Privacy Policy

www.flameproxies.com
Effective: October 3, 2026

1. Introduction & Scope of Policy

This Privacy Policy describes how EA Flame Technologies LTD ("Company," "we," "us," or "our") collects, uses, processes, and protects personal data in connection with your access to and use of the website located at https://www.flameproxies.com (the "Site") and any related applications, dashboards, APIs, proxy services, or other services (collectively, the "Services").

This Privacy Policy applies to all individuals who access or use the Services, including visitors, registered users, and customers (collectively, "Users," "you," or "your").

This Privacy Policy forms part of, and should be read together with, our Terms of Service. In the event of any conflict between this Privacy Policy and the Terms of Service, the Terms of Service shall govern with respect to your use of the Services.

The Services are designed for use by businesses and individuals worldwide. As a result, your personal data may be processed in accordance with the laws of multiple jurisdictions.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller & Contact Information

EA Flame Technologies LTD is the entity responsible for the collection and processing of personal data in connection with the Services.

EA Flame Technologies LTD is a private limited company incorporated and registered under the laws of the Republic of Cyprus, with a registered office at:

Mesaorias 1
Lakatamia
2322, Nicosia, Cyprus

For the purposes of applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the Cypriot Processing of Personal Data (Protection of the Individual) Law (Law 125(I)/2018), the Company acts as a data controller with respect to personal data processed for its own business purposes, including account management, billing, security, and compliance.

In certain circumstances, the Company may act as a data processor on behalf of Users, including where it processes data solely on behalf of and under the instructions of a User. The Company's role will depend on the context of the processing.

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, you may contact us at:

Email: [email protected]
Website: https://www.flameproxies.com

3. Categories of Personal Data We Collect

We collect personal data that is necessary to provide, operate, and improve the Services. The categories of personal data we collect may include:

3.1 Account Information

When you create an account, we collect information such as:

  • Email address
  • Username or display name
  • Account credentials and authentication data
  • Account preferences and settings

Authentication services may be provided through third-party providers.

3.2 Payment and Transaction Information

When you make payments or Top-Ups, we process transaction-related data, including:

  • Transaction identifiers
  • Payment amounts
  • Payment method type
  • Partial payment details (such as card type, last four digits, and expiry date)

Payment processing is performed by third-party payment providers. We do not store full payment card numbers or security codes.

3.3 Technical and Device Information

When you access or use the Services, we may automatically collect certain technical information, including:

  • IP address (processed for security and fraud prevention purposes and not retained in identifiable form beyond what is necessary)
  • Browser type and version
  • Operating system
  • Device characteristics
  • Screen resolution and display settings
  • Time zone and language preferences

This information is used to operate, secure, and improve the Services.

3.4 Usage Information

We collect information about how you interact with the Services, including:

  • Pages visited
  • Features used
  • Service configuration and usage data
  • Interaction with dashboards, APIs, or tools

3.5 Communication Information

If you contact us or interact with our support services, we may collect:

  • Your contact details
  • The content of your communications
  • Support history and related information

3.6 Security and Fraud Prevention Data

We may collect and process data necessary to detect, prevent, and investigate fraud, abuse, or security incidents, including:

  • Transaction risk signals
  • Device and session identifiers
  • Technical indicators associated with suspicious activity

3.7 Sensitive Data

We do not intentionally collect sensitive personal data (such as data relating to health, biometric identifiers, or other special categories of data as defined in Article 9 of the GDPR) unless required for legal or compliance purposes and with appropriate safeguards in place.

4. Sources of Personal Data

We collect personal data from the following sources:

4.1 Directly from You

We collect information that you provide directly when you:

  • Register for an account
  • Make payments or Top-Ups
  • Contact customer support
  • Use the Services

4.2 Automatically Through Your Use of the Services

We collect certain data automatically through your interaction with the Services, including technical, usage, and device information.

4.3 From Third-Party Providers

We may receive data from third-party service providers, including:

  • Payment processors
  • Authentication providers
  • Infrastructure and hosting providers
  • Analytics providers

Such third parties may provide us with information necessary to process transactions, authenticate users, or maintain the Services.

5. Purposes of Processing

We process personal data for the following purposes:

5.1 Service Delivery

To provide, operate, maintain, and improve the Services, including account management and access to proxy infrastructure.

5.2 Account Management

To create and manage user accounts, authenticate users, and provide access to features and functionalities.

5.3 Payments and Billing

To process payments, manage billing, detect payment issues, and maintain financial records.

5.4 Security and Fraud Prevention

To detect, prevent, and investigate fraud, abuse, chargebacks, and unauthorized activity, and to protect the integrity and security of the Services.

5.5 Customer Support and Communications

To respond to inquiries, provide support, and communicate with you regarding your use of the Services.

Where permitted by Applicable Law, we may also send service-related communications and, where you have provided consent, promotional communications.

5.6 Legal and Compliance Purposes

To comply with applicable laws, regulations, legal processes, and governmental requests, and to enforce our Terms of Service and other policies.

5.7 Service Improvement

To analyze usage patterns, improve functionality, and enhance the performance and reliability of the Services.

6. Legal Bases for Processing (GDPR)

Where the General Data Protection Regulation (EU) 2016/679 ("GDPR") applies, we rely on the following legal bases for processing personal data:

6.1 Contract Performance

We process personal data where it is necessary to perform a contract with you or to take steps at your request prior to entering into a contract (Article 6(1)(b) GDPR). This includes:

  • Providing access to the Services
  • Processing payments
  • Managing your account

6.2 Legitimate Interests

We process personal data where it is necessary for our legitimate interests, provided that such interests are not overridden by your rights and interests (Article 6(1)(f) GDPR). These legitimate interests include:

  • Ensuring the security and integrity of the Services
  • Detecting and preventing fraud, abuse, and unauthorized use
  • Improving and maintaining the Services
  • Enforcing our Terms of Service

Where we rely on legitimate interests, we consider the necessity of the processing and balance our interests against your rights, taking into account the nature of the data, the context of processing, and reasonable expectations of Users.

6.3 Consent

We process personal data based on your consent where required by Applicable Law (Article 6(1)(a) GDPR), including for certain types of cookies or marketing communications.

You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before such withdrawal.

6.4 Legal Obligations

We may process personal data where necessary to comply with legal obligations (Article 6(1)(c) GDPR), including tax, accounting, and regulatory requirements under Cypriot and EU law.

7. Cookies & Similar Technologies

We use cookies and similar technologies to operate, secure, and improve the Services.

7.1 Types of Cookies

Cookies used by the Company may include:

  • Essential Cookies: Necessary for the operation of the Services, including authentication and security
  • Functional Cookies: Used to enhance user experience and remember preferences
  • Analytics Cookies: Used to understand how Users interact with the Services

7.2 Purpose of Cookies

We use cookies and similar technologies for purposes including:

  • Maintaining user sessions
  • Securing the Services
  • Preventing fraud and abuse
  • Analyzing usage and performance
  • Improving functionality

7.3 Consent

In accordance with the ePrivacy Directive (2002/58/EC) and applicable Cypriot law, we will obtain your prior informed consent before placing non-essential cookies on your device.

You may manage your cookie preferences through your browser settings or through any consent management tools provided on the Site.

7.4 Third-Party Cookies

We may use third-party service providers, such as analytics providers, that use cookies or similar technologies to collect information about your interaction with the Services.

Such third parties may process data in accordance with their own privacy policies.

7.5 Cookie Policy

Further information regarding our use of cookies is set out in our Cookie Policy.

7.6 Do Not Track & Global Privacy Control

Some browsers provide "Do Not Track" ("DNT") signals or Global Privacy Control ("GPC") mechanisms.

At this time, the Company does not respond to DNT signals. Where required by Applicable Law, we will honor legally recognized opt-out preference signals, including GPC signals.

8. Analytics & Tracking Technologies

We may use analytics tools and similar technologies to better understand how Users interact with the Services, improve functionality, and maintain system performance.

These tools may collect information such as:

  • Pages visited and interactions within the Services;
  • Device and browser characteristics;
  • General location information derived from IP addresses; and
  • Usage patterns and performance metrics.

Analytics data is used in an aggregated or de-identified form where reasonably practicable.

We do not use analytics technologies for cross-site tracking or behavioral advertising. Any analytics providers engaged by the Company are contractually required to process data in accordance with applicable data protection laws, including the GDPR where applicable.

9. Payment Processing & Financial Data

Payments for the Services are processed through third-party payment providers. By making a payment, you agree to the terms and conditions of such providers.

We do not collect or store full payment card numbers, security codes, or other sensitive financial information. Such information is processed directly by the payment provider.

We may receive limited transaction-related information necessary to:

  • Confirm payment status;
  • Prevent fraud and abuse;
  • Maintain financial records; and
  • Provide customer support.

Payment providers may independently collect and process personal data in accordance with their own privacy policies. We are not responsible for the privacy practices of such third parties.

10. Fraud Prevention & Automated Decision-Making

To protect the Services, Users, and the Company, we implement fraud detection and risk assessment systems, which may include automated decision-making processes.

These systems may analyze various data points, including:

  • Transaction details;
  • Device and session information;
  • Location indicators; and
  • Behavioral patterns associated with potential fraud or abuse.

As a result of such processing, certain actions may be taken, including:

  • Blocking or declining transactions;
  • Restricting access to the Services;
  • Flagging or suspending Accounts; or
  • Requiring additional verification.

In accordance with Article 22 of the GDPR, where automated decision-making produces legal effects or similarly significantly affects you, you have the right to:

  • Obtain human intervention from the Company;
  • Express your point of view; and
  • Contest the decision.

We implement appropriate safeguards to ensure that such processing is proportionate, necessary, and designed to protect the integrity of the Services.

11. Proxy Services & Traffic Data

The Services include proxy network functionality that enables Users to route internet traffic through various networks.

In providing such Services, the Company acts as a technical intermediary and does not control the content of communications transmitted through the proxy infrastructure.

The Company does not intentionally inspect, monitor, or analyze the content of User communications transmitted through the Services, except to the limited extent necessary to:

  • Maintain the security and integrity of the Services;
  • Detect and prevent fraud, abuse, or unlawful activity;
  • Troubleshoot and improve system performance; or
  • Comply with legal obligations or valid legal requests.

Depending on the service tier, the Company may process limited technical logs or request metadata for operational, security, and support purposes. Such data is handled in accordance with this Privacy Policy and is not used to identify individual users beyond what is necessary for legitimate business purposes.

The Company does not guarantee anonymity, privacy, or untraceability in connection with the use of the Services. Third parties, including websites or network operators, may be able to detect or identify the use of proxy services.

You are solely responsible for the data you transmit through the Services and for ensuring that your use complies with all Applicable Laws and third-party rights.

12. Data Sharing & Third Parties

We may share personal data with third parties where necessary to provide, operate, secure, and improve the Services, or where required by Applicable Law. We do not disclose personal data except as described in this Privacy Policy or as otherwise permitted by law.

12.1 Service Providers (Processors)

We engage third-party service providers to perform functions on our behalf and to support the operation of the Services. These service providers act as data processors (or equivalent roles under applicable law) and are contractually obligated to process personal data only in accordance with our instructions and applicable data protection laws, including through Data Processing Agreements as required by Article 28 of the GDPR.

Such service providers may include, without limitation:

  • Payment processors (e.g., Stripe) for payment processing and fraud prevention;
  • Authentication and identity management providers (e.g., Clerk);
  • Hosting, infrastructure, and database providers (e.g., Railway, Vercel, Supabase);
  • Analytics and performance monitoring providers (e.g., Google Analytics or similar tools); and
  • Communication and customer support service providers.

These providers are authorized to process personal data only as necessary to provide their services to us and are subject to confidentiality, security, and data protection obligations.

12.2 Independent Third Parties

Certain third parties, such as payment processors, may act as independent controllers with respect to the personal data they process. In such cases, their processing is governed by their own privacy policies, and we encourage you to review those policies before providing your information.

12.3 Legal Compliance & Protection of Rights

We may disclose personal data where required or permitted by Applicable Law, or where we reasonably believe that such disclosure is necessary to:

  • Comply with applicable laws, regulations, legal processes, or enforceable governmental requests, including those issued by Cypriot or EU authorities;
  • Respond to lawful requests from public authorities, including for national security or law enforcement purposes;
  • Enforce our Terms of Service, Acceptable Use Policy, or other agreements;
  • Detect, prevent, or address fraud, abuse, security incidents, or technical issues; or
  • Protect the rights, property, safety, or legitimate interests of the Company, our Users, or third parties.

12.4 Business Transfers

In the event of a merger, acquisition, reorganization, financing, asset sale, or other corporate transaction, personal data may be transferred to a third party as part of such transaction.

Where this occurs, we will take appropriate steps to ensure that any recipient of personal data is bound by confidentiality obligations and, where required, data protection obligations consistent with this Privacy Policy and applicable law.

12.5 Professional Advisors

We may disclose personal data to our professional advisors, including legal, financial, audit, and insurance advisors, where necessary to obtain advice, enforce our rights, or manage our business risks.

12.6 No Sale or Commercial Exploitation of Personal Data

We do not sell, rent, or trade personal data to third parties for their own marketing, advertising, or commercial purposes.

We do not engage in cross-context behavioral advertising or the sale or sharing of personal data as defined under applicable privacy laws, including the GDPR and any applicable national data protection legislation.

13. International Data Transfers

The Company is established in the Republic of Cyprus and operates on a global basis. As a result, personal data may be transferred to, processed in, or accessed from jurisdictions outside the European Economic Area ("EEA").

Where personal data is transferred outside the EEA, we implement appropriate safeguards to ensure that such data remains protected in accordance with the GDPR and Applicable Law.

These safeguards may include:

  • An adequacy decision by the European Commission under Article 45 of the GDPR;
  • Standard Contractual Clauses (SCCs) approved by the European Commission under Article 46(2)(c) of the GDPR;
  • Binding Corporate Rules where applicable;
  • Contractual obligations with service providers; and
  • Additional technical and organizational measures where appropriate, in line with the guidance of the European Data Protection Board.

By using the Services, you acknowledge that your personal data may be transferred and processed internationally in accordance with the safeguards described above.

14. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements, in accordance with the principle of storage limitation under Article 5(1)(e) of the GDPR.

Retention periods may vary depending on the type of data and the purposes of processing.

14.1 Account Data

Account-related data is retained for the duration of your account and for a reasonable period thereafter as necessary to comply with legal obligations or resolve disputes.

14.2 Transaction Data

Transaction and financial records may be retained for longer periods as required by applicable tax, accounting, and regulatory requirements under Cypriot and EU law.

14.3 Service and Usage Data

Technical and usage data, including logs, may be retained for limited periods necessary to:

  • Maintain system performance;
  • Detect and prevent fraud or abuse;
  • Troubleshoot issues; and
  • Ensure security.

Retention periods may vary depending on the service tier and operational requirements.

14.4 Security and Fraud Data

Data associated with fraud detection, security monitoring, or investigations may be retained for longer periods where necessary to prevent abuse, enforce policies, or comply with legal obligations.

14.5 Deletion and Anonymization

Where personal data is no longer required, we will delete or anonymize such data in accordance with our internal retention schedules and Applicable Law, unless retention is required or permitted by law.

15. Data Security

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure, in accordance with Article 32 of the GDPR.

Such measures may include:

  • Encryption of data in transit (e.g., TLS);
  • Access controls and authentication mechanisms;
  • Network and system security safeguards;
  • Monitoring and logging of security events; and
  • Regular review of our security practices.

Access to personal data is limited to authorized personnel who require such access for legitimate business purposes and are subject to confidentiality obligations.

While we take reasonable steps to protect personal data, no method of transmission over the internet or method of electronic storage is completely secure. Accordingly, we cannot guarantee absolute security.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of natural persons, the Company shall notify the competent supervisory authority without undue delay and, where feasible, within 72 hours, in accordance with Article 33 of the GDPR. Where the breach is likely to result in a high risk, affected individuals will also be notified in accordance with Article 34 of the GDPR.

16. Your Rights Under the GDPR and Cypriot Law

Under the GDPR and the Cypriot Processing of Personal Data (Protection of the Individual) Law (Law 125(I)/2018), you have the following rights in relation to your personal data:

  • Right of Access (Article 15 GDPR): To obtain confirmation as to whether we process your personal data and to receive a copy of such data;
  • Right to Rectification (Article 16 GDPR): To request correction of inaccurate or incomplete personal data;
  • Right to Erasure (Article 17 GDPR): To request deletion of your personal data, subject to certain legal exceptions;
  • Right to Restrict Processing (Article 18 GDPR): To request limitation of processing in certain circumstances;
  • Right to Data Portability (Article 20 GDPR): To receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller where technically feasible;
  • Right to Object (Article 21 GDPR): To object to processing based on legitimate interests, including processing related to fraud prevention, subject to applicable law;
  • Right Not to Be Subject to Automated Decision-Making (Article 22 GDPR): To not be subject to a decision based solely on automated processing that produces legal effects or similarly significantly affects you, with certain exceptions.

To exercise your rights, you may contact us using the details provided in this Privacy Policy.

We will respond to your request without undue delay and in any event within one (1) month of receipt, as required by Article 12(3) of the GDPR. This period may be extended by a further two months where necessary, taking into account the complexity and number of requests.

In certain cases, we may request additional information to verify your identity before responding.

Certain rights may be limited where processing is necessary for compliance with legal obligations, the establishment or defense of legal claims, or the prevention of fraud and abuse.

17. Additional Rights Under Other Privacy Laws

If you are a resident of a jurisdiction with specific privacy laws (such as the California Consumer Privacy Act (CCPA) or similar legislation), you may have additional rights regarding your personal information, subject to applicable exceptions.

These rights may include:

  • The right to know what personal information we collect, use, disclose, and retain;
  • The right to request deletion of your personal information;
  • The right to correct inaccurate personal information;
  • The right to access specific pieces of personal information; and
  • The right not to be discriminated against for exercising your rights.

We do not sell or share personal information for cross-context behavioral advertising as defined under applicable law.

You may submit a request to exercise your rights by contacting us using the contact details provided below.

We may verify your identity before responding to your request and may deny or limit requests as permitted by Applicable Law.

18. Children's Privacy

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect personal data from children.

If we become aware that we have collected personal data from a child without appropriate authorization, we will take steps to delete such data as soon as reasonably practicable, in accordance with Article 8 of the GDPR and applicable national law.

If you believe that a child has provided us with personal data, please contact us so that we can take appropriate action.

19. Changes to This Privacy Policy

We may update or modify this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or business operations.

When we make material changes, we will update the "Effective Date" at the top of this Privacy Policy and, where appropriate, provide additional notice, such as through the Services or by email.

Your continued use of the Services after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes.

20. Contact, Complaints & Supervisory Authority

If you have any questions, concerns, or requests regarding this Privacy Policy or the Company's data practices, you may contact us at:

EA Flame Technologies LTD
Mesaorias 1, Lakatamia, 2322, Nicosia, Cyprus
Email: [email protected]
Website: https://www.flameproxies.com

We encourage you to contact us first so that we can attempt to resolve your concerns directly.

If you are located in the European Economic Area, you have the right to lodge a complaint with a competent supervisory authority under Article 77 of the GDPR. The lead supervisory authority for the Company is:

Office of the Commissioner for Personal Data Protection of the Republic of Cyprus
(Γραφείο Επιτρόπου Προστασίας Δεδομένων Προσωπικού Χαρακτήρα)
Website: https://www.dataprotection.gov.cy

You may also lodge a complaint with the supervisory authority in your own EU/EEA Member State of habitual residence, place of work, or place of the alleged infringement.