1. Who we are and what this covers

CLProxies ("we", "us", "our") supplies dedicated Australian 4G mobile proxy connectivity through dashboard.clproxies.com. This policy explains what personal information we collect when you use the dashboard and the proxies, why we collect it, who we share it with, how long we keep it, and how you can access or correct it. We handle personal information under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). It should be read together with our Terms of Service.

2. What we collect

Account details.

• Your username and email address.
• If you sign in with Discord: your Discord user ID, username and avatar, and the email address Discord provides for your account. We do not receive your Discord password. We do not add you to any Discord server without your action.
• If you set one, a Discord webhook URL for notifications.

Payment details.

• Card payments are processed by Stripe. We receive Stripe's customer, payment and subscription identifiers, the amount, the payment status, and the billing country and postcode Stripe uses to work out GST. We never see or store your full card number.
• Bank transfer orders: the order reference we issue, the amount, and, when your payment lands, the sender name and reference as they appear on our bank statement.
• Refunds, disputes and the correspondence about them.

Records of your use of the dashboard.

• Logins and other account access: the time, your IP address and your browser type.
• Your acceptance of the Terms of Service: the time, the version accepted and your IP address.
• When you view your proxy credentials, request an IP rotation or an IP check, place or cancel an order, or ask to cancel a plan.
• When one of our staff accesses your account to help you: the time and their IP address, so their activity is never mistaken for yours.

Records of your use of the proxies.

• Raw connection logs from the proxy server: for each connection, your proxy username, the time, the bytes sent and received, the IP address the connection came from, and the hostname and port it went to.
• Daily summaries per proxy: bytes transferred, number of connections, and the client IP addresses that connected. The daily summaries do not include destination hostnames.
• Results of our own automated health checks through your proxy. These are excluded from your usage figures.

We do not collect the content of the traffic that passes through your proxy beyond the connection metadata listed above.

3. Why we collect it

• To provide the service: creating your account, allocating a SIM, routing your traffic, showing you your usage, and sending you notifications you have asked for.
• To bill accurately: metering data use against your plan, processing payments, matching bank transfers to orders, issuing receipts and refunds.
• To keep the service secure and fair: detecting abuse, duplicate IP addresses, and misuse of credentials, and enforcing the acceptable use rules in the Terms.
• To answer questions about a charge: responding to card disputes and refund requests with records of what was bought, when it was used and from where.
• To support you when you contact us.
• To meet legal obligations, including tax record-keeping.

We do not use your information for advertising, we do not build marketing profiles, and we do not sell personal information to anyone.

4. Who we share it with

• Stripe (payment processing, GST calculation, receipts). Stripe stores payment data on its own systems, some of which are outside Australia, including the United States.
• Discord (sign-in and direct-message notifications), located in the United States.
• Our hosting provider, whose servers for this service are located in Melbourne, Australia.
• Our bank, when you pay by bank transfer or we refund you to a bank account.
• Card issuers and card networks, through Stripe, when a charge is disputed. In that case we may provide the records described in section 2 that relate to the disputed charge, such as your account details, acceptance of the Terms, access records and daily usage summaries. We do not provide destination hostnames in dispute responses.
• Regulators, courts and law enforcement where the law requires or permits it.

We do not otherwise disclose personal information to third parties. Where we disclose information to a recipient outside Australia, we do so only to the providers named above for the purposes described, and those providers are bound by their own privacy commitments.

5. How long we keep it

• Raw connection logs: about 40 days, then deleted.
• Daily usage summaries and account access records: up to 18 months, then deleted.
• Payment, refund and dispute records: 5 years, as required for tax and financial record-keeping.
• Account details: while your account is open and for up to 18 months after your last active plan, unless you ask us to delete them sooner (see section 8) or we must keep them for the reasons above.

6. How we protect it

• The dashboard is served over HTTPS. Proxy credentials are unique to each plan and can be regenerated.
• Access to our systems is limited to staff who need it. Staff access to a customer account is logged.
• Payment card details are held by Stripe, not by us.
• Backups and logs live on servers in Australia.

If a data breach is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner as the Notifiable Data Breaches scheme requires.

7. Cookies and local storage

The dashboard stores your sign-in token and basic preferences in your browser's local storage so you stay signed in. We do not use advertising or tracking cookies. Stripe's checkout page sets its own cookies under Stripe's privacy policy.

8. Access, correction and deletion

• You can see and update your email address in the dashboard.
• You can ask us for a copy of the personal information we hold about you, or ask us to correct it, by emailing the address in section 10. We will respond within 30 days.
• You can ask us to delete your account. We will delete or de-identify your information except for the records we must keep under section 5, and we will tell you what we have kept and why.

9. Complaints

If you think we have mishandled your personal information, email us first and we will investigate and reply within 30 days. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au.

10. Contact

11. Changes to this policy

We may update this policy. The version date at the top changes when we do, and material changes are announced in the dashboard. Continued use after a change means the new policy applies to information collected from then on.