Privacy Policy

Last Updated: January 4, 2026

We fully understand the importance of personal information to you and will do our utmost to protect your personal information securely and reliably. We are committed to maintaining your trust by adhering to the following principles: the Principle of Accountability, Purpose Specification Principle, Choice and Consent Principle, Data Minimization Principle, Security Safeguard Principle, Participation Principle, and Transparency Principle. We also commit to adopting industry-standard security solutions and implementing appropriate security measures to protect your personal information. To this end, we have formulated this “ProxHub Privacy Policy” (hereinafter referred to as “this Policy/Privacy Policy”) and remind you of the following:

This policy applies to ProxHub products and related services.

Please note that this policy does not apply to services provided to you by other third parties, nor does it apply to products or services with separate privacy policies.

Before registering or using our services, please read and fully understand this policy, especially the terms highlighted in bold or underlined. You should read them carefully, and after fully understanding and agreeing to them, you can use the relevant products or services. If you refuse to accept this policy, you will not be able to use our application. If you have any questions, comments, or suggestions about the content of this policy, you can contact us through the contact information we provide.

1.Introduction

ProxHub strictly maintains user confidentiality and has established a comprehensive user information protection system to provide each user with reliable and secure services:

1. Clarity: We will explain the privacy policy to you as clearly as possible in plain language so that you can understand how we protect and process the information we collect about you.

2. Rights Protection: We will take sufficient and reasonable measures to protect your privacy rights.

3. Respect for Users: We respect the freedom of users to exercise their rights, including the right to choose, the right to know, and the right to manage their personal information.

4. Necessary Security: We will only collect necessary information and use it to provide you with secure and detailed services.

5. Timely and Careful Response: We will always listen to your inquiries and respond to your questions as quickly as possible.

2. How We Collect and Use Your Personal Information

You understand and agree:

1. We are committed to creating diverse products and services to meet your needs. Due to the variety of products and services we provide, different users may use different specific products/services, and therefore, the types and scope of personal information collected and used may vary accordingly. Please refer to the specific products/services for the types of personal information collected.

2. We may use the information collected through certain functions for our other services. For example, we may use the information collected when you use one function or service for another function or service, such as providing specific content, including security alerts based on the content you have read, and indirect profiling based on functional tags to provide more accurate services and content. If we use your personal information beyond the purposes stated at the time of collection or in a directly or reasonably related manner, we will notify you again and obtain your explicit consent before using your personal information.

3. To provide you with a better product and service experience, we continuously improve our technology and may launch new functions or optimize existing ones that may require the collection and use of new personal information or change the purposes or methods of using personal information. We will explain the purpose, scope, and use of the collected information through updates to this policy, pop-up windows, or page prompts, and provide you with a choice to consent. We will only collect and use information with your explicit consent. If you have any questions, comments, or suggestions during this process, you can contact us through the various contact methods we provide, and we will respond as soon as possible.

Special Note:

We provide user recommendation services, and the nickname, age, gender, avatar, and photos you provide in your personal information will be used for this purpose.

Business Function: Register as a User
When you register for ProxHub services, you need to complete account creation to access the account quickly. You must ensure the security of the account and not lend this ID to others.

Device ID and Unique Identifier: Used to ensure the secure operation, quality, and efficiency of the software and services.

Permissions：
To provide an exceptional user experience and functionality, ProxHub may request the following permissions:

• Camera Permission:
ProxHub requires camera access to allow users to take and share photos or make live video calls within the app. This permission is used only when users choose to take a photo or make a video call, providing necessary functionality support.

• Photo Library Permission:
ProxHub may request access to the user's photo library to facilitate sharing images during chats. This permission is only used when users actively choose to upload and send pictures from their device's photo library, ensuring ease of image sharing.

• Bluetooth Permission:
ProxHub may request Bluetooth permission when connecting audio devices to provide a higher-quality audio experience. This permission supports seamless connectivity with Bluetooth devices, ensuring smooth audio recording and calls.

• Audio Recording Permission:
ProxHub may need audio recording permission to support users in sending voice messages and making voice calls. This permission is enabled only when users choose to record voice or make voice calls, allowing for capturing and transmitting voice content.

• External Storage Read/Write Permission:
ProxHub may request read and write permissions for external storage, allowing users to save and manage app-related content (such as photos, videos, or other files). This permission is only used when users need to save or download content, ensuring data storage security and management.

• Advertising IDs Permission:
ProxHub may request Advertising ID access permission to enable personalized ad delivery and accurate ad performance attribution. This permission allows the app to retrieve the device’s unique, anonymous Advertising ID, which is strictly used for optimizing ad relevance and measuring the effectiveness of ad campaigns (e.g., click-through rates, install conversions).

• Read Phone State Permission:
ProxHub may request permission to read phone status to ensure that users are not interrupted during calls or other important activities. This permission is used to detect call status or other system states, preventing disruption to the in-app experience.

• Read Privileged Phone State Permission:
ProxHub may need permission to read privileged phone status to obtain more accurate information about the device. This helps optimize app performance and user experience.

• Location Information Permission:
ProxHub may request location information permission to provide personalized location-based services and content recommendations. This permission is only used when users choose to enable it to enhance their experience.

• Phone State Permission:

ProxHub may request the Phone State permission to detect the device’s call status in real time. This permission is solely used to pause in-app features (e.g., live streaming, audio playback) automatically when a phone call is incoming or ongoing, preventing any disruption to the user’s communication and app experience. We do not collect or store any sensitive information such as phone numbers or call records via this permission.

These permissions are only used after the user's explicit authorization and can be managed and adjusted at any time in the device settings. We will collect your mobile phone number, but we promise that the user's phone number data will not be transmitted. Your privacy is very important to us, and all personal information will be strictly confidential and will never be used for any unauthorized purpose.

Device Information:
ProxHub may automatically collect various details about your device, such as device ID, brand, model, operating system, version, system settings, and phone status (e.g., current activity status, signal strength, and call status). We may also collect identifiers related to your device and app, browser type and version, hardware details, and information from your internet service provider or mobile carrier, including your IP address (or proxy server). While using our app, we may also obtain information related to your device's network type and platform, its unique identifier, and data about how you interact with different features within the app.

Data Collection for Analysis:
We collect logs and usage data to better understand how our services perform and are used. Whenever you interact with our services, our servers automatically collect this diagnostic information. The data may include your IP address, device specifications, browser type, configuration settings, and detailed records of your activities on our platform, such as access dates and times, pages and files viewed, searches conducted, and features used. We may also collect device event data, including system activities, error logs (also known as “crash reports”), hardware settings, and more.

3. How We Share, Transfer, and Disclose Your Personal Information

We do not share your personal information with companies, organizations, or individuals outside of ProxHub service providers, except in the following circumstances:

1. With Your Explicit Consent: We will only share your personal information with third parties after obtaining your explicit consent.

2. When Required by Law: We may share your personal information when necessary to comply with applicable laws and regulations, resolve disputes, or respond to requests from administrative and judicial authorities.

3. With Authorized Partners: We may engage authorized partners to provide specific services or perform certain functions on our behalf. In such cases, we will only share your personal information for legitimate, necessary, specific, and clearly defined purposes. Our authorized partners will only access the information necessary for their tasks and are prohibited from using it for any other purposes.

We may share your information with suppliers, service providers, and other partners that assist us in operating our business. These entities include those providing technical infrastructure, analyzing service usage, measuring the effectiveness of advertising and services, providing customer support, facilitating payments, or conducting research and surveys.

To ensure the protection of your personal information, we enter into strict data protection agreements with these companies, organizations, and individuals, requiring them to process your data in accordance with our instructions, this privacy policy, and other relevant confidentiality and security standards.

For marketing analysis and attribution purposes, we use Appsflyer. Data related to app usage, user behavior, and the effectiveness of our marketing campaigns will be shared with Appsflyer to help us optimize our marketing strategies.

If you disagree with all the terms of this privacy policy, please do not use our services. ProxHub is committed to creating a secure community for all users, and sharing certain information is necessary to achieve this goal.

4. How We Protect Your Personal Information

To ensure the security of your information, we strictly comply with the technical measures and operational procedures required by laws, regulations, and other normative documents to protect the confidentiality of your information. Additionally:

1. We strive to provide security for users' personal information to prevent unauthorized use, access, disclosure, leakage, damage, or loss. We use various security measures within a reasonable security level to ensure the safety of information, including anonymization of personal information, establishing a trusted protection mechanism to prevent malicious attacks on personal information, building an access control mechanism, and adhering to the principle of least privilege to ensure that only authorized personnel can access personal information. We conduct security and personal information protection training courses to enhance personnel awareness of personal information protection.

2. We will take reasonable and feasible measures to avoid collecting irrelevant personal information.

If you discover that your personal information, especially your account information, has been compromised, please contact ProxHub customer service immediately so we can take appropriate measures in response to your request.

Please note that information you voluntarily share, even publicly, while using our services may involve your or others' personal information, including sensitive personal information. Please carefully consider whether to share or publicly disclose relevant information while using our services.

We will also report the handling of personal information security incidents to regulatory authorities as required.

5. How to Manage Your Personal Information

Accessing Personal Information
You have the right to access your personal information, except in cases where laws and regulations provide otherwise. You can access your personal information in the following ways:

• Account Information: If you wish to access or edit your personal information in your account, you can log into your account via [My - Settings].

• If you cannot access personal information through the above methods, you can always contact us via ProxHub customer service. We will respond to your access request within 15 days.

• For other personal information generated during your use of our products or services, we will provide it according to the relevant arrangements.

• You may request a copy of your personal information from ProxHub customer service.

Deleting Personal Information
You may delete some of your personal information through the methods listed in the “Accessing Personal Information” section.

You may request to delete personal information under the following circumstances:

1. If our handling of personal information violates laws and regulations;

2. If we collect and use your personal information without your explicit consent;

3. If our handling of personal information seriously violates our agreement with you;

4. If you no longer use our products or services or voluntarily cancel your account;

5. If we permanently no longer provide products or services to you.

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us to delete it promptly unless otherwise stipulated by laws and regulations or these entities have obtained your independent authorization.

After you or we assist you in deleting information from our services, we may not immediately delete the corresponding information from the backup system according to applicable laws and regulations, but we will securely store your personal information and isolate it from any further processing until the backup can be cleared or anonymized.

6.How long do we retain your content

Please understand that the content you provide may be saved by users using any technology, such as screenshots, in-app features, or other image capture technology. As with any digital information, it may be possible to access this content through forensic means or temporary storage on a device. If our application deletes user information, we cannot guarantee complete deletion within a specific period of time. In addition, we may retain certain information for a limited period of time as required by law or in backups.

Controlling your information

We want you to be in control of your information, so we provide the following tools for your use:

• Access and Update:

We are committed to providing you with access and control over your personal information. However, we may deny your request for a variety of reasons, such as if the request may jeopardize the privacy of other users or is illegal. You can directly access and update your account information by visiting the settings page of the application. To access, update, or delete other personal information we hold, you can make a request here. You can also delete our services or request account deletion through your mobile device.

• Deletion:

In some cases, you can delete or change your account ID, but please do so with caution, as doing so may result in the loss of your account information or ID.

ProxHub will no longer process your personal information unless we have compelling legitimate grounds to continue processing it which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

7.Legal Basis for Data Processing and User Rights in Privacy Policy

1. Legal Basis for Data Processing

We process your personal data in accordance with applicable privacy laws. The legal bases for processing personal data include but are not limited to the following:

• Consent: In certain circumstances, we will seek your consent to collect and use your personal data.

• Contract Performance: When we need to process your personal data to fulfill a contract signed with you, it will be based on this legal basis.

• Legitimate Interests: We may process your personal data based on our legitimate interests to ensure the security of our application and enhance the user experience.

• Legal Obligations: In cases required by applicable laws or regulations, we may need to process your personal data.

• Public Interest: In cases involving significant public interest, we may also process your personal data.

2. Your Rights

According to applicable privacy laws, you have the following rights:

• Right to Access: You have the right to access the personal data we hold about you.

• Right to Rectification: If your personal data is inaccurate or incomplete, you have the right to request that we correct this data.

• Right to Deletion: In certain circumstances, you have the right to request that we delete your personal data.

• Right to Restrict Processing: You can request that we restrict the processing of your personal data in specific situations.

• Right to Data Portability: You have the right to request that we transfer your personal data to you or a designated third party.

• Right to Object: In certain circumstances, you have the right to object to our processing of your personal data.

• Right to Withdraw Consent: If we process data based on your consent, you have the right to withdraw that consent at any time.

• Right to Lodge a Complaint: If you believe we have not processed your data in accordance with privacy laws, you have the right to lodge a complaint with your local data protection supervisory authority.

3. Applicable International Privacy Laws

To fully protect the personal information rights and interests of users in different global jurisdictions, we strictly comply with the international and regional privacy laws applicable to the user's location. Below is a breakdown of the core requirements of each regulation and their specific impacts on users:

(1) EU General Data Protection Regulation (GDPR)

Core Requirements & User Rights:

• Legal Bases for Data Collection: We will only collect/process your personal information based on the following legitimate grounds:① Obtaining your explicit consent (e.g., when you actively check "I agree to the Privacy Policy");② Fulfilling contractual obligations with you (e.g., collecting account information to provide membership services);③ Complying with legal obligations (e.g., retaining transaction records in accordance with tax regulations);④ Protecting the vital interests of you or others (e.g., identifying malicious accounts to safeguard your account security).

• Core User Rights:① Right of Access: You may request a copy of the personal information we hold about you;② Right to Rectification: If your personal information is incorrect or incomplete, you may request us to correct it;③ Right to Erasure ("Right to be Forgotten"): Under specific conditions (e.g., you withdraw consent, the data is no longer necessary), you may request us to delete your personal information;④ Right to Restrict Processing: If you dispute the accuracy of the data or the processing is unlawful, you may request us to suspend processing your personal information;⑤ Right to Data Portability: You may request us to provide your personal information in a structured, machine-readable format, or transfer it directly to another service provider;⑥ Right to Object: You may object to data analysis based on "legitimate interests" (e.g., targeted advertising), and we will cease such processing unless there are overriding legitimate grounds.

• Data Security & Breach Notification: We will adopt technical measures such as encryption and access control to protect data security; in the event of a major data breach that may affect your rights, we will notify the EU supervisory authority (e.g., the Irish Data Protection Commission) within 72 hours, and notify you directly as appropriate.

(2) California Consumer Privacy Act (CCPA, including CPRA amendments)

Core Requirements & User Rights:

• Transparency of Data Collection: We will clearly inform you of the types of personal information collected (e.g., name, contact details, device information), the purposes of collection (e.g., providing services, optimizing experience), and the recipients of shared/"sold" data (note: "sale" under CCPA includes exchanging data with third parties for commercial benefits).

• Core User Rights:① Right to Know: You may request free details of the collection, use, sharing/sale of your personal information in the past 12 months;② Right to Delete: You may request us to delete the personal information we hold about you (exceptions include retaining data to fulfill contracts, comply with laws, or ensure security);③ Right to Opt-Out: You may refuse our "sale" of your personal information (including data sharing for targeted advertising), and we will confirm and implement your choice within 15 days;④ Right to Non-Discrimination: When you exercise your privacy rights, we will not reduce service quality, increase prices, or refuse to provide services to you.

• Data Security Obligations: We must take reasonable security measures to protect the personal information of California users and prevent unauthorized access or breaches.

(3) Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)

Core Requirements & User Rights:

• Notification of Collection Purposes: Before collecting your personal information, we will clearly inform you of the specific purpose (e.g., "for account registration"), and will only use the data within that purpose.

• Core User Rights:① Right of Access: You may request to view the personal information we hold about you and understand how it is used;② Right to Rectification: If your personal information is inaccurate or incomplete, you may request us to correct it;③ Right to Consent: We will only collect, use, or disclose your personal information with your consent (exceptions include legal requirements, protection of vital interests, etc.).

• Cross-Border Data Transfers: If we transfer your personal information outside Canada, we must ensure the recipient adopts privacy protection measures equivalent to PIPEDA to safeguard data security.

(4) Brazil’s General Data Protection Law (LGPD)

Core Requirements & User Rights:

• Legitimacy of Data Processing: We will only process your personal information based on the following grounds: obtaining your consent, fulfilling a contract, complying with laws, protecting public interests, protecting the vital interests of you or others, or based on our legitimate interests (provided they do not harm your rights).

• Core User Rights:① Right of Access and Confirmation: You may request confirmation of whether we are processing your personal information, and obtain details of the processing;② Right to Rectification: You may request correction of inaccurate or incomplete personal information;③ Right to Erasure ("Right to be Forgotten"): Under specific conditions, you may request deletion of your personal information;④ Right to Data Portability: You may request your personal information in a structured format;⑤ Right to Object: You may object to the processing of personal information based on legitimate interests or public interests.

• Data Breach Notification: In the event of a data breach that may harm your rights, we must notify Brazil’s National Data Protection Authority (ANPD) and affected you within a reasonable period after discovery.

(5) Other Relevant National/Regional Privacy Laws

For users outside the above regions, we will comply with the valid privacy protection laws in their locations, such as:

• UK Data Protection Act (DPA 2018): Equivalent to GDPR, applicable to UK users, with core requirements and user rights consistent with GDPR;

• Australia’s Privacy Act 1988: Applicable to Australian users, requiring compliance with 13 Privacy Principles (e.g., transparent collection, security protection, user access rights);

• Japan’s Act on the Protection of Personal Information (APPI): Applicable to Japanese users, requiring notification of purposes before collecting personal information, obtaining user consent, and adopting security measures to protect data.

8. Your Privacy Rights in California under CCPA

Under the California Consumer Privacy Act (CCPA), California residents have specific privacy rights. Here are detailed descriptions of these rights:

1. Right to Know:

You have the right to know whether your personal data has been shared.You have the right to know the specific information about your personal data that we have collected, used, shared, or sold over the past 12 months. You can request this information up to twice every 12 months, including:

￮ Categories and specific personal information we have collected about you.

￮ Categories of sources from which your personal information was collected (e.g., directly from you, your device, or third parties).

￮ The business or commercial purposes for which your personal information was collected (e.g., improving our services, conducting marketing activities, or preventing fraud).

￮ Categories of personal information disclosed for business purposes.

￮ Categories of personal information sold to third parties, if applicable.

￮ Categories of third parties to whom we have shared or sold your personal information (e.g., advertising networks, data analytics providers).

2. Right to Deletion:
You have the right to request the deletion of any personal information we have collected from you. Once we receive and verify your valid request, we will delete (and instruct our service providers and partners to delete) the information unless we need to retain it to fulfill legal obligations, complete transactions, prevent fraud, or other exceptions.

3. Right to Opt Out of the Sale of Personal Information:
Under California law, you have the right to opt out of the sale of your personal information. You can exercise this right by visiting our "Privacy Settings" page and submitting a request. Once we receive your opt-out request, we will no longer sell your personal information but may still need to share necessary information with service providers to ensure the functionality and security of the service.

4. Right to Opt Out of Sharing Personal Information:
You have the right to opt out of sharing your personal information for targeted advertising purposes. You can exercise this right by visiting our "Ad Preferences" page or directly contacting us.

5. Right to Non-Discrimination:
When exercising your rights under CCPA, you have the right not to be discriminated against. We will not charge you higher prices, provide lower-quality services, or limit the range and functionality of services simply because you exercise your privacy rights. However, if you choose to delete certain necessary information, it may affect the provision of certain services.

6. Right to Know Whether Your Data Is Sold:
You have the right to know whether your personal data has been sold to third parties. If we sell your personal data, we will notify you and provide opt-out options. You can request to know whether your data has been sold at any time and exercise your opt-out rights.

7. Right to Lodge a Complaint with a Regulatory Authority:
If you have any questions or concerns about how we handle your personal information or believe we have violated privacy laws, you have the right to file a complaint with your local data protection supervisory authority. We encourage you to contact us before filing a complaint so that we can address your concerns, but this does not affect your right to file a complaint.

How to Exercise Your Opt-Out Rights

Under the European Union Data Protection Law (GDPR) and the Virginia Consumer Data Protection Act (VCDPA), ProxHub is committed to protecting user privacy and ensuring that users understand how their data is used. To comply with applicable data protection laws, ProxHub offers options to opt out of the following data processing activities:

1. Opt-Out of Personalized Advertising: You can choose not to receive personalized advertising based on your behavior or interests. This way, we will no longer use your personal data to provide targeted advertising.

2. Opt-Out of Data Sharing: You have the right to choose not to share your personal data with third parties, especially when the data is used for analysis, marketing, or other purposes.

3. Withdraw Consent for Data Processing: If you have previously consented to certain data processing activities, you can withdraw that consent at any time.

4. Opt-Out of Data Analysis: You can choose not to participate in data analysis activities, including those used to improve services and personalize the user experience.

You can exercise these opt-out rights by emailing our privacy team. Please specify the data processing activities you wish to opt out of and the relevant specific request in your email. Our team will process your request within a reasonable time and provide a confirmation response.

You have the right to opt out of the "sale" of your personal data, and we will not discriminate against you for exercising this right (e.g., by charging different prices or providing different quality services).

Pursuant to applicable privacy laws (including the California Consumer Privacy Act), you may opt out of the sharing or sale of your personal data by sending your written request to the following email address: mengchunshu8@gmail.com.

LGPD Compliance Statement (Applicable to Brazil)

We value your privacy and are committed to protecting your personal data under the Brazilian General Data Protection Law (LGPD). As a resident of Brazil, you have the right to know how we collect, use, store, and share your information while using our services. We will transparently explain our data processing activities and ensure your data is properly protected throughout the process.

Under LGPD, you have the following rights:

• Right to Access: To know the personal data we hold about you and its processing purposes.

• Right to Rectification: To request corrections of inaccurate, incomplete, or outdated personal data.

• Right to Deletion: To request the deletion of your personal data where legally permitted.

• Right to Be Informed: To know about data processing entities, data-sharing parties, and their purposes.

• Right to Withdraw Consent: To withdraw your consent to data processing at any time.

• Right to Object: To object to processing your personal data based on legal interests.

• Right to Data Portability: To request the transfer of your personal data to you or a third party.

• Right to Lodge a Complaint: To file a complaint with the National Data Protection Authority (ANPD).

We strive to ensure your privacy rights are respected and comply with applicable LGPD legal requirements.

9. How We Handle Minors' Personal Information

Children's Privacy Policy: This service is not intended for children or individuals under the age of 18. As part of our service, we do not knowingly collect personally identifiable information from children or individuals under the age of 18. However, we do collect age-related information to ensure that underage users are not part of our platform, maintain the security of our services, and use third parties to help maintain the correct age profile of the application. If we become aware that we have inadvertently received or collected personally identifiable information from a user under the age of 18 as part of our service, we will delete this information from our records. If you are under 18, please do not use this service.

If you find that we have collected personal information of minors under your guardianship, please contact us immediately, and we will delete the relevant information as soon as possible after verification.

10. How This Privacy Policy is Updated

Our privacy policy may change from time to time.

We will not reduce your rights under this privacy policy without your explicit consent. For significant changes, we will provide major notifications (including announcements on ProxHub or even pop-up prompts). You can also review this privacy policy regularly to obtain the latest terms.

The main changes to this policy include but are not limited to:

1. Significant changes in our service model, such as changes in the purposes for processing personal information, the types of personal information processed, and how personal information is used;

2. Significant changes in our control, such as changes in ownership due to mergers and acquisitions;

3. Changes in the main recipients of personal information shared, transferred, or publicly disclosed;

4. Significant changes in your rights to participate in the processing of personal information and how these rights are exercised;

5. Changes in the department responsible for handling personal information security, contact information, and complaint channels;

6. High-risk alerts in personal information security impact assessment reports.

If you continue to use our services after receiving the notice, it means you agree to be bound by the revised policy. If you refuse to accept the updated policy, you can only browse in guest mode.

We will also archive older versions of this policy for your review. You can contact us using the above contact information to request a review of them.

11.Controller Information

The controller of this service is MLBCAR. We are responsible for the collection, use, storage and disclosure of the personal information you provide when you use our service. Please contact us at mengchunshu8@gmail.com.

12.Data Protection Officer (DPO)

If you have any questions, requests, or complaints about processing your personal data or want more information about your privacy rights, please contact our Data Protection Officer (DPO): MLBCAR, at mengchunshu8@gmail.com.

13.How to Contact Us

You can contact us in the following ways, and we will respond to your request within 15 days:

If you have any questions, comments, or suggestions about the content of this policy, you can contact our official customer service in the ProxHub application or send an email to our service mailbox at mengchunshu8@gmail.com.

Address:

17111 Road 25

Dolores - 81323

United States (US)