach is likely to put you at high risk, we tell you without undue delay.

13. Discord

1. Our community runs on Discord. Discord is a separate company with its own privacy policy.
2. Other members can read what you post in shared channels. Do not post passwords, proxy logins or payment details there.
3. If you buy through our Discord, we store your Discord ID and username with your Stripe payment record. We use them to match the order to you and to support you.

14. Referrals

1. If you sign up through a referral link, we record which account referred you.
2. The referrer gets a reward based on the size of your first order. They can see that they earned a reward and how large it is. From that they can work out how much data your first order held.
3. The referrer does not see your name, your email address or your later orders.
4. If you share your own link, we record the accounts that used it and the rewards you earned.

15. Children

Our service is for adults. You must be 18 or over to open an account. We do not knowingly collect data from anyone under 18. If you think a child has opened an account, tell us and we close it.

16. If you are a business customer

1. This policy applies in the same way to the people who open and use a business account.
2. If you use our service to collect or use personal data, you are the controller of that data. We are not your processor. You need your own lawful basis and your own privacy notice.
3. We ask business contacts for consent before we send marketing email.

17. Changes to this policy

We post any new version on this page and change the date at the top. If a change makes an important difference to how we use your data, we email you before it takes effect.