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PRIVACY POLICY

LAST UPDATED: 5th September 2025

This is the privacy policy (“ Policy”) for the Virtualsurf.io app by [Virtualsurf.io Pte Ltd] (“ Virtualsurf.io” or “ we” or “ our” or “ us”).

We take your privacy very seriously and have in place policies and practices dealing with data protection. We ask that you read this Policy carefully as it contains important information about our collection, use, processing and disclosure of personal data in our possession or under our control, including information on:

i) our policies and practices for meeting our obligations under laws, regulations and guidelines which concern data protection;

ii) how you may access, correct or make other requests in relation to your personal data in our possession or control as permitted by applicable laws; and

iii) details of our data protection complaints procedure.

1. COLLECTION OF PERSONAL DATA

1.1. Personal data that Virtualsurf.io collects include email address, billing information and user-submitted support tickets or emails.

1.2. These Personal data may be collected by us, directly or indirectly, during instances such as:

1.2.1. when you register for an account on the Virtualsurf.io app

1.2.2. When you sign up for a subscription, which is handled by third-party payment processors;

1.2.3. when you respond to our promotions, or subscribe to our mailing lists;

1.2.4. when you communicate with us by telephone, email, via our website or through other communication channels including social media platforms;

1.2.5.when you submit your personal data to us for any reason.

1.3. In certain circumstances, you may also provide us with personal data of persons other than yourself. If you do so, you warrant that you have informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes, including all purposes as set out in this Policy.

2. PURPOSES OF COLLECTION, USE OR DISCLOSURE

2.1. We may collect, use, store and process your personal data (defined in Para 1.1) for one or more of the following purposes:

General

2.1.1. to verify your identity;

2.1.2. to inform of you of deals and promotions in your vicinity;

2.1.3. to conduct research and analysis to improve our products and/or services;

Support and assistance

2.1.4. to facilitate customer service (e.g. providing information on status and updates), your requests, and to respond to any enquiries submitted by you or on your behalf;

2.1.5. to investigate and rectify technical issues; and/or

2.1.6. conduct feedback, analysis and development activities to improve your experience.

NO-LOGS POLICY

3.1. Virtualsurf.io does not do any of the following:

3.1.1. Log users’ traffic or the content of any communications

3.1.2. Log which websites you visit, your IP address, your session lengths, or track any location-based information.

3.1.3. Discriminate against devices, protocols or applications

4. ACCURACY

4.1. We generally rely on the accuracy of personal data provided by you or your authorised representatives. In order to ensure that our records of your personal data are current, complete and accurate, please update us if there are changes to your personal data by writing to our Data Protection Officer at the contact details at the end of this Policy.

5. OTHER WEBSITES AND MOBILE APPLICATIONS

5.1. The Virtualsurf.io app may contain links to other websites and mobile applications. However, this Policy only applies to the Virtualsurf.io app, and if you visit other websites or other mobile applications, including through such links, different privacy policies will apply.

6. SECURITY AND RETENTION

6.1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and loss of any storage medium or device on which your personal data is stored, we have introduced appropriate administrative, physical and technical measures, including to protect personal data from unintended access.

6.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure, and Virtualsurf.io cannot and does not guarantee that our systems or applications are invulnerable to security breaches. Virtualsurf.io makes no warranty, guarantee, or representation that your use of our systems or applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities.

6.3. We keep your personal data only for so long as we need the personal data to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including audit, accounting or reporting requirements. In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction.

7. YOUR RIGHTS

7.1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, (b) a correction request to correct or update any of your personal data which we hold about you, or (c) other request in relation to your personal data, as permitted by applicable data protection laws, you may submit your request by contacting the Data Protection Officer. 7.2. If you wish to exercise your rights, please contact the Data Protection Officer. You may be required to submit certain forms or provide certain information in order for your request to be processed. Where permitted by law, Virtualsurf.io may charge you a reasonable fee to process your request, and will inform you of the fee before processing your request. 7.3. We will respond to your request as soon as reasonably possible, and in accordance with applicable law.

8. CONSENT WITHDRAWALS

8.1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you. You may withdraw consent and request us to stop using and/or disclosing your personal data by submitting a request in writing to our Data Protection Officer at the contact details provided below.

8.2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within 10 business days of receiving it.

8.3. If you withdraw your consent to any or all use of your personal data or do not consent to the collection of your personal data by us, we may not be able to provide or continue providing you with products and/or services which you have requested. You understand and agree that in such instances where Virtualsurf.io requires your personal data to fulfil a contractual obligation to you and you withdraw your consent to collect, use or disclose the relevant personal data for those purposes, Virtualsurf.io cannot be held liable for breach of that agreement. Virtualsurf.io’s legal rights and remedies in such event are expressly reserved.

8.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws in any jurisdiction.

9. CHANGES TO THIS POLICY

9.1. We keep this Policy under regular review. If we change this Policy we will post the changes on or through the Virtualsurf.io app, [https://www.virtualsurf.io], or such other means as we deem appropriate.

9.2. Where you continue to provide personal data to us as described in this Policy, or continue to use our products or services, this will constitute your acknowledgement and acceptance of a revised Policy.

10. HOW TO CONTACT US / DATA PROTECTION OFFICER DETAILS

10.1. If you have any queries or comments on this Policy or the use of your personal data, or if you wish to lodge a privacy-related complaint, please contact Virtualsurf.io’s Data Protection Officer at:
Data Protection Officer
Email address: dpo@virtualsurf.io

Virtualsurf.io will investigate your queries, comments or complaint, and will use reasonable endeavours to respond, in accordance with applicable laws.