Privacy Policy

This Privacy Policy explains how TIPTOP GAME LIMITED and its affiliated companies (referred to as "TIPTOP", "we", "our", or "us") collect, use, and share information when you use our websites, services, and applications (collectively referred to as "Services"). This Privacy Policy (referred to as "Privacy Policy") does not apply to information that you may process when using our Services.

1. User Control Options: Personal Information

Our VPN APP is a non-compulsory log network. We are unable to obtain information related to users' personal information, including but not limited to names (subscriber name, username, and screen name), addresses (including mailing address, residential address, business address), and phone numbers unless the data you provide depends on the context of your interactions with us and the choices you make, including your privacy settings, and the products and features you use to manage your subscription and enjoy our VPN services. Except for limited exceptions, we will not automatically collect any personal information from you.

When you open the APP seeking our VPN service, the APP will assign a unique identifier for your service (this unique identifier is only bound to your device identification code but is not associated with any other personal information of the user). When you use the VPN service, we will check your account information through this unique identifier to determine the service level you registered before establishing the VPN connection.

Under certain payment forms, some Mac versions of our VPN service may redirect you to the website of a third-party payment processor (i.e., PayPal) to complete the transaction. To understand the personal information collected and stored by the processor, please refer to the terms and privacy policy of the respective processor. Therefore, except for the above-mentioned limited exceptions, we do not know any way or source that users pay for the VPN service in detail (including any credit card or bank account number) or any billing records.

If you contact us directly, we may receive additional information about you, such as your name, email address, phone number, the content of messages and/or attachments you may send to us, and any other information you may choose to provide. We may also receive confirmations when you open our emails.

We use your email address (if any, depending on your choice) to:

We only use your personal information for the purposes listed in this Privacy Policy, and we will not sell your personal information to third parties without your prior consent.

2. Service Information Related to Your VPN Use

In accordance with applicable laws and to avoid infringing any Internet Service Providers, any browsing information, traffic destination, data content, IP addresses, DNS queries, or other similar information related to your online activities transmitted to our servers will be encrypted and cleared after the VPN "session" is closed. That is, we will not collect any information about the websites you visit or any information stored or transmitted on your device, including any data that applications on your device may transmit through the VPN network. More specifically, we do not have the following files/information in the limited connection with your personal information and the non-collection of any data about the websites you visit or any data stored or transmitted on your device:

If anyone wants to access or tries to force us to release user information based on any of the above points, we cannot provide this information because this data does not exist.

To fulfill our contractual obligations in good faith and let you enjoy excellent VPN services, we collect the following information related to your VPN use:

Information related to applications and application versions

We collect information about which applications and application versions you have activated. This allows our support team to effectively identify and eliminate your technical problems.

Information related to connections

We collect information about whether the VPN connection was successful on a specific date (but not a specific time of the day), to which VPN location (but not the outbound IP address assigned to you), and from which country/ISP (but not your source IP address). This minimal information allows us to provide you with effective technical support, such as identifying connection problems, providing country-specific suggestions on how to use our VPN services, and enabling our engineers to identify and fix network problems.

Size of data transfer (in MB) (but does not include any websites you visited or any data transmitted from your device)

We collect information about the total sum of data transferred by a given user. One of our service principles is to provide unlimited data transfer, however, if we notice that the traffic occupied by a user is more than that of thousands of other users combined, affecting other users' enjoyment of high-quality services, we may seek reasons from the user.

Anonymous data for network diagnostics, learning, and analysis

When you become one of our VPN service users, with your permission, we collect minimal usage statistics data and anonymous analysis data for network diagnostics in our network operation tools, in order to optimize network speed and let us identify problems related to specific applications, VPN servers, or ISPs. Learning and analyzing these statistical data enable us to improve the quality of our services and products. We ensure that the information we receive is completely anonymous and cannot be traced back to individual users (i.e., we do not store which user sent what data, and we do not store IP addresses).

We will collect the following information:

Conclusion

We collect minimal usage statistics data to maintain the quality of our services. Although we provide users with services to improve network speed, we cannot uniquely identify any specific behavior of any user, because thousands of users share the same location to enjoy surfing the Internet at the same time, and the usage patterns overlap with thousands of other customers connecting to the same location on the same day.

Regarding sensitive data, we have designed our systems to explicitly eliminate the storage of sensitive data. We never know how they utilize our services.

We adhere to our firm commitment to our customers' privacy and do not possess any data related to users' online activities.

3. Use and Sharing of Information

How We Use Information

We use the information we collect in various ways, including to:

How We Share Information

We may share the information we collect in various ways, including the following:

Vendors and Service Providers

We may share information with third-party vendors and service providers that provide services on our behalf, such as helping to provide our Services, for promotional and/or marketing purposes, and to provide you with information relevant to you such as product announcements, software updates, special offers, or other information.

Aggregate Information

Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified forms that can’t reasonably be used to identify you.

Information Shared through Referrals

If you register for our Services through a referral from a friend, we may share information with your referrer to let them know that you used their referral to sign up for our Services.

Analytics

We collect minimal usage statistics data and anonymous analysis data for network diagnostics in our network operation tools. Please see Section 2 of this Privacy Policy for more information.

Business Transfers

Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

As Required By Law and Similar Disclosures

We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property, or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

With Your Consent

We may share information with your consent.

4. Advertising

Our VIP subscription service does not offer any advertising. In addition, we are proud to provide customers with a free, ad-supported VPN service. We cooperate with third-party advertising partners to display advertisements to customers who choose free VPN services.

We ensure that we do not target any personal information based on these advertisements. Even if you choose to use a free, ad-supported VPN service, we will not share your any personal information or any usage information with advertisers without your prior consent.

Despite the above provisions, these advertising partners may set up and access their own cookies, pixel tags, and similar technologies on our services, and they may collect or access information about you, and they may collect this information over time across different online services.

To learn more about these programs, please visit:

5. Jurisdiction and Applicable Law

Keeping your information private is our core mission. To achieve this mission, TIPTOP is registered and operates in Singapore, where comprehensive data protection legislation is in place.

Singapore does not have any specific data retention laws, nor any guidelines on electronic discovery or disclosure to foreign law enforcement agencies. The disclosure of personal data may follow this Privacy Policy.

We will only surrender protected user information upon receiving a valid subpoena, court order, or search warrant, which should be effectively served according to the rules of the Singapore courts. More specifically, we believe that subpoenas, court orders, or search warrants may lose their compulsory force when crossing their borders. They can only regain compulsory force on the other side of the border under the authority of a domestication action (in courts of other states) or under the authority of a certain statute. In addition, we will notify the affected users about any requests for their account information unless the law or court order prohibits us from doing so. If we receive a valid legal order, it is important to note that we do not collect any IP addresses, browsing history, traffic data, or DNS queries, which can be used to identify any specific user.

6. DATA RETENTION

We store personal data collected from you as long as it is necessary for our ongoing legitimate business needs (such as to render services you requested or to comply with legal, tax, or accounting requirements).

When there's no longer a legitimate business requirement to process your personal data, we will either erase or anonymize it. If this isn't feasible (for instance, your personal data is stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible.

We maintain records of any correspondence, inquiries, complaints, or compliments you send to us, along with our response. Depending on how you contact us, we may collect your email address and any additional information you provide to us. Keeping full correspondence records helps us provide the best possible customer support experience.

Our support correspondence is conducted through email: tiptopgame@163.com. When you correspond with us using this email, your correspondence records, including your name and email address, are stored in their systems.

7. SECURITY MEASURES

We are dedicated to safeguarding your information. We employ top-tier physical, procedural, and technical security measures in our offices and data storage facilities to prevent any loss, misuse, unauthorized access, disclosure, or modification of information. Access to user information is limited to staff who require such access to perform their job duties.

While we believe our systems are robust, it's important to understand that no data security measures in the world can offer 100% protection.

Our servers are located in data centers with strong security practices. None of these data centers require us to collect or store any traffic data or personal information related to your use of VPN services. If any data center were to ask us to log such data, we would immediately cease operations with that data center and find alternative options.

Even if a government were to physically seize one of our VPN servers and manage to break its disk encryption, there would be no logs or information that would tie any individual user to a particular event, website, or behavior.

8.THIRD-PARTY SERVICES

You may access other third-party services through the VPN services, for example by clicking on links to those third-party services from within the Services. We are not responsible for the privacy policies and/or practices of these third-party services, and we encourage you to carefully review their privacy policies.

9.CHILDREN'S PRIVACY

We feel a particular obligation to protect information obtained from young children. We strongly urge parents to instruct their children never to disclose their real name, their address, or their telephone number while they are online without prior permission. We do not knowingly collect information from children under the age of 16, and children under 16 years old are prohibited from using our services. If you learn that a child has provided us with personal information in violation of this Privacy Policy, you can alert us at tiptopgame@163.com.

10.ACCESS

When you become one of our VPN service users, you may access certain information associated with you by emailing tiptopgame@163.com. If you decide to stop using our VPN services, any public activity on your Account prior to deletion may remain stored on our servers and may remain accessible to the public.

To protect your privacy and security, we may also take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. Your ability to access and correct your information may be temporarily limited where access and correction could: inhibit our ability to comply with a legal obligation; inhibit our ability to investigate, make or defend legal claims; result in disclosure of personal information about a third party; or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to us or a third party.

11.GDPR

We are committed to user privacy globally, and our existing practices include keeping personal information under users' control and minimal data collection. In accordance with the General Data Protection Regulation (GDPR) of the European Union (EU), we collect and process the data of users in the EU in the specific manner outlined in this Privacy Policy based on one of the following bases, depending on the circumstances:

  1. To fulfill our contractual obligations to users, which includes:
    • Providing users with the VPN services and Apps they requested.
    • Managing user subscriptions and processing payments.
    • Providing customer support.
  2. For a legitimate interest associated with running our business, which includes:
    • Enhancing the quality, reliability, and effectiveness of our VPN Services, and Apps.
    • Communicating with customers to provide information and seek feedback related to our VPN services and Apps.

You can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Also, you have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.

You can exercise your rights under the GDPR to access, transfer, correct, delete, or object to the processing of your personal information by contacting us at tiptopgame@163.com.

12.INTERNATIONAL DATA TRANSFERS

We are a global business. We may transfer personal information to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy.

13.CHANGES TO THIS PRIVACY POLICY

To comply with applicable privacy laws and principles, this Privacy Policy may be modified from time to time without prior notice to you, so please review it frequently. Your continued use of our VPN services constitutes your acceptance of our Privacy Policy. Changes to this Privacy Policy will be posted on our websites. If we materially change the ways in which we use or share personal information previously collected from you through our VPN services, we will notify you through our APP, email, or other communication.

14.Contacts

If you have any questions or concerns about this Privacy Policy, please feel free to contact us at tiptopgame@163.com.