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TERMS OF USE

The following Terms of Use and the Privacy Policy (together, the "Terms") constitute a legally binding agreement between you and Proofn Limited, its subsidiaries, affiliates, partners, representatives, directors, and officers (collectively referred to as “Proofn," “Proofn Limited,” "us," "we," or "our") and govern your access and use of and describe your rights and responsibilities while using the Proofn web application, mobile application, services, features and functionalities, website, and technology platform (collectively, the "Services").



By registering and using our services, you hereby agree to be bound by the following terms. These Terms, together with the privacy policy available at ("Privacy Policy"), limited warranty available at ("Limited Warranty"), and other additional agreements referred to and/or linked herein, all of which are incorporated herein by reference, are, collectively, the "Agreement."



Certain services we provide to you may be subject to additional terms and such additional terms will be presented to you when you use such services. If the terms and conditions herein this Agreement are inconsistent with the additional terms, the provisions of the additional terms shall be superior and shall control with respect to such additional service and your use thereof. The additional terms, upon acceptance, are incorporated into these Terms.



Please, read these Terms, Agreement and any additional terms applicable to your use of the Services before using it. These Terms expressly supersede prior agreements or arrangements with you regarding the use of the Services.



If you fail to abide by the provisions of the Terms herein, except as otherwise permitted by us from time to time, you agree that we may suspend or delete your user account and all information related to such account, with or without notice to you.



Throughout these Terms, we use “Proofn,” “Proofn Limited,” "we," "us," and "our" to refer to Proofn, offering our Services to you. "You" means the organization you represent in accepting these Terms or, if that is not applicable, "you" refers to you as an individual who makes use of the Proofn services.



Modification to the Agreement



We reserve the right to modify these Terms at any time with no prior notice to you, effective upon posting the amended Terms on this site. If we do modify these Terms, we will revise the "Last Updated" date at the top of this page. You are responsible for regularly reviewing all modified versions of these Terms. Continued use of Proofn after any modifications to the Terms shall constitute your express consent to be bound by each of the modified terms and conditions. If you do not agree to be bound to terms and conditions of the modified Terms you will not use or access the Proofn Services.


Eligibility and Account Registration




You may need to register for an account to access some or all of our Services. Before you create an account, you confirm that you are eligible to use our service. By using the service, you warrant and represent that:



You are at least 17 years old or of the legal age in your jurisdiction and you have the capacity, right, and authority to enter a legal agreement and will abide by all the provisions of these Terms of Use;



If you register for an account with Proofn, you shall provide us with accurate and complete registration information (including, but not limited to, your email address and mobile telephone number and a password you will use to access the Service).



You will also keep your registration information accurate and up-to-date. Failure to do so shall constitute a breach of these Terms, which may result in immediate termination of your Proofn account.



By registering to use Proofn, you agree that you will not:



select as your User ID a name that you don't have the right to use or another person's name with the intent to impersonate that person;



create an account for anyone other than yourself without such person's permission;



create a user name or Proofn account that is subject to any rights of a person other than you without appropriate authorization; or


create a user name that is otherwise offensive, vulgar or obscene or otherwise unlawful.


We reserve the right to refuse registration of or cancel a user name at its sole discretion. You are solely responsible and liable for activity that occurs on your account and shall be responsible for maintaining the confidentiality of your account password. You shall never use another user's account without such other user's prior express permission. You accept responsibility for all activities that occur under your User Account you will immediately notify us in writing of any unauthorized use of your account or other account-related security breaches of which you are aware.



Intellectual Property Rights



All data and content made available to you through the Service, such as graphics, logos, page headers, button icons, scripts, and service names, are trademarks (whether registered or in the process thereof), copyright, service marks, or other trade property of Proofn, not you, and is protected by the Hong Kong Special Administrative Region and international intellectual property laws. We own – not you – our information, data, and content, including but not limited to: databases, technology, know-how, visual interfaces, interactive features, graphics and design or the Site and other products, software, aggregate databases and metrics, supervision systems, business model, cost measures, feedback and all other elements and components of the Site and Service.



Any use of the App or the App Content, website, or the website content other than as specifically authorized herein, without our prior written permission, is strictly prohibited and will terminate the license granted herein. Such unauthorized use may also violate applicable laws, including without limitation copyright and trademark laws and applicable communications regulations and statutes. Unless explicitly stated herein, nothing in these Terms shall be construed as conferring any license to intellectual property rights, whether by estoppel, implication, or otherwise. This license is revocable by us at any time without notice and with or without cause.



Without the prior written consent of the owner, modification of the materials, use of the materials on any other website, app or networked computer environment, or use of the materials for any purpose other than personal, non-commercial use is a violation of the copyrights, trademarks, and other proprietary rights, and is prohibited. Any use for which you receive any remuneration, whether in money or otherwise, is a commercial use for the purposes of this clause.



License and Restrictions



Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-sublicensable, revocable, non-transferable license to access and use the Services subject to the Terms of this Agreement. Any rights not expressly granted herein are reserved by us. You may not: (i) remove any copyright, trademark, or other proprietary notices from any portion of the Services; (ii) reproduce, modify, prepare derivative works based upon, distribute, license, lease, sell, resell, transfer, publicly display, publicly perform, transmit, stream, broadcast or otherwise exploit the Services except as expressly permitted by us; (iii) decompile, reverse engineer or disassemble the Services except as may be permitted by applicable law; (iv) link to, mirror or frame any portion of the Services; or (v) cause or launch any programs or scripts for the purpose of scraping, indexing, surveying, or otherwise data mining any portion of the Services or unduly burdening or hindering the operation and/or functionality of any aspect of the Services.



PRICING & PAYMENT, SUBSCRIPTIONS, FEATURES, BILLING, RENEWAL & CANCELLATION



(i) Pricing and Payment



We may make certain paid features available to you through the service under multiple subscription plans. Via the service, you can subscribe and get full access to the service. You are responsible for the management of your login details. If you lose your data or suspect that your account has been breached, please let us know immediately. Proofn has the right to refuse a request for subscription purchase.


Subscribing to our plan(s) requires you to have a valid method of payment, such as a credit card or debit card (a "Payment Method"). You are responsible for all charges incurred in connection with your payment, and you agree to pay the fees and charges for any purchased feature and plans as described below.



You Must Choose the Following Option After Downloading the Proofn app for iOS and Android:



1-A Free Plan ("Free Plan").



You can create a free Proofn email username for yourself (i.e., yourname@proofn.com) (a "Free Plan") by downloading the Proofn app for IOS and Android, entering your First and Last Name, entering an existing Proofn email username (optional), entering a second non-Proofn email address for password recovery purposes, selecting your birthdate (optional) and creating and confirming a password for your Free Plan. You will receive all your emails ("messages") in your inbox folder. The non-Proofn emails you send will not be editable and you will not be able to see unread messages sent to non-Proofn email addresses, add the non-Proofn email recipient to Private Groups, and fill in Private Notes about the non-Proofn email recipient. Your only choice to use all the features on Proofn is to use Proofn as your default external email mailbox and send messages to Proofn contacts. You can import all your mobile phone contacts with an email address to Proofn. If you all import your mobile phone contacts with an email address to Proofn, your respective contacts must download the Proofn app for iOS and Android and create a Free Plan.



Your Non-Proofn Email Recipients Can Create Their Proofn Free Plan by Following the Signup Link in Your Emails



Every message you sent from Proofn to a non-Proofn email address will have a Proofn signup link on the footer. Your recipients can follow the Proofn signup link on your message to download the free Proofn app for iOS and Android, and create their Free Plan. Your recipients can then upgrade their Free Plan to a Silver Plan or Gold Plan anytime by going to the Proofn website at proofn.com, logging in to their Free Plan using their Proofn email username and password, going to Settings, and selecting a Silver Plan or Gold Plan billed monthly or annually. They will be asked to enter their credit card number to pay for their Silver Plan or Gold Plan.



All Free Plans Have a 50 Proofn Contact Limit



You can have up to 25 Proofn contacts (“contacts”) and an unlimited number of non-Proofn contacts (“non-Proofn contacts") on your Free Plan. However, if you import all your smartphone contacts with an email address to Proofn, you can have an extra 25 contacts. That means you can have up to 50 contacts if you import your mobile phone contacts with an email address to Proofn. If you exceed your 50 contacts Free Plan limit, you will have to remove contacts to drop below the 50 contacts limit. If your Free Plan still exceeds the 50 contacts limit, you will not be able to add new contacts. To have more than 50 contacts, your only option is to upgrade to a Silver Plan or Gold Plan by going to “Settings”, then “Upgrade Plan”, select a Subscription Plan. You must enter your credit card details or use your credit card on file to purchase a monthly or annual Silver Plan or Gold Plan. Your respective contacts must download the Proofn app for iOS and Android and create a Free Plan to use all the features on Proofn.



All Free Plans Provide 500MB of Free Storage.



You can't increase your total storage capacity limit on a Free Plan. If you exceed your 500 MB free storage limit on a Free Plan, you will have to delete messages to drop below the 500MB free storage limit. If your Free Plan still exceeds the 500MB shared storage limit at the end of the day (midnight your time), you will not be able to send or receive incoming messages and group messages, until your Free Plan storage drops below the 500MB free storage limit. To increase your storage limit, your only option is to upgrade to a Silver Plan or Gold Plan by going to “Settings”, then “Upgrade Plan”, select a Subscription Plan. You must enter your credit card details or use your credit card on file to purchase a monthly or annual Silver Plan or Gold Plan.



All Free Plans Let You Create up to 5 Different Folders For Your Messages



You can create up to 5 folders for your messages. If you exceed your 5 Free Plan Folder limit, you will not be able to create new folders for your messages. You will have to delete existing folders to get under the 5 Folder limit in order to create new folders. To create more than 5 folders for your messages, your only option is to upgrade to a Silver Plan or Gold Plan by going to “Settings”, then “Upgrade Plan”, select a Subscription Plan. You must enter your credit card details or use your credit card on file to purchase a monthly or annual Silver Plan or Gold Plan.



You May Choose One of The Following Options After You Create Your Free Plan.



1-A Silver Plan ("Silver Plan")



You can upgrade from a Free Plan to a Silver Plan by going to “Settings”, then “Upgrade Plan,” and selecting a monthly or annual Silver Plan. You will be asked to enter your credit card number to pay for your Silver Plan. You will receive a 15% discount if you choose to be billed annually for your Silver Plan. There will be no refunds for your Silver Plan.



All Silver Plans Have a 600 Contact Limit



You can have up to 600 Proofn contacts (“contacts”) and an unlimited number of non-Proofn contacts (“non-Proofn contacts") on your Silver Plan. If you exceed your 600 contacts Silver Plan limit, you will have to remove contacts to drop below the 600 contacts limit. To have more than 600 contacts, your only option is to upgrade to a Gold Plan by going to “Settings”, then “Upgrade Plan,” and selecting a monthly or annual Gold Plan.


All Silver Plans Provide 5 GB of Free Storage.



If you exceed your 5 GB free storage limit, on a Silver Plan, you will have to delete messages to drop below the 5 GB free storage limit. If your Silver Plan still exceeds the 5 GB shared storage limit at the end of the day (midnight your time), you will not be able to send or receive incoming messages and group messages until your Silver Plan storage drops below the 5 GB free storage limit.



You can increase your total storage capacity limit from 5 GB to 1 TB in 1 GB increments on your Silver Plan for a monthly fee that will be billed monthly to your credit card on file. To increase your storage limit, your only option is to select how many GBs you want to add to your Silver Plan total storage capacity. You must enter your credit card details or use your credit card on file to purchase additional total storage capacity for your Proofn Plan. The subscription period for your additional total storage capacity subscription is monthly and will automatically renew each month on the anniversary of your purchase unless you cancel prior to your renewal date. You will be billed monthly for your additional total storage capacity subscription on or about the same day each month until you cancel your subscription. There will be no refunds for your additional total storage capacity subscription.



All Silver Plans Let You Create up to 50 Different Folders For Your Messages



If you exceed your 50 Folder limit, on a Silver Plan, you will not be able to create new folders for your messages. You will have to delete existing folders to get under the 50 Folder limit in order to create new folders. To create more than 50 folders for your messages, your only option is to upgrade to a Gold Plan by going to “Settings”, then “Upgrade Plan,” and selecting a monthly or annual Gold Plan.



Cancelling Your Increased Total Storage Capacity



To cancel your "increased total storage capacity subscription", you must message us at cancel@proofn.com and request cancellation prior to your renewal date. If you cancel the "increased total storage capacity subscription" prior to your renewal date, your Silver Plan will revert back to the 5GB shared free storage limit. You will have to delete messages to drop below the 5GB free storage limit. If your Silver Plan still exceeds the 5GB free storage limit at the end of the day (midnight your time), you will not be able to send or receive incoming messages and group messages until your Silver Plan storage drops below the 5GB free storage limit. There will be no refunds. All prices and pricing plans are subject to future modification or termination at our sole discretion.



Student and Educator Discounts for a Silver Plan and Additional Storage



If you are a current student or educator with a school email address (i.e., yourname@schoolname.edu) you must enter your school email address as your Recovery Email Address when you first signup to a Proofn Free Plan to receive a 20% student and educator discount on a Silver Plan. You will not receive a 20% student and educator discount when you purchase a monthly "increased total storage capacity subscription" on a Silver Plan.



2-A Gold Plan ("Gold Plan")



You can upgrade from a Free Plan to a Gold Plan by going to “Settings”, then “Upgrade Plan,” and selecting a monthly or annual Gold Plan.You will be asked to enter your credit card number to pay for your Gold Plan. You will receive a 15% discount if you choose to be billed annually for your Gold Plan. There will be no refunds for your Gold Plan.



All Gold Plans Have a 1500 Contact Limit



You can have up to 1500 Proofn and non-Proofn contacts ("contacts") on your Gold Plan. If you exceed your 1500 contacts Gold Plan limit, you will have to remove contacts to drop below the 1500 contacts limit. If your Gold Plan still exceeds the 1500 contacts limit, you will not be able to add new contacts. You can't increase your total contacts limit.



All Gold Plans Let You Create up to 300 Different Folders For Your Messages



If you exceed your 300 Folder limit, on a Gold Plan, you will not be able to create new folders for your messages. You will have to delete existing folders to get under the 300 Folder limit in order to create new folders. You can't increase your 300 Folder limit.



All Gold Plans Provide 10 GB of Free Storage.



If you exceed your 10 GB free storage limit, on a Gold Plan, you will have to delete messages to drop below the 10 GB free storage limit. If your Gold Plan still exceeds the 10 GB shared storage limit at the end of the day (midnight your time), you will not be able to send or receive incoming messages and group messages until your Gold Plan storage drops below the 10 GB free storage limit. You can increase your total storage capacity limit from 10 GB to 1 TB in 1 GB increments on your Gold Plan for a monthly fee that will be billed monthly to your credit card on file. To increase your storage limit, your only option is to select how many GBs you want to add to your Silver Plan total storage capacity. You must enter your credit card details or use your credit card on file to purchase additional total storage capacity for your Proofn Plan. The subscription period for your additional total storage capacity subscription is monthly and will automatically renew each month on the anniversary of your purchase unless you cancel prior to your renewal date. You will be billed monthly for your additional total storage capacity subscription on or about the same day each month until you cancel your subscription. There will be no refunds for your additional total storage capacity subscription.



Cancelling Your Increased Total Storage Capacity



To cancel your "increased total storage capacity subscription, you must message us at cancel@proofn.com and request cancellation prior to your renewal date. If you cancel the "increased total storage capacity subscription" prior to your renewal date, your Gold Plan will revert back to the 10 GB shared free storage limit. You will have to delete messages to drop below the 10 GB free storage limit. If your Gold Plan still exceeds the 10GB free storage limit at the end of the day (midnight your time), you will not be able to send and receive incoming messages and group messages, until your Gold Plan storage drops below the 10 GB free storage limit. There will be no refunds. All prices and pricing plans are subject to future modification or termination at our sole discretion.



Student and Educator Discounts for Gold Plans



If you are a current student or educator with a school email address (i.e., yourname@schoolname.edu) you must enter your school email address as your Recovery Email Address when you first signup to a Proofn Free Plan to receive a 20% student and educator discount on a Gold Plan. You will not receive a 20% student and educator discount when you purchase a monthly "increased total storage capacity subscription" on a Gold Plan.



Send and Receive Messages to/From any Non-Proofn Email Address on All Plans



You can enter a recipient's email address, and even if the recipient has a non-Proofn email address, that recipient will be added as your contact and count towards your contact limit when you send your message to the recipient. You can message anyone with a non-Proofn email address, but in that case you will not be able to see if your messages was read to such email addresses. Messages along with attachments you sent to any non-Proofn email address cannot be changed or removed. You can read, reply, copy and paste, mark as important, move messages to a folder you created, transform messages into PDF files, and forward messages from anyone with a non-Proofn email address. If you reply or forward messages sent from anyone with a non-Proofn email address, that non-Proofn email address will get added to your Proofn account as an contact. That means if you receive a message from a non-Proofn email address that you don't want add as a contact you should delete the message. You should never reply to or forward a message from a non-Proofn email address if you don't want that non-Proofn email address saved as a contact.



Create Private Groups on All Plans



You can create Private Groups on Proofn by adding at least 3 of your Proofn Contacts and join Private Groups that your Proofn Contacts created. You will be the admin of any Groups you create on Proofn. As the admin of any Private Group, you can add Proofn Contacts to that group, designate another Private Group member as an additional Private Group admin, leave your Private Group after designating another Private Group member as an additional Private Group admin, and remove members from your Private Group. You can't add any contact with a non-Proofn email address to any of your Private Groups on Proofn. You can also join any Private Group on Proofn created by your Proofn contacts, remove yourself as a member from any Private Group on Proofn, you belong to if you are not an Admin of that Private Group on Proofn.



Send Inline Short-Form Video Attachments That Autoplays in Silent Mode in Messages Called "PeekViews" on the Proofn app for iOS on All Plans



If you use the Proofn app for iOS, you can send messages and group messages and add short-form inline video attachments (up to 10 MB maximum) that autoplay in silent mode ("PeekViews") to any recipient that has an email account from Proofn and to any Private group you belong to. If you use the Proofn app for Android, you can send messages and group messages and attach regular (non-inline) short-form video attachments but you can't attach PeekViews because the Android operating system doesn't support PeekViews at this time. If you use the Proofn app for Android, you can watch the PeekViews you receive from Proofn contacts by going to the Proofn website (proofn.com) and logging in to your Proofn account.



Change or Delete Any Unread Message You Sent Retroactively to Any Group You Belong to on Proofn on All Plans



You can send group messages that include attachments and/or PeekViews (if you use the Proofn app for iOS) to Private Groups you belong to. You can see all the unread group messages you sent to Private Groups you belong to. That means when no member in a Private Group you belong to has read your group message it is an unread group message. You can edit the intended recipient of any unread group message you sent to Private Groups you belong to by adding recipients. You can edit anything you wrote including attachments and/or PeekViews (if you use the Proofn app for iOS) in the unread group messages you sent to Private Groups you belong to.



That means any group messages you edited including any attachments and/or PeekViews (if you use the Proofn app for iOS) to any Private Group you belong to will have the same timestamp and inbox and chat queue position as your originally sent group message. You can't edit or delete any read group message you sent to any Private Group you belong to. That means you can't edit or delete a group message if any member in the Private Group you belong to reads what you sent. You can't add any contacts with a non-Proofn email address to any Private Group you belong to.



Please note that any attachments and/or PeekViews (if you use the Proofn app for iOS) on a group message you've sent to a Private Group you belong to will get added to the Photo gallery of that Private Group. That means other members of that Private Group you belong to can view attachments and/or PeekViews (if you use the Proofn app for iOS) even if you retroactively delete the attachments/and or PeekViews. The only way to remove attachments and/or PeekViews (if you use the Proofn app for iOS) from the Photo gallery of a Private Group you belong to is to retroactively delete the unread group message you've sent that contain the attachments and/or PeekViews. You can resend your unread edited group messages including attachments and/or PeekViews (if you use the Proofn app for IOS) to any Private Group you belong to and the timestamp and queue position of your group message will not change.



Change or Delete Any Unread Messages You Sent Retroactively to Anyone With an Email Address from Proofn on All Plans



You can enter the name of an email recipient, and if the recipient has an email account from Proofn, that recipient is automatically added as your Proofn Contact when you send a message to them. You can send messages that include attachments and/or PeekViews (if you use the Proofn app for iOS) to any recipient with an email account from Proofn. You can see the unread messages you sent to any recipient with an email account from Proofn. You can edit the intended recipient of your unread message by adding recipients. You can edit anything you wrote including adding or removing attachments and/or PeekViews (if you use the Proofn app for iOS) in the unread messages you sent to any recipient with an email account from Proofn. You can resend your unread edited messages to any recipient with an email account from Proofn and the timestamp and position in the inbox and chat queue will not change. That means any messages you edited to any recipient with an email account from Proofn, will have the same timestamp and position in the inbox and chat queue as your originally sent message on Proofn. You can also create folders for each message you send and receive from a Private Group you belong to, transform any message into a PDF, mark Proofn contacts and Private Groups as Favorites, take a photo, and attach the photo to your message, record and attach audio clips to your messages, attach video to your messages, attach files, attach photos, attach PeekViews (if you use the Proofn app for IOS) to your messages, change your password, upload and change your profile photo, and see which of your Proofn contacts are online and offline on Proofn.



Fill Out And Edit Private Notes About Every Proofn Contact on All Plans



You can fill out/edit Private Notes about any Proofn Contact. When you message or retroactively edit any unread message you’ve sent to any Proofn Contact or Proofn Contacts, you can see/edit your Private Notes that involves that Proofn Contact or Proofn Contacts you're sending a message to. You can't fill out Private Notes about contacts with a non-Proofn email address.



Turn a Chat Into an Email (And Vice Versa) on Proofn on All Plans



You can turn any chat into an email and mark the chat as important, copy and paste the message, move the chat to a folder you created for your messages, transform the chat into a PDF, or delete it. You can also turn any chat into an email and forward that email message to a non-Proofn email address. Email can also be converted back into a chat.



(ii) Subscription/Package Price Changes



We reserve the right to change the price for a subscription to the Service at our sole discretion and will be responsible for communicating any price changes to you.



(iii) Updating Payment Method



You may update your Payment Method at any time within your account settings. If at any time your Payment Method is unable to be charged for the Subscription Fee due to insufficient funds, expired or invalid account details, or otherwise, you remain responsible for the cost of such Subscription Fee. A change in your Payment Method may result in changes to your prior billing cycle. It is your responsibility to update and maintain the Payment Method associated with your Subscription Fee. In the event your Payment Method is unable to cover the Subscription Fee, we reserve the right to suspend your respective accounts and access to the Service until such time as the Payment Method has been updated to permit a charge on your payment method for the Subscription Fee.



User Representation and Platform Guidelines



You hereby represent, warrant, and agree that no materials of any kind submitted through your account or otherwise posted or shared by you through the service will be in violation of the rights of any third party, including but not limited to the copyright, trademark, publicity, privacy or other personal or proprietary rights.



Although we are committed to providing a safe user experience, we do not guarantee that the platform, or any content in it, will be safe, error-free, or uninterrupted or that it will be free from bugs or viruses. Access to the service may be interrupted, suspended, or restricted from time to time, including because of a fault, error, or unforeseen circumstances or due to scheduled maintenance. We shall not be liable to you for any loss or damage that you may suffer as a result of the service being unavailable at any time for any reason.



You agree, undertake and confirm that your use of the platform shall be strictly in accordance with the following binding guidelines:



a. You shall not host, display, upload, modify, publish, transmit, update or share any information which:



belongs to another person and to which you do not have any right to make use of or promotes an illegal or unauthorized copy of another person's copyrighted work such as posting any resume or information that doesn't belong to you, providing pirated computer programs or links to them, providing information to circumvent manufacture-installed copy-protect devices;


is grossly harmful, harassing, blasphemous, defamatory, obscene, pornographic, paedophilic, libelous, invasive of another's privacy, hateful, or racially, ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner whatever; or,


is patently offensive to the online community, such as sexually explicit content, or content that promotes obscenity, paedophilia, racism, bigotry, hatred, or physical harm of any kind against any group or individual or provides material that exploits people in a sexual, violent or otherwise inappropriate manner or solicits personal information from anyone;


Involves the transmission of "junk mail," "chain letters," or unsolicited mass mailing or "spamming" or contains any trojan horses, worms, time bombs, cancelbots, easter eggs, or other computer programming routines that may damage, detrimentally interfere with, diminish the value of, surreptitiously intercept or expropriate any system, data or personal information;


promotes illegal activities or conduct that is abusive, threatening, obscene, defamatory, or libelous;


Provides instructional information about illegal activities such as making or buying illegal weapons, violating someone's privacy, or providing or creating computer viruses; contains video, photographs, or images of another person (with a minor or an adult);


tries to gain unauthorized access or exceeds the scope of authorized access to the service or to profiles, blogs, communities, account information, bulletins, or other areas of the service or solicits passwords or personal identifying information for commercial or unlawful purposes from other users.


Interferes with another user's use and enjoyment of the service or any other individual's user and enjoyment of similar services;


Refers to any website, app or URL that, in our sole discretion, contains material that is inappropriate for the Website and app or any other website and app, contains content that would be prohibited or violates the letter or spirit of these Terms of Use.



b. You shall not use any "deep-link," "page-scrape," "robot," "spider" or other automatic devices, program, algorithm or methodology, or any similar or equivalent manual process, to access, acquire, copy or monitor any portion of the service or any Content, or in any way reproduce or circumvent the navigational structure or presentation of the service or any Content, to obtain or attempt to obtain any materials, documents or information through any means not purposely made available through the service. We reserve our right to bar any such activity.



c. You shall not probe, scan or test the vulnerability of the service or any network connected to the service nor breach the security or authentication measures on the service or any network connected to the service. You may not reverse look-up, trace or seek to trace any information on any other User of or visitor to service, or any other customer, including any account on the service not owned by you, to its source, or exploit the service or information made available or offered by or through the service, in any way where the purpose is to reveal any information, including but not limited to personal identification or information, other than your own information, as provided for by the service.



d. It is possible those other users (including unauthorized users or "hackers") may post or transmit offensive or obscene materials on the service and that you may be involuntarily exposed to such offensive and obscene materials. It also is possible for others to obtain personal information about you due to your use of the service and that the recipient may use such information to harass or injure you. We do not approve of such unauthorized uses, but by using the service, you acknowledge and agree that we are not responsible for the use of any personal information that you publicly disclose or share with others on the service. Please carefully select the type of information that you publicly disclose or share with others on the service.



e. You further agree to abide by any third-party terms that apply to the Services or when posting reviews of Proofn, including the iTunes App Store Terms of Service or the Google Play Terms of Service. Posting Proofn usernames in app store reviews is strictly prohibited and will result in deletion of your Proofn account.



Copyright Infringement Policy


1. Introduction


We respect the intellectual property rights of others and expect our users to do the same. This Copyright Infringement Policy is designed to comply with the relevant laws of Hong Kong, specifically the Copyright Ordinance (Cap. 528), and sets out the procedures for addressing claims of copyright infringement in relation to the content available on this website.


2. Copyright Infringement Procedure


If you believe that any material on our website infringes your copyright, please notify us by providing a written notice that includes the following details:


a) Identification of the copyrighted work that you claim has been infringed.


b) Identification of the material on the website that you believe infringes your copyright, including a description and its location (e.g., URL).


c) Your contact information, including your name, address, telephone number, and email address.


d) A statement that you have a good-faith belief that the use of the material is not authorized by the copyright owner, its agent, or the law.


e) A statement that the information in the notice is accurate, and that you are the copyright owner or are authorized to act on behalf of the copyright owner.


f) A physical or electronic signature of the person authorized to act on behalf of the copyright owner.


3. Counter-Notice


If you believe that the content was removed or disabled due to a mistake or misidentification, you may submit a counter-notice. To be valid, the counter-notice must include the following:


a) Identification of the material that was removed or disabled and its location before removal (e.g., URL).


b) A statement that you have a good-faith belief that the material was removed or disabled as a result of mistake or misidentification.


c) Your name, address, telephone number, and email address.


d) A statement that you consent to the jurisdiction of the courts of Hong Kong and that you will accept service of process from the party who provided the original notice of infringement.


e) A physical or electronic signature of the person authorized to act on behalf of the alleged infringer.


4. Repeat Infringers


In accordance with Hong Kong law, we may suspend or terminate the accounts of users who are found to be repeat infringers of copyright law. If you repeatedly infringe on others’ copyrights, your access to this website may be permanently revoked.


5. Limitation of Liability


We are not responsible for any damages, losses, or costs arising from the removal of content or the suspension of an account due to a valid copyright infringement notice or counter-notice.


6. Contact Information


If you wish to file a notice of copyright infringement or have any other questions about this policy, please contact us at:


Proofn Limited

copyright@proofn.com

Rm. 2101, Hong Kong Trade Centre,

161-7 Des Voeux Road Central,

Hong Kong


This policy is intended to comply with Hong Kong law and may be updated or amended from time to time. We encourage users to review it regularly.



Third-party links and services



Some links on the service may allow you to leave the service. The linked sites are not in any way under our control, and we are not responsible for the contents of any of such linked sites or any link contained in a linked site or any changes or updates to such sites.



We are not responsible for any form of transmission sent or received from any linked site. We are providing these links to you only as a convenience, and the inclusion of any link does not imply affiliation, adoption, or endorsement by us of the site. Your use of any linked site is at your own risk and is subject to the terms of use and privacy policies located on such site.



Any information or content expressed or made available by a third party or any other Site Visitor or User is that of the respective author(s) or distributor(s) and not of Proofn. We neither endorse nor are we responsible for the accuracy or reliability of any opinion, advice, information, or statement made on the service by anyone other than our authorized agents acting in their official capacities.



User Generated Contents



Advises, opinions, statements, offers, or other content or information made available through the Service to you but not directly by Proofn are those of their respective authors and should not necessarily be relied upon. Such authors are solely responsible for such content. We do not in any way guarantee the accuracy, completeness, or usefulness of any information on the service, and neither do we adopt nor endorse, nor are we responsible for, the accuracy or reliability of any opinion, advice, or statement made by parties other than Proofn.



We take no responsibility and assume no liability for any User Content that you or any other user or third party posts or sends over the Service. Under no circumstances shall we be responsible for any loss or damage resulting from anyone's reliance on information or other content posted on the Service or transmitted to users.



Though we strive to enforce these Terms of Use, you may be exposed to User Content that is inaccurate or objectionable. We reserve the right, but has no obligation, to monitor or censor the materials posted in the public areas of the service or to limit or deny a user's access to the service or take other appropriate action if a user violates these Terms of Use or engages in any activity that violates the rights of any person or entity or which we deem unlawful, offensive, abusive, harmful or malicious. We reserve the right to remove any such material that in our sole opinion violates or is alleged to violate the law or this agreement or which might be offensive, or that might violate the rights, harm, or threaten the safety of users or others.



Indemnification



By agreeing to these Terms you agree to indemnify, defend, and hold harmless Proofn, our managing members, shareholders, employees, affiliates, licensors, and suppliers (the "Proofn Parties") from and against any and all complaints, charges, claims, damages, losses, costs, liabilities, and expenses (including attorneys' fees) due to, arising out of, or relating in any way to (a) your access to or use of the Services; (b) any User Content you post, upload, use, distribute, store, or otherwise transmit through the Services; (c) your violation of these Terms; (d) your violation of the rights of another, including without limitation, any intellectual property right, publicity, confidentiality, privacy, or propriety right; or (e) your violation of any statutes, codes, ordinances, laws, rules, regulations, including without limitation, all regulatory, administrative, and legislative authorities.



Disclaimer of Warranties



By accessing or using the service, you represent and warrant that you have read, understood, and agreed to be bound by and under these terms. We supply our site, web app, mobile app and Services "as is," "with all faults," and "as available," including all content, software, data, materials, services, functions, and/or information made available therein. Accordingly, we shall not be liable to you for any loss or damage that might arise therefrom, and we hereby disclaim any express or implied warranties, including warranties as to the products or services offered by third parties listed on the Site and mobile app, non-infringement, merchantability, and fitness for a particular purpose. The use on your part of the products and/or services provided through the site, web app and mobile app is at your own and final discretion. No oral or written information or advice provided to you by Proofn shall create a representation or warranty of any kind.



Limitation of Liability



To the fullest extent permitted by applicable law, Proofn Limited (“the Company”) shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages, or any loss of profits, revenue, data, or use, arising from or in connection with the use or inability to use the services, whether in contract, tort (including negligence), or otherwise, even if the Company has been advised of the possibility of such damages.


In no event shall the total liability of the Company to you, whether in contract, tort, or otherwise, exceed the amount paid by you to the Company for the specific service that gave rise to the liability during the 12-month period preceding the claim.


Nothing in this disclaimer shall exclude or limit the Company’s liability for death or personal injury arising from the Company’s negligence, or for any other liability that cannot be excluded or limited under applicable Hong Kong law.


This limitation of liability shall apply regardless of whether the damage is caused by breach of contract, negligence, or any other cause of action.



Governing Law and Dispute Resolution



Governing Law: These Terms and your use of the service are governed by and construed in accordance with the laws of Hong Kong Special Administrative Region applicable to agreements made and to be entirely performed within Hong Kong, without regard to its conflict of law principles.



Arbitration Clause

1. Dispute Resolution: Any dispute, controversy, or claim arising out of or in connection with this Agreement, including any question regarding its existence, validity, interpretation, performance, or termination, shall be resolved through arbitration.

2. Arbitration Rules: The arbitration shall be conducted in accordance with the Arbitration Rules of the Hong Kong International Arbitration Centre (HKIAC), as in effect at the time of the arbitration, which rules are deemed to be incorporated by reference into this clause.

3. Arbitrator(s): The arbitration shall be conducted by a sole arbitrator, unless the parties agree otherwise. The arbitrator shall be appointed in accordance with the HKIAC Rules.

4. Place of Arbitration: The place of arbitration shall be Hong Kong, and the language of the arbitration shall be English, unless otherwise agreed by the parties.

5. Final and Binding: The decision of the arbitrator shall be final and binding on both parties, and judgment upon the award may be entered in any court having jurisdiction.

6. Confidentiality: The arbitration proceedings and any award shall be kept confidential, unless disclosure is required by law or agreed by the parties.

7. Governing Law: This arbitration clause shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region.



Class Action Waiver Clause



1. No Class Action or Representative Action

By accepting these Terms of Service, you agree that any dispute, claim, or controversy arising out of or relating to these Terms, your use of our services, or any related matters will be resolved on an individual basis. You agree that you will not participate in, initiate, or join any class action, collective action, or representative action against us or our affiliates in relation to such disputes.

2. Limitation on Dispute Resolution

You acknowledge that this clause prevents you from initiating or participating in class or group litigation, arbitration, or other representative dispute resolution procedures in connection with any claim against us. This provision applies regardless of whether the claims arise under contract, tort, statute, or otherwise.

3. Dispute Resolution Mechanism

You further agree that any disputes will be resolved individually, either through negotiation, mediation, or arbitration. In the event of a dispute, you agree to first attempt to resolve the matter through direct negotiation. If negotiation does not resolve the issue within 30 days, the dispute may be referred to mediation, or, if required, to arbitration, in accordance with the rules of the Hong Kong International Arbitration Centre (HKIAC) or another mutually agreed upon body.

4. Severability

If any portion of this Class Action Waiver Clause is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, the remaining portions of this waiver shall remain in full force and effect.

5. Acknowledgment of Understanding

By using our services, you confirm that you have read, understood, and agree to be bound by this Class Action Waiver Clause. You further acknowledge that you have had an opportunity to seek independent legal advice before agreeing to these terms.



General Provisions



Entire Agreement: Except as otherwise specified herein, these Terms of Use constitute the entire agreement between you and Proofn with respect to your use of the service that we make available to you and supersedes all prior communications and proposals (whether oral, written, or electronic) between you and us with respect to use of the service that we provide. Any rights not otherwise expressly granted by this Agreement are reserved by Proofn.



Waiver: The failure of Proofn to exercise or enforce any right or provision of the Terms and Conditions of Use shall not constitute a waiver of such right or provision.



Assignability: You may not assign or transfer these Terms, by operation of law or otherwise, without Proofn's prior written consent. Notwithstanding the foregoing, we may assign any rights or obligations hereunder.



Severability: If any part of these Terms of Use is held invalid or unenforceable, by a court of competent jurisdiction, that portion shall be construed in a manner consistent with applicable law to reflect, as nearly as possible, and the original intentions of the parties, and the remaining portions shall remain in full force and effect.



Notices: Any notices or other communications provided by Proofn under these Terms, including those regarding modifications to these Terms, will be given: (i) by Proofn via email; or (ii) by posting to the Services. For notices made by email, the date of receipt will be deemed the date on which such notice is transmitted.



Contacting Us



In order to resolve a complaint regarding the service or to receive further information regarding the use of the App and services, please contact us at joelgoslar@myabuy.com.


Privacy notice


Scope of this notice

Please read this privacy notice (“Notice”) carefully to understand our policies and practices regarding your Personal Data and how we will treat it. This Notice applies to individuals who interact with Proofn services as consumers (“you”). This Notice explains how your Personal Data is collected, used, and disclosed by Proofn Limited (“Proofn”, “We”, "Us”). It also tells you how you can access and update your Personal Data and make certain choices about how your Personal Data is used.

This Notice covers both our online and offline data collection activities, including Personal Data that we collect through our various channels such as websites, apps, third party social networks, Customer Service, and events. Please note that we might aggregate personal data from different sources (website, offline event) and across different devices. As part of this, we combine Personal Data that were originally collected by different Proofn partners. Please see Section 8 for further information on how to object to this.

If you do not provide necessary Personal Data to us (we will indicate to you when this is the case, for example, by making this information clear in our registration forms), we will not be able to provide you with our services. This Notice can change from time to time (see Section 9).

This Notice provides important information in the following areas:

Section 1-Sources of personal data

Section 2-Personal data that we collect about you and how we collect it

Section 3-Personal data of children

Section 4-Log files

Section 5-Disclosure of your personal data

Section 6-Retention of personal data

Section 7-Storage and/or transfer of your personal data

Section 8-Your rights

Section 9-Changes to our notice

Section 10-Data controllers & contact


1. Sources of personal data

This Notice applies to Personal Data that we collect from or about you, through the methods described below (see Section 2), from the following sources:

Proofn websites. Consumer-directed websites operated by or for Proofn, including sites that we operate under our own domains/URLs and mini-sites that we run on third party social networks such as Facebook (“Websites”).

Proofn mobile sites/apps. Consumer-directed mobile sites or applications operated by or for Proofn, such as smartphone apps.

E-mail, text and other electronic messages. Interactions with electronic communications between you and Proofn.

Proofn Customer Service. Communications with our Customer Service.


Advertising interactions. Interactions with our advertisements (e.g., if you interact with on one of our ads on a third-party website, we will receive information about that interaction).

Data we create. In the course of our interactions with you, we will create Personal Data about you (e.g. records of your purchases or purchase of subscription from our websites).


Data from other sources. Third party social networks (e.g. such as Facebook, Google, Instagram, Pinterest) third party social media (e.g. Twitter, Medium, TikTok), market research (if feedback not provided on an anonymous basis), third party data aggregators, Proofn promotional partners, public sources and data received when we acquire other companies

2. Personal data that we collect about you and how we collect it Depending on how you interact with Proofn (online, offline, over the phone, etc.), we collect

various types of information from you, as described below.

Device Information. We collect information about your device, including the hardware model, operating system and version, unique device identifiers (including MAC address and IMEI), browser type and language, email type, mobile device phone number, and mobile network information. We also collect certain device information that will help us diagnose problems in the (hopefully rare) event you experience any crash or other problem while using our Services. So, for example, if we detect a crash or other problematic event, we will collect the list of apps on your device and other information about your device’s performance at the time of the event for troubleshooting purposes.

Device Phonebook and Email Account. Because Proofn is all about communicating with friends, family, and colleagues, in order to access and use the features of the Service, you acknowledge and agree that you will have to provide Proofn with your full name, and email address for a Free Plan and with your credit card payment information for a Silver Plan and Gold Plan Account. You expressly acknowledge and agree that in order to provide the Services,

Proofn will periodically access your contact list and phone and email address book on your mobile device to find and keep track of mobile phone numbers and email addresses of other users of the Service. When providing your mobile phone number or email address, you must provide accurate and complete information. We do not collect physical addresses. You must notify Proofn immediately of any breach of security or unauthorized use of your mobile phone and/or mobile device. Although Proofn will not be liable for your losses caused by any unauthorized use of your account, you will be liable for the losses and damages of Proofn or third parties due to such unauthorized use.


Location Information. With your consent, we collect your device location so that you can use our location-based features including Proofn scheduling, and for any other purpose described in this privacy policy. As with your phonebook, email accounts and photos, you can always revoke your consent by changing the settings or preferences on your device. If you do so, certain features of the Services will no longer function.

Account login information. Any information that is required to give you access to your specific account profile. Examples include your email handle ID/email address from Proofn, password in unrecoverable form, and/or security question and answer.


Demographic information & interests. Any information that describes your demographic or behavioral characteristics to help Proofn improve our services. Examples include your date of birth, age or age range, gender, geographic location (e.g. postcode/zip code), favorite products, hobbies and interests, and household or lifestyle information

Information from computer/mobile device. Any information about the computer system or other technological device that you use to access one of our Websites or apps, such as the Internet protocol (IP) address used to connect your computer or device to the Internet, operating system type, and web browser type and version. If you access a Proofn website or app via a mobile device such as a smartphone, the collected information will also include, where permitted, your phone’s unique device ID, advertising ID, geo-location, and other similar mobile device data.

Websites/communication usage information. We collect information about your activity and the email you send and receive through our Services. This includes information such as the time, date, sender, recipient of a email, the number of email you exchange with your friends, which friends you exchange email with the most, how often you edit what you sent to recipients on Proofn, and your interactions with email (such as when you open an email or capture a screenshot). As you navigate through and interact with our Websites, we use automatic data collection technologies to collect certain information

about your actions. This includes information such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies and web beacons, and is also collected

through the use of third-party tracking for analytics and advertising purposes.

Market research & consumer feedback. Any information that you voluntarily share with Us about your experience of using our products and services.

Consumer-generated content. Any content that you create and then share with Us on third party social networks or by uploading it to one of our Websites or apps, including the use of third-party social network apps such as Facebook. Examples include photos, videos, personal stories, or other similar media or content. Where permitted, we collect and publish consumer-generated content in connection with a variety of activities, including contests and other promotions, website community features, consumer engagement, and third-party social networking.

Third party social network information. Any information that you share publicly on a third-party social network or information that is part of your profile on a third-party social network (such as Facebook) and that you allow the third-party social network to share with Us. Examples include your basic account information (e.g. name, email address, birthday, current city, profile picture, email handle, list of friends, etc.) and any other additional information or activities that you permit the third-party social network to share. We receive your third party social network profile information (or parts of it) every time you download or interact with a Proofn web application on a third party social network such as Facebook, every time you use a social networking feature that is integrated within a Proofn site (such as Facebook Connect) or every time you interact with Us through a third party social network. To learn more about how your information from a third-party social network is obtained by Proofn, or to opt-out of sharing such social network information, please visit the website of the relevant third-party social network.

Payment and Financial information. Any information that we need in order to fulfill an order, or that you use to make a purchase or purchase a subscription, such as your debit or credit card details (cardholder name, card number, expiration date, etc.) or other forms of payment (if such are made available). In any case, we or our payment processing provider(s) handle payment and financial information in a manner compliant with applicable laws, regulations and security standards such as PCI DSS.

Calls to Customer Services. Communications with a Customer Services can be recorded or listened into, in accordance with applicable laws, for local operational needs (e.g. for quality or training purposes). Payment card details are not recorded. Where required by law, you will be informed about such recording at the beginning of your call.

Sensitive Personal Data. We do not seek to collect or otherwise process sensitive personal data in the ordinary course of our business. Where it becomes necessary to process your sensitive personal data for any reason, we rely on your prior express consent for any processing which is voluntary (e.g. for marketing purposes). If we process your sensitive personal data for other

purposes, we rely on the following legal bases: (i) detection and prevention of crime (including the prevention of fraud); and (ii) compliance with applicable law (e.g. to comply with our diversity reporting).

3. Personal data of children

We do not knowingly solicit or collect personal data from children below the age of 17. If we discover that we have unintentionally collected personal data from a child below 17, we will remove that child’s personal data from our records promptly. However, Proofn will collect personal data about children below the age of 17 years of age from the parent or guardian directly, and with that person’s explicit consent.

4. Log files

We collect information in the form of log files that record website activity and gather statistics about your browsing habits. These entries are generated automatically, and help Us to troubleshoot errors, improve performance and maintain the security of our Websites.

5. Disclosure of your personal data

We share your Personal Data with the following types of third-party organizations:

•Other recipients on Proofn. When you send an email to other email addresses on Proofn (yourname@proofn.com), your recipients will see your name and, of course, whatever your email says or shows (whether that’s a photo, video, text or document attachment.)

•When you view other emails from Proofn email addresses the sender, can edit, delete or remove content and attachments at any time without providing notification to you of the changes the sender made.

•When you send a non-Proofn email, your recipients will see your name and Of course, whatever your email says or shows (whether that’s a photo, video, text or document attachment.)

•When your recipients view your email, the sender, cannot edit, delete or remove content and attachments. We will let the sender know whether the recipient(s) opened your email or not, and if we detect that you captured a screenshot of the email, we will try to let the sender know that. If you ever want to change your payment information, you may do so in the “Settings” tab.

•When you let us access your mobile phone device, we will share information about you with other users who have your phone number in their device phonebook.

•When you let us access your mobile device’s email account, we will share information about you with other users who have your email in their email account.

•When other users view your profile, they will be able to view profile information, including your full name, profile photos. When you send email along with attachments and make retroactive changes to your original email and any attachments before your recipient to other email addresses on Proofn (yourname@proofn.com), it is important for you to understand that users who see your email can always save them, either by taking a screenshot or by using some other image-capture technology (whether that be software or even something as old-fashioned as a camera to take a photo of your device’s screen). If we’re able to detect that a recipient took a screenshot of an email you sent, we’ll try to notify you. But the same common sense that applies to the Internet at large applies to Proofn as well: Don’t send email that you wouldn’t want someone to share with others. Do not write something that you will later regret writing. Always assume an unknown third party will read your email without your knowledge or permission.

A few final words on editing, deletion and removals on emails sent to anyone with an email address on Proofn. We can’t guarantee that email will be deleted, or attachments removed within a specific timeframe. And even after we’ve deleted email data or attachments from our servers, that same data or attachment will remain in backup for a limited period of time. We also sometimes receive requests from law enforcement requiring us by law to suspend our ordinary

server-deletion practices for specific information. Finally, of course, as with any digital information, there will be ways to access email while still in temporary storage on recipients’ devices or, forensically, even after they are deleted.


Service providers. These are external companies that we use to help Us run our business (e.g. order fulfillment, payment processing, fraud detection and identity verification, website operation, market research companies, support services, promotions, website development, data analysis, CRC, etc.). Service providers, and their selected staff, are only allowed to access and use your Personal Data on Our behalf for the specific tasks that they have been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure. Where required by applicable law, you can obtain a list of the providers processing your Personal Data (see Section 10 to About Us). Among the third parties we use for analytics is Google Analytics, which provides mobile analytics in connection with our app. Additionally, some companies will use the information they collect on our blog and other websites to deliver targeted advertisements on behalf of us or other companies, including on third-party websites and apps. Proofn does not currently respond to do-not-track signals that will be sent from your device. If we do so in the future, we will provide information about that practice in an updated version of this privacy policy.

Third party recipients using Personal Data for legal reasons or due to merger/acquisition.

We will disclose your Personal Data to third parties for legal reasons or in the context of an acquisition or a merger.

6. Retention of personal data

Proofn takes every reasonable step to ensure that your personal data is only processed for the minimum period necessary for the purposes set out in this Privacy Notice. The criteria for determining the retention period for your Personal Data is:

(a) Proofn will retain copies of your Personal Data in a form that allows for identification only for as long as:

(i) We maintain an ongoing relationship with you (e.g. where you have a Free Plan, Silver Plan or Gold Plan );

(ii) Your Personal Data is necessary in connection with the purposes set out in this Privacy Notice and we have a valid legal basis, Plus

(b) The duration of: (i) any applicable limitation period (i.e. any period during which a person could bring a legal claim against us), and (ii) an additional 2 months following the end of the applicable limitation period (so we are able to identify any personal data of a person who will bring a claim at the end of the applicable period),

And

(c) In addition, if any relevant legal claims are brought, we will continue to process your Personal Data for such additional time necessary in connection with that claim.

During the periods noted in paragraphs b(i) and b(ii) above, we will restrict our processing of your Personal Data to storage or, and maintaining the security of, those data, except to the extent the data need to be reviewed in connection with any claim, or any obligation under applicable law.

Once the periods in paragraphs (a), (b) and (c) above, each to the extent applicable, have concluded, we will either (i) permanently delete or destroy the relevant Personal Data or (ii) anonymize the relevant Personal Data.

7. Storage and/or transfer of your personal data

We use appropriate measures (described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas such as third-party social networks.

People who can access your Personal Data. Your Personal Data will be processed by our authorized staff or agents, on a need to know basis, depending on the specific purposes for which your Personal Data have been collected (e.g. our staff in charge of consumer care matters will have access to your consumer record).

Measures taken in operating environments. We store your Personal Data in operating environments that use reasonable security measures to prevent unauthorized access. We follow reasonable standards to protect Personal Data. The transmission of information via the Internet is, unfortunately, not completely secure and although we will do our best to protect your Personal Data, we cannot guarantee the security of the data during transmission through our Websites/apps.

Measures we expect you to take. It is important that you also play a role in keeping your Personal Data safe and secure. When signing up for an online account, please be sure to choose an account password that would be difficult for others to guess and never reveal your password to anyone else. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer, never choose to have your login ID/email address or password remembered and make sure to log out of your account every time you leave the computer. You should also make use of any privacy settings or controls we provide you in our Website/app.


Transfer of your Personal Data.

The Services are hosted in the Hong Kong Special Administrative Region. If you are a user accessing the Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from Hong Kong Special Administrative Region laws, please be advised that through your continued use of the Services, which are governed by Hong Kong Special Administrative Region law, you are transferring your personal information to the Hong Kong Special Administrative Region and you consent to that transfer.


8. Your rights

Under the GDPR, if you are an EU citizen you have the right:

•to access your personal data

•to be provided with information about how your personal data is processed

•to have your personal data corrected

•to have your personal data erased in certain circumstances

•to object to or restrict how your personal data is processed

•to receive a copy of your data in a machine-readable format

•to take any complaints about how we process your data to the Data Protection Authority in your country.

Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep.

9. Changes to our notice

If we change the way we handle your Personal Data, we will update this Notice. We reserve the right to make changes to our practices and this Notice at any time, please check back frequently to see any updates or changes to our Notice.

10. Data controllers & contact

To ask questions or make comments on this Notice and our privacy practices or to make a complaint about our compliance with applicable privacy laws, please write to us at

Proofn Limited

Rm. 2101, Hong Kong Trade Centre,

161-7 Des Voeux Road Central, Hong Kong or via email at

jgoslar@proofn.com.

We will acknowledge and investigate any complaint about the way we manage Personal Data (including a complaint that we have breached your rights under applicable privacy laws).