Privacy Policy

This Privacy Policy describes how MediaHub Limited, registered at FLAT/RM A 12/F ZJ 300 Lockhart Rd, Wan Chai, Hong Kong (hereinafter — "We", "Us", "Our", "the Company"), collects, uses, stores and protects information when You use our VPN application and related services (the "Service").

This Privacy Policy is an integral part of our Terms of Service. By using the Service, You agree to the information-handling practices described below. If You do not agree with this Policy, please do not use the Service.

For any questions or requests relating to privacy, please contact us at hi@roiperfect.com.

1. Our No-Logs Commitment

We have designed the Service so that Your online activity remains private. We do not record, store or share:

• Your browsing history or details of the websites You visit;
• The content of the internet traffic transmitted through our VPN servers;
• DNS queries made while connected to the Service;
• Your originating IP address after a VPN session has ended;
• Connection timestamps that could be correlated with specific internet activity.

2. What Information We Collect

To operate the Service, process payments and maintain service quality, We collect a limited amount of information.

2.1. Account Information

• An anonymized account or device identifier that is created when the application is installed;
• Your email address, only if You provide it voluntarily, for example when contacting support.

2.2. Subscription and Payment Information

All payments are processed by Apple through the App Store and Google through Google Play using Apple Pay and Google Pay. We never receive or store the full details of Your bank card.

From Apple and Google We receive only the following:

• Subscription status;
• Transaction identifiers;
• Purchase date;
• The identifier of the purchased product;
• Subscription renewal or refund status.

This is the minimum information necessary to provide and manage Your access to the Service.

2.3. Aggregated Usage Data

• Total traffic used by an account. This is an aggregated counter that is not tied to specific websites, addresses or destinations of internet traffic. We use it to prevent abuse, ensure fair use of the Service and determine eligibility for a refund under our refund policy. A full refund may be granted within 7 days if less than 1 GB of traffic has been used.
• Active VPN session status. This is required to control the number of simultaneous connections and to route traffic. Active session data is deleted after the connection ends.
• Server load statistics. This is collected in aggregate and is not linked to specific users.

2.4. App Diagnostics and Device Information

We may collect the following:

• App version;
• Operating system version;
• Device type;
• Device language settings;
• Crash reports and performance diagnostics;
• Whether a VPN connection was successfully established.

Connection-outcome data is used to improve the reliability of our servers in Germany, the United Kingdom and the Netherlands.

2.5. Analytics and Attribution Data

We use third-party software development kits and analytics tools to understand how users find and use the app, and to manage subscriptions:

• Adapty — subscription management and purchase analytics;
• AppsFlyer — install attribution, including identifying the advertising campaign that led to the installation;
• Firebase and other analytics services — this list is kept in line with the tools actually used in the app.

These tools may collect device identifiers such as IDFA or GAID, where You have granted the relevant permission, as well as information about app installation and in-app actions.

On iOS devices, attribution tracking is carried out in accordance with Apple's App Tracking Transparency requirements and only with Your consent.

Analytics data is never linked to Your activity history or to the sites You visit through the VPN.

3. How We Use Your Information

We use the information We collect solely in order to:

• Provide, maintain and operate the VPN service;
• Process and manage Your subscription, including renewals and refunds;
• Enforce our Terms of Service and Acceptable Use Policy;
• Identify technical issues and improve app stability and server performance;
• Assess marketing effectiveness and app performance;
• Respond to Your support requests;
• Comply with legal obligations.

We do not sell Your personal data to third parties and do not use it to display third-party advertising.

4. Legal Bases for Processing (EEA and UK Users)

If You are located in the European Economic Area or the United Kingdom, We process Your data on the following legal bases:

• Performance of a contract — providing the Service You subscribed to;
• Legitimate interests — preventing abuse, ensuring security and improving the Service;
• Consent — processing identifiers for attribution or tracking, for example IDFA via App Tracking Transparency, and sending optional communications;
• Legal obligation — retaining or disclosing information where required by applicable law.

5. Sharing Data With Third Parties

We share information only with the following categories of recipients, and only to the extent necessary to operate the Service:

• Apple and Google — to process payments and manage subscriptions in accordance with their own privacy policies;
• Analytics and attribution providers — the providers listed in Section 2.5, acting as our data processors;
• Hosting and infrastructure providers — organizations that operate our VPN servers in Germany, the United Kingdom and the Netherlands;
• Government and law-enforcement authorities — only upon a valid legal request issued in accordance with the laws of Hong Kong.

Because We do not keep logs of browsing history or internet activity, We have no such records that could be disclosed.

6. International Data Transfers

The Company is registered in Hong Kong, and our VPN infrastructure is located in Germany, the United Kingdom and the Netherlands. As a result, Your data may be processed outside Your country of residence.

For international transfers of data belonging to users in the European Economic Area or the United Kingdom, We apply appropriate safeguards, including standard contractual clauses entered into with our data processors.

7. Data Retention

• Account and subscription information — retained while Your account is active and for up to 12 months after its deletion. Information may be retained longer where required by tax or accounting law.
• Aggregated traffic counters — retained for the current subscription period and the refund-eligibility period.
• Crash reports and diagnostics — retained for up to 90 days.
• Active VPN session data — deleted immediately after the session ends.
• Support correspondence — retained for up to 24 months.

8. Data Security

To protect Your data, We apply generally accepted industry security measures, including modern WireGuard® and OpenVPN encryption protocols, encryption of stored information and strict access controls granted only to authorized personnel.

No method of transmission or storage can guarantee absolute security. Nonetheless, We continuously take measures to protect Your information.

9. Your Rights

Depending on the laws of Your country, including the European Union and UK General Data Protection Regulation and the Hong Kong Personal Data (Privacy) Ordinance, You may have the following rights:

• Access the personal data We hold about You;
• Correct inaccurate or incomplete data;
• Delete Your personal data — the so-called right to be forgotten;
• Restrict processing or object to certain ways of processing Your data;
• Receive Your data in a structured, commonly used and machine-readable format;
• Withdraw consent at any time where processing is based on consent, for example by disabling tracking in Your device settings;
• Lodge a complaint with Your local data protection authority.

To exercise any of these rights, please contact us at hi@roiperfect.com. We will respond to Your request within 30 days.

10. Account and Data Deletion

You may delete Your account and its associated data at any time by one of the following methods:

• Directly in the app, via Settings → Delete Account;
• By emailing hi@roiperfect.com.

After account deletion, the associated data is removed from our active systems, except for information We are required to retain by law, such as transaction records needed for tax purposes.

Subscription cancellation is handled separately through Your App Store or Google Play account settings.

11. Children's Privacy

The Service is not intended for children under 16 years of age, or under any other minimum age established by the laws of the user's country of residence.

We do not knowingly collect personal data from children. If You believe that a child has provided Us with personal data, please contact us. We will promptly delete such information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify You of material changes at least 14 days in advance via push notification and/or by updating the "last updated" date shown at the top of this page.

Continued use of the Service after the changes take effect constitutes Your acceptance of the updated Privacy Policy.

13. Governing Law

This Privacy Policy is governed by the laws of Hong Kong, without limiting any mandatory data protection rights that may be available to You under the laws of Your country of residence.

14. Contact Information