This Privacy Policy will help you understand how ToCN Inc. (“ToCN,” “we,” or “our”) handles your personal information when you use our services (“Services”).
ToCN is committed to protecting your privacy. We want you to understand what information we collect, what information we don't collect and how we collect, use and store information. We do not collect logs of your activity, including no logging of browsing history, traffic destinations, data content or DNS queries. We also never store connection logs, meaning your IP address, outgoing VPN IP address, connection timestamp or session duration are not logged.
We only collect the minimum data necessary to operate the service. We design our systems to contain no sensitive data about our customers; even if we were forced to, we cannot provide data that we do not own.
We are a global business, offering our products and services around the world. In order to reach all of our users and provide them with our software, we operate on a global infrastructure. Therefore, the servers that are part of this infrastructure may be located in a different country than the one in which you reside. In some cases, these countries may be countries outside the European Economic Area (“EEA”) whose laws may not provide a level of protection that differs from the high standards set forth in the GDPR. Regardless, we provide the same GDPR level of protection for all personal data it processes.
1. Collection of personal information As a provider of online privacy services, we ultimately strive to collect the minimum information necessary to operate our services. This often means difficult trade-offs between the information we collect and the performance of our services.
We believe in open dialogue, as this Privacy Policy is a continuously evolving document. We welcome your ideas and feedback on our work.
1.1 What is personal information? As described below, "personal information" means any information by which you can be identified, including information you provide when using our services. If we use or store personal information together with non-personal information, we treat it as personal information.
1.2 Account User Data We collect and store this "Account Data" when you create or update your ToCN user account. The full account data stored is listed below:
Account Data What do we use it for? Telephone Number General Communications, User Accounts Phone Confirmation Confirm your phone number is valid
1.3 Operation Data In order to maintain excellent customer support and service quality, ToCN only collects and stores "operational data" necessary to operate our services. This is data we collect and store when you connect to our network. The complete operating data is as follows:
(1) Operating system version, application and application version We collect information related to the operating system you are using and the applications and application versions you have activated. Knowing your current operating system and application version enables our customer support team to work with you to resolve technical issues.
(2) The connection is successful
We collect information about whether you successfully established a VPN connection on a specific date (but not a specific time of day), to which VPN location (but not your assigned outgoing IP address), and from which country/ISP (but not your source IP address). This minimal information helps us provide technical support, such as identifying connectivity issues, providing country-specific advice on how best to use our services, and enabling ToCN engineers to identify and fix network issues.
(3) Total amount of data transferred (in MB) We collect information about the total amount of data transfers you consume. Knowing how much data people use is a key metric for ToCN. It tells us if people are using ToCN, if people are hitting the free data limit, if the service is functioning, and it helps us plan our network needs. However, choosing usage metrics that respect your privacy is a challenging task. We think collecting the total amount of data used by a given user for the month is the right balance. We also ensure that no history is kept by resetting the monthly total usage value to 0 at the end of each month. We believe that the overall usage will respect the privacy of individual users (ie no login timestamp, no logs, etc.), while still providing the most important data for Lingchuang to operate our services efficiently.
(4) Summary We collect minimal usage statistics to maintain the quality of our service. For example, we may know that our customer Tom connected to our Los Angeles VPN location on Monday and transferred a total of 1024 MB of data in 24 hours. It is not possible to uniquely determine that Tom was responsible for any particular actions, as her usage patterns overlapped with thousands of other ToCN customers who also connected to the same location on the same day.
We have designed systems that completely eliminate storage of sensitive data. We may know that customers have used ToCN, but we never know how they use our services. With a strong commitment to our customers' privacy, we hold no data related to our users' online activities.
1.4 Other Data ToCN is not collected through VPN
ToCN expressly does not collect, store or record the following data: • The IP address from which our website was accessed • IP address when the service connects • DNS lookup on connection • Any information about the applications, services or websites our users use when connecting to our Services We make sure that browsing history, traffic destinations, data content, IP addresses or DNS queries are never logged. so: We do not know which user ever visited a particular website or service. We do not know which user is connected to the VPN at a specific time or which VPN server IP address they are using. • We do not know the original set of IP addresses of the user's computer. If anyone tries to force ToCN to disclose user information based on any of the above, we will not be able to provide that information because that data does not exist.
2. Personal information Any personal information you provide to ToCN will be managed in accordance with the following principles:
2.1 Accountability If you have any questions about how your information is handled or have questions about our Privacy Policy, please feel free to contact us at super@51tocn.com
2.2 Disclosure of information to third parties ToCN does not store the original IP address of the user when connecting to our service and therefore cannot identify the user when provided with our server's IP address. Additionally, we cannot disclose information about the applications, services, or websites our users use when connecting to our Services; because ToCN does not store such information.
2.3 Unless otherwise required by law, we will ask for your consent when collecting your personal information or changing the operational information we store. Your consent may be expressed or implied. In some cases, your actions may imply your consent. For example, by providing us with personal information to register for our services, this means that we may use such information as outlined in this Privacy Policy.
The form in which ToCN seeks consent may vary depending on the nature of the information. We will consider the sensitivity of the information and your reasonable expectations when determining the appropriate form of consent. Implied consent is usually appropriate when the information is less sensitive.
You have the right to refuse to agree to any request to use your personal information. To exercise your choices, or to ask questions about your personal information, please contact: super@51tocn.com
2.4 Restrictions on collection We take great care not to collect personal information indiscriminately and limit the information we collect to the minimum necessary to operate our services. By limiting data collection, we help protect the privacy and security of your personal information.
2.5 Limitations on Use, Disclosure and Retention We will not use your personal information for any purpose without your consent. Link Network does not sell or trade personal information for commercial purposes.
Only Lingchuang employees who need to do so for their business needs or duties have access to our customers' personal information. All such employees are required to respect the confidentiality of customers' personal information as a condition of employment.
We only store your personal information for as long as necessary for the purpose for which it was collected. We delete or destroy records containing personal information when they are no longer needed; doing so in a manner that will ensure your continued privacy.
2.6 Accuracy It is your responsibility to notify Leader of any relevant changes to your personal information by updating your account information.
2.7 Safeguards Linkcn uses extremely strong safeguards to protect the privacy of all of our records, including your personal information. We implement physical, operational and technical security measures. These strong safeguards are designed to prevent unauthorized access, disclosure, loss, theft, copying, use or modification of your personal information.
2.8 Openness and transparency To reassure you that we are handling your personal information appropriately, we have taken extraordinary steps to document our policies and provide open and transparent information about what data we collect, why we collect it and how we process it.
2.9 Personal access If at any time you have questions about our records containing your personal information, we will do our best to answer them. You have the right to know what type of personal information we maintain and how it is used. Upon request, we will provide you with information regarding the existence, use and disclosure of your personal information.
2.10 Changes to our Privacy Policy We may need to make changes to our Privacy Policy from time to time, and all updates will be posted online. Your continued use of our Services after such changes have taken effect constitutes your acceptance of such changes. For your convenience, we will post the effective date at the top of the page.
2.11 Data Protection Officer As required by the GDPR, we have a Data Protection Officer (DPO) who monitors our compliance with the GDPR, advises and works with regulators as required. You can contact our Data Protection Officer at super@51tocn.com.
If you have any comments and suggestions on this "Privacy Policy", you can contact our customer service through the "Personal Center" - "Online Customer Service" in the ToCN application, or send an email to super@51tocn.com
Henan Yuansuli Network Technology Co., Ltd.