Use Policy

1. Introduction and Scope

1.1. Welcome to EnigmaProxy

("Company," "we," "us," or "our"). We are a Middle Eastern company operating internationally, providing proxy services and data gathering solutions. We value your privacy and are committed to protecting it through our compliance with this policy.

1.2. Privacy Policy (the "Policy")

This Policy is designed to inform you about our practices regarding the collection, use, and disclosure of information that you may provide via our website Enigmaproxy.net (the "Website") and any related services, sales, marketing, or events (collectively, the "Services").

1.3. Applicability of This Policy

This Policy applies to all users of our Services globally, including:

  • Visitors to our Website
  • Registered users of our proxy services
  • Clients utilizing our data gathering solutions
  • Any individual who communicates with EnigmaProxy via email, chat, or other means

1.4. Agreement to This Policy

By accessing or using our Services, you agree to this Privacy Policy. If you do not agree with our policies and practices, your choice is to not use our Services. We encourage you to read this Policy carefully and contact us if you have any questions or concerns.

1.5. Definitions

  • "Personal Data" means any information relating to an identified or identifiable natural person
  • "Processing" means any operation performed on Personal Data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • "User," "you," and "your" refer to the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable.
  • "Cookies" are small text files that websites place on your device to store information about your browsing session and preferences.
  • "Data Controller" refers to EnigmaProxy, which determines the purposes and means of processing personal data.
  • "Data Processor" refers to any entity that processes personal data on behalf of the Data Controller.
  • "Proxy Services" refer to the intermediary server services provided by EnigmaProxy that facilitate requests between users and other servers.
  • "Data Protection Laws" refer to all applicable laws and regulations relating to the processing of Personal Data and privacy.

1.6. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top of this document. We encourage you to review this Privacy Policy periodically for any changes.

2. Information We Collect

2.1. Personal Data

We collect personal data that can be used to identify you, such as:

  • Name
  • Email address
  • Phone number
  • Billing address
  • Payment information (e.g., credit card details, PayPal account)
  • Last-Visit IP Address
  • User account credentials
  • Communication preferences
  • Transaction history
  • Any other information you provide to us directly

2.2. Non-Personal Data

We also collect non-personal data that cannot be used to identify you directly, including:

  • Browser type and version
  • Language preferences
  • Operating system
  • Access times and dates
  • Pages viewed
  • Referring website addresses
  • Exit pages and clickstream data
  • Other technical information about your visit to our Website

3. How We Collect Your Information

3.1. Direct Collection

We collect information directly from you when you:

  • Register for an account
  • Purchase our Services
  • Fill out forms on our Website
  • Correspond with us via phone, email, or chat
  • Participate in surveys or promotions
  • Request technical support
  • Subscribe to our newsletters or marketing communications

3.2. Automated Collection

We automatically collect certain information when you visit, use, or navigate our Website. This information does not reveal your specific identity but may include device and usage information, such as:

  • IP address of last visit
  • Browser and device characteristics
  • Operating system
  • Language preferences
  • Referring URLs
  • Country
  • Location
  • Information about how and when you use our Services
  • Other technical information about your visit to our Website

This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

3.3. Social Media Interactions

If you choose to interact with us on social media platforms, we may collect information from these interactions. This may include:

  • Profile information
  • Interactions with our social media accounts
  • Content you post on our social media pages
  • Information made available by the social media platform based on your privacy settings

Please note that the information you share on social media is subject to the privacy policies of those platforms. We encourage you to review these policies and adjust your privacy settings on these platforms as needed.

4. How We Use Your Information

4.1. Purposes of Use

We use the information we collect for various purposes, including:

  • Providing, maintaining, and improving our Services
  • Processing transactions and sending related information (e.g., confirmations, invoices)
  • Responding to your requests, questions, and feedback
  • Sending you technical notices, updates, security alerts, and support messages
  • Monitoring and analyzing trends, usage, and activities in connection with our Services
  • Detecting, preventing, and addressing technical issues
  • Carrying out our obligations and enforcing our rights arising from any contracts
  • Complying with legal obligations in Middle East and other jurisdictions where we operate
  • Personalizing your experience on our Website
  • Conducting research and analysis to improve our products and services
  • Developing new products, services, features, and functionality
  • Communicating with you about promotions, upcoming events, and other news about products and services offered by us and our selected partners
  • Protecting, investigating, and deterring against fraudulent, unauthorized, or illegal activity
  • Verifying your identity and preventing fraud or unauthorized access to your account
  • Facilitating corporate acquisitions, mergers, or transactions
  • Enforcing our terms and conditions and other usage policies

4.2. Legal Basis for Processing (GDPR and UK GDPR)

a) Consent:

In some cases, we process your data based on your explicit consent, which you can withdraw at any time.

  • Sending you marketing communications
  • Using certain types of cookies
  • Processing sensitive personal data

b) Contractual Necessity:

We process your data to perform our contractual obligations to you or to take steps at your request before entering into a contract. This includes:

  • Providing our proxy services
  • Processing payments
  • Fulfilling orders
  • Providing customer support

c) Legitimate Interests:

We process your data when it is in our legitimate interests to do so and not overridden by your rights. This includes:

  • Improving and personalizing our services
  • Protecting against fraud and unauthorized transactions
  • Marketing our products and services to existing customers
  • Analyzing usage of our services to improve them
  • Enforcing our terms of service

d) Legal Obligation:

We may process your data to comply with a legal obligation, such as:

  • Responding to lawful requests from public authorities
  • Complying with anti-money laundering regulations
  • Reporting security incidents to relevant authorities

4.3. Automated Decision-Making and Profiling

We may use automated decision-making and/or profiling in regard to your personal data for some services and products, for example:

  • To determine the level of risk associated with your account or transactions
  • To determine your eligibility for certain types of proxy services
  • To tailor our marketing communications to your preferences

You can request a manual review of the accuracy of an automated decision if you are unhappy with it. Please see Section 8 for more information about your rights.

5. Disclosure of Your Information

5.1. Disclosure of Aggregated Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. This may include:

  • Statistical data about our users' browsing actions and patterns
  • Data on the usage of certain features of our Services
  • General demographic information

5.2. Disclosure of Personal Information

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To contractors, service providers, and other third parties we use to support our business, including:
    • Payment processors
    • Analytics services
    • Customer support services
    • IT and system administration services
    • Professional advisers including lawyers, bankers, auditors, and insurers
  • To fulfill the purpose for which you provide it
  • For any other purpose disclosed by us when you provide the information
  • With your consent

5.3. Other Disclosures

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request in Middle East or other jurisdictions where we operate
  • To enforce or apply our terms of use https://enigmaproxy.net/tos and other agreements
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of EnigmaProxy, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

5.4. Third-Party Services

We use the following third-party services in our operations:

  • Payment Processing: Cryptomus for Cryptocurrency, Stripe for Card payments
  • Customer Support: [email protected]

These third-party services may have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We implement appropriate contractual and technical safeguards to limit access to your personal data and ensure it is handled consistently with this Privacy Policy.

6. Data Security

6.1. Measures Implemented

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures include:

  • Use of encryption protocols to protect data in transit
  • Storing data on secure servers behind firewalls
  • Regular security audits and penetration testing
  • Employee training on data protection and security practices
  • Regular backups to prevent data loss
  • Multi-factor authentication for accessing sensitive systems
  • Intrusion detection and prevention systems
  • Regular software updates and patch management

6.2. Your Responsibility

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We also recommend using a unique password for your EnigmaProxy account and enabling two-factor authentication where available.

6.3. Security Limitations

Despite our best efforts, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. In the event that we become aware of a security breach that affects your personal data, we will notify you in accordance with applicable laws.

6.4. Proxy Service Security

We implement additional security measures specific to our proxy services, including:

  • Regular rotation of proxy IP addresses
  • Monitoring for abuse and unauthorized access
  • Encryption of proxy traffic where applicable
  • Real-time threat detection and mitigation systems
  • Anonymization of user data in proxy logs
  • Strict access controls for proxy server management
  • Regular security assessments of our proxy infrastructure

6.5. Data Breach Notification

In the event of a data breach that may compromise your personal information, we will:

  • Notify you and the relevant authorities as required by applicable laws
  • Provide details of the breach and steps taken to mitigate any potential risks
  • Offer guidance on how you can protect yourself from potential negative consequences
  • Implement additional security measures to prevent similar incidents in the future

7. Data Retention

7.1. Retention Principles

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements in Middle East and other jurisdictions where we operate.

7.2. Factors Considered

To determine the appropriate retention period for personal data, we consider:

  • The amount, nature, and sensitivity of the personal data
  • The potential risk of harm from unauthorized use or disclosure of your personal data
  • The purposes for which we process your personal data
  • Whether we can achieve those purposes through other means
  • The applicable legal requirements in various jurisdictions
  • The statute of limitations for potential legal claims
  • Industry standards and best practices for data retention

7.3. Specific Retention Periods

Specific retention periods include:

  • Account Information: Retained for the duration of your account plus 1 year after account closure
  • Transaction Data: Retained for 5 years for tax and accounting purposes
  • Marketing Data: Retained until you unsubscribe or ask us to delete this information
  • Communication Records: Retained for 1 year after the last interaction
  • Website Usage Data: Retained in aggregate form for 1 year for analytics purposes

7.4. Anonymization

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes. This anonymized data may be used indefinitely without further notice to you for purposes such as:

  • Improving our services and user experience
  • Conducting market research and analysis
  • Developing new products and features
  • Creating aggregate statistics about our user base and service usage

7.5. Data Deletion

Upon expiration of the retention period, we will securely delete or destroy your personal data using industry-standard methods. This includes:

  • Secure overwriting of digital files
  • Physical destruction of storage media
  • Anonymization techniques that prevent re-identification

7.6. Data Retention Requests

You may request that we retain your data for a longer period in some circumstances (e.g., for legal claims). If you make such a request, we will retain your data for the period you specify unless prohibited by law.

8. Your Legal Rights

8.1. Rights Regarding Your Personal Data

Depending on your jurisdiction, you may have the following rights regarding your personal data:

  • Right to Access: Request a copy of your personal data
  • Right to Rectification: Correct inaccurate or incomplete data
  • Right to Erasure (Right to be Forgotten): Request deletion of your personal data
  • Right to Restrict Processing: Limit how we use your data
  • Right to Object: Oppose processing based on legitimate interests or direct marketing
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Withdraw Consent: Revoke previously given consent for data processing
  • Right to Non-discrimination: Not be discriminated against for exercising these rights

8.2. Exercising Your Rights

To exercise these rights, contact us using the information in Section 10. We'll respond within 30 days, or sooner if required by law. We may need to verify your identity before processing your request.

8.3. Fees and Refusal of Requests

You won't be charged for accessing your personal data or exercising your rights. However, we may charge a reasonable fee or refuse requests that are:

  • Manifestly unfounded or excessive
  • Repetitive (more than two requests in a 12-month period)
  • Require extended technical efforts to fulfill

We will inform you of any fees before proceeding with your request.

8.4. European Union General Data Protection Regulation (GDPR) Rights

EU residents have additional rights under the GDPR, including:

  • Right to Lodge a Complaint: File a complaint with your local data protection authority
  • Right to Object to Automated Decision-Making: Contest decisions made solely by automated systems, including profiling, which produce legal or similarly significant effects on you

8.5. Limitations

We may not be able to fulfill your request if:

  • It would adversely affect others' rights and freedoms
  • The information is necessary for a legal obligation or claim
  • The request is manifestly unfounded or excessive
  • We are legally prohibited from disclosing the information

We will inform you of any limitations that apply to your request.

10. Contact Information

10.1. Privacy-Related Inquiries

Email: [email protected]

10.2. General Inquiries or Support

Email: [email protected]

Telegram: @epboris

10.3. Urgent Matters Related to Data Breaches or Security Incidents

Email: [email protected]

10.4. Media Inquiries

Email: [email protected]

We strive to respond to all inquiries within 48 hours, and sooner for urgent matters.

12. Limitation of Liability

12.1. Security Measures

While we implement robust security measures, no method of data transmission or storage is 100% secure. We can't guarantee absolute security of your information.

12.2. User Responsibility

You transmit personal information at your own risk. We're not responsible for circumvention of privacy settings or security measures on our Website or Services.

12.3. Disclaimer of Liability

To the fullest extent permitted by law, we disclaim liability for any loss, damage, or injury resulting from:

  • Unauthorized access to or use of our servers and other information stored therein
  • Any interruption or cessation of transmission to or from our Services
  • Any bugs, viruses, trojan horses, or the like that may be transmitted to or through our Services
  • Any errors or omissions in any content or for any loss or damage of any kind incurred as a result of the use of any content posted, emailed, transmitted, or otherwise made available via the Services

12.4. Limitation of Damages

In jurisdictions where limitation of liability for consequential or incidental damages isn't allowed, our liability shall be limited to the greatest extent legally permissible.

12.5. Exceptions

This limitation of liability does not affect any liability that cannot be excluded or limited under applicable law, including liability for death or personal injury caused by our negligence or liability for fraud or fraudulent misrepresentation.

15. Governing Law

15.1. Applicable Law

This Privacy Policy shall be governed by and construed in accordance with the laws of Middle East, without regard to its conflict of law provisions. However, this will not deprive you of any mandatory consumer protections under the law of your country of residence, where applicable.

15.2. Data Protection Compliance

For users in the European Union, United Kingdom, and other jurisdictions with data protection laws, we comply with applicable legal requirements providing adequate protection for the transfer of personal data to countries outside of the EEA.

15.3. Dispute Resolution

In the event of any disputes arising from or relating to this Privacy Policy or our data practices:

  • We will attempt to resolve the dispute amicably through negotiations
  • If negotiations fail, the dispute shall be subject to the exclusive jurisdiction of the courts of Middle East
  • For EU users, alternative dispute resolution mechanisms may be available through local data protection authorities

15.4. Applicability of Privacy Policy

This Privacy Policy does not override any applicable national data privacy laws in countries where we operate.

18. Acknowledgment and Acceptance

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms and conditions. We encourage you to review this policy regularly as it may change from time to time.

Last updated: November 11, 2025

For questions or concerns about this Use Policy, please contact us at [email protected]