Privacy Policy

Last Updated: [ ] 2025

Only available in Malaysia, Thailand, Philippines, Indonesia, Singapore, Hong Kong SAR, Macau, Japan and Republic of Korea

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to Hiispii (“Service”) a gaming network accelerator applicationthat does network acceleration, network diagnostics and network channel scanning to optimize mobile networks. If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Ltd..

For the information that we collect from you directly, we act as a data controller. This Privacy Policy only applies to the information we collect from you directly and your information that we process whilst you use the Service.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

*What information do we need to be able to provide the Service?*	· In order to provide you with the Service, we will collect some information from you directly via your use of the Service, including your account credentials, device and network information.	More Information.
*How will we use your information?*	· We use your information to provide you with the Service.	More Information.
*Who do we share your information with?*	· Where applicable, we use third parties and work with our affiliates to help us deliver the best possible experience such as enabling you to login via third party social media platforms. · All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., to fulfil the purpose(s) described above). · In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.	More Information.
*Where do we process your information?*	· We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. · Our server for the Service is in Singapore. We also have support, engineering and other teams who may support the Service, including from the People’s Republic of China (“PRC”).	More Information.
*How long do we keep your information?*	· Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Service, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.	More Information.
*How can I exercise my rights over my information?*	· Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.	More Information.
*How will we notify you of changes?*	· Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.

Welcome to Hiispii!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with Hiispii, a network acceleration application (the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Service. If you use any other products or services please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging how we process your personal information as described in this Privacy Policy.

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Ltd., a Singapore registered company located at 10 Anson Road, #21-07 International Plaza Singapore 079903. (“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer here. We have representatives for data protection purposes listed here.

1. Children

Children must not use the Service for any purpose. By children, we mean users under the age of 18 years old or the legal minimum age in your jurisdiction.

2. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. It also identifies the legal basis which we rely on to process your personal data, to the extent required under applicable data protection laws.

Personal Information	Use	Legal Basis (where applicable)
Information you provide to us or which is generated as part of the Service
Network acceleration information: · Device information: Device model, operating system, device identifier (e.g. android ID); · Network information: IP address, domain name and other network status related information (WiFi information and router address); and · Game information: name of target game, target game size, target game version number.	We use this information to perform network acceleration when you play the game.	Necessary to perform the contract with you to provide the Service.
Payment information: OpenID, RoleID, country, device information and model, SDK version, application version network type, country, currency, amount and IDFV.	We use this information to enable you to make in-app purchases for the Service via Apple/Google Pay.	Necessary to perform the contract with you to provide the Service.
Account login information: · OpenID; and · If you login using your email / phone number: email address, telephone number and country code · If you sign up via third party social media platforms (e.g. QQ, WeChat, Apple, Google): your social media ID (e.g. QQ ID, WeChat ID, Apple ID, Google ID)	We use this information to enable you to sign up and automatically login to the Service.	Necessary to perform the contract with you to provide the Service.

3. How We Store and Share Your Personal Information

We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. We have servers for the Service in Singapore. We also have support, engineering and other teams who may support the Service, including from the PRC.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Third parties that provide services in support of the Service. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., for the purpose(s) described above).

· Companies within our corporate group who process your personal information solely for the purpose of providing the Service to you. All such group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:

enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

4. The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.

5. Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
Network acceleration information	Stored for the lifetime of your use of the Service or deleted within 14 days of your account deletion request, whichever is earlier.
Payment information	Stored for the lifetime of your use of the Service or deleted within 30 days of your account deletion request, whichever is earlier.
Account login information	Stored for 90 days from the date of your last login or deleted within 30 days of an account deletion request, whichever is earlier.

6. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.

Access

You may have the right to access personal information we hold about you, how we use it, and who we share it with.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.

Correction

You may have the right to correct personal information we hold that is inaccurate.

Erasure

You may be able to request for the deletion of your personal information. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, contact us, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.

7. Contact

You can reach us using our online form here to submit Data Subject Requests (“DSAR”) and any questions or concerns related to data privacy.

Mailing Address:

Tencent International Privacy & Data Protection Centre

30 Raffles Place #19-01

Singapore

048622

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

8. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

9. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.

Our Representatives in Certain Jurisdictions

Jurisdiction

Representative

Address

Contact details

Thailand

Tencent (Thailand) Company Limited

8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand

DSAR Form

Republic of Korea

Kite Bird Korea Yuhan Hoesa

25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea

DSAR Form

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Indonesia

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

In the event we fail to maintain the confidentiality of your personal information in the Service, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information, in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

By accepting the Privacy Policy, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

The categories of personal information specified in Section 2 (How We Process Your Personal Information) may include "special care-required personal information" (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us.

Macau

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Service to you. As a Macau data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However, this may affect our provision of the Service to you.

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Our data protection officer, responsible for the management and safety of your personal information

Telephone: +603-22872388
Email: as set out in the section 7 (Contact)

Philippines

You are entitled to the following rights:

Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

By consenting to this Privacy Policy, you consent to us:

collecting and processing your personal information as described in the section (How We Process Your Personal Information);
sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and

transferring or storing your personal information in destinations outside the Philippines as described in the section 3 (How We Store and Share Your Personal Information)

Republic of Korea

Collection and Use of Personal Information

We collect your personal information for the purposes described in this Privacy Policy. Personal information that we collect from Republic of Korea is stored in and processed on our server located in Singapore.

With regards to the legal basis of processing personal information included in Section 2 “How We Process Your Personal Information,” the following legal provisions under the PIPA applies:

- (consent): we use this information pursuant with your consent, pursuant to Article 15(1)(1) of the PIPA.

- (complying with legal obligations): we use this information where necessary to comply with a legal obligation pursuant to Article 15(1)(2) of the PIPA.

- (contractual necessity): we use this information where necessary to perform our contract with you to provide our Services, pursuant to Article 15(1)(4) of PIPA.

Third-Party Provision of Personal Information

We provide your personal information to third parties as described below:

Legal Grounds

Name of Recipient (and contact information)

Types of Personal Information provided

Purpose of Use by Recipient

Period of Retention and Use by Recipient

[PIPA Art. 17(1)(2), 15(1)(6) necessary for legitimate interests]

Apple Inc.

https://www.apple.com/legal/privacy/

Google Inc.

https://policies.google.com/privacy

Payment information

Allow you to make in-app purchases using Apple or Google Pay

In accordance with each of the third party’s privacy policies.

Delegation of Personal Information

For the performance of the services detailed in this Privacy Policy, we delegate the processing of your personal information to the following professional service providers:

Delegatee	Description of Delegated Services
Aceville Pte. Ltd.	Storage of personal information
Shenzhen Tencent Computer System Co. Ltd.	System operation and maintenance support

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

*Legal Grounds*	*Recipient (Contact Information of Information Manager)*	*Country or Region to which Your Personal Information is to be Transferred*	*Date and Method of Transfer*	*Types of Your Personal Information to be Transferred*	*Purposes of Use by Recipients*	*Period of Retention of Use by Recipient*
PIPA Art. 28-8(1)(3) Delegation and Retention for Contractual Performance	Aceville Pte. Ltd. (cloudlegalnotices@stencent.com)	Singapore	Transferred via information and communications network at the time of service use	All personal information collected	Storage of personal information	For the data retention period specified under “Data Retention”
PIPA Art. 28-8(1)(3) Delegation and Retention for Contractual Performance	Shenzhen Tencent Computer System Co. Ltd. (meeting_info@tencent.com)	PRC	Transferred via information and communications network at the time of service use	All personal information collected	System operation and maintenance support	For the data retention period specified under “Data Retention”
PIPA Articles 28-8 (1)(1), 17(1)(1) (Consent of Data Subject)	Google Inc. https://policies.google.com/privacy Apple Inc. https://www.apple.com/legal/privacy/	United States	Transmitted if user wishes to use Apple Pay or Google Pay to make in-app purchase	Payment information	In-app purchase	In accordance with each of the third party’s privacy policies.

You may refuse the overseas transfer of your personal information by contacting our Data Protection Department. If you refuse the overseas transfer of your personal information, your personal information will not be transferred overseas. However, you may not be able to use our services for which overseas transfer of personal information is necessary.

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed in section “Data Retention”. With the exception of the personal information set out below, personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

The personal information detailed in section “Data Retention” are required to be retained pursuant to the following laws:

Act on the Consumer Protection in Electronic Commerce, Etc.

Article 6 of the Act on the Consumer Protection in Electronic Commerce

In an electronic commerce or a mail-order sale:

· Records regarding labelling and advertising (6 months)

· Records regarding execution or withdrawal of a contract (5 years)

· Records regarding the payment of a price and the supply of goods and services (5 years)

· Records regarding customer services or dispute resolution (3 years)

Protection of Communications Secrets Act

Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications Secrets Act

· Log records, IP address (3 months)

· The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

Your Rights

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion, or suspension of processing of your personal information, or objecting to or requesting an explanation on an automated decision concerning your personal information, etc. pursuant to applicable laws such as the Personal Information Protection Act (“PIPA”). You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA. You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Additional Use and Provision of Personal Information

In accordance with the PIPA, we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc. We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information. Pursuant to Articles 15(3) and 17(4) of the PIPA, we consider the following factors set forth in Article 14-2 of the Enforcement Decree of the PIPA when using or providing to a third party additional personal information without your consent:

whether the additional use/provision is related to the initial purpose of the collection;
whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;
whether the additional use/provision unfairly infringe on the interests of the data subject; and
whether the necessary security measures such as pseudonymization or encryption were taken.

Measures to Ensure Safety of Personal Information

We implement the following measures to ensure safety of your personal information:

1. Managerial measures: establishment and implementation of internal management plan, operation of dedicated organization, regular employee training

2. Technical measures: management of access rights to the personal information processing system, installation of an access control system, encryption of personal information, and installation and renewal of security programs

3. Physical measures: access control of computer rooms, data storage rooms, etc.

Contact

Data Protection Department, responsible for the management and safety of your personal information
Telephone: +82-2-2185-0926
Email: specified in Section 7 (Contact)

Remedies for Infringement of Rights and Interests

In order to seek remedies for personal information infringement, you may file an application for dispute resolution or consultation with the Personal Information Dispute Mediation Committee, the Korea Internet & Security Agency's Personal Information Infringement Reporting Center, etc. In addition, you may contact the following institutions for other reports and consultations on personal information infringement:

1. Personal Information Dispute Mediation Committee: (no area code required) 1833-6972 (www.kopico.go.kr)

2. Personal Information Infringement Report Center: (no area code required) 118 (privacy.kisa.or.kr)

3. Supreme Prosecutors’ Office: (no area code required) 1301 (www.spo.go.kr)

4. National Police Agency: (no area code required) 182 (ecrm.cyber.go.kr)

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in the section (How We Store and Share Your Personal Information).

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in the section (Contact).

Thailand

By clicking "accept", you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the Service.

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

· withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;

· request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;

· request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or

· lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us as set out in the section (Contact).

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in the section (Contact) and can be contacted via email. Please include the word “Thailand” in the subject line of your email.