Effective and last updated: 12 October 2026
This Privacy Policy applies to the ZTProxy website, dashboard, APIs, customer support and related proxy-network services operated by PHOENIX BLAZENET SOLUTIONS LIMITED (香港鳳凰網絡科技有限公司, “we”, “us” or “our”). We process personal data in accordance with Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486).
1. Data we collect
Account and contact data, such as username, email address, telephone number, referral relationship, account role and contact information you provide.
Order and transaction data, such as products purchased, usage, order status, payment amounts, ledger records, digital-asset transaction identifiers and refunds. We do not collect full payment-card numbers through this website.
Service and technical data, such as login and access IP addresses, device and browser information, timestamps, API requests, bandwidth and usage, proxy-authentication events, error logs, and security or abuse-investigation records.
Communications, such as content submitted through email, Telegram, tickets or other support channels.
Cookies and similar technologies used to maintain sessions, remember language and security preferences, protect sign-in state and understand basic website operation.
2. Purposes and whether data is required
We use data to create and administer accounts, deliver proxy services, process orders and payments, display usage and balances, provide support, secure our network and accounts, prevent fraud and abuse, comply with legal duties and improve our services.
Data identified as required for registration, authentication, billing or order fulfilment is necessary to provide the relevant service. If you do not provide it, we may be unable to create an account, complete a transaction or provide the requested feature. Other data is generally voluntary.
We will not use personal data for a new purpose unrelated to the original collection purpose unless we obtain consent or applicable law permits the use.
3. Sharing and processors
We may provide the minimum data necessary to service providers that support cloud hosting, content delivery, security, databases, communications, customer support, analytics, payment processing or digital-asset transaction verification.
To deliver proxy resources, we may exchange non-identifying account mappings, technical configurations and order parameters with network-infrastructure or resource providers. We should not send your registration email, telephone number, site login password or real name to upstream providers unless legally required and separately notified to you.
We may disclose data when necessary for legal process, regulatory requirements, protection of users or the public, fraud investigation, or the establishment and defence of legal rights. We do not sell personal data.
4. Cross-border processing
Our services and providers may operate outside Hong Kong. Data may therefore be processed or stored in other jurisdictions. We apply reasonable contractual, access-control and security measures appropriate to the data and transfer only what is necessary for the relevant purpose.
5. Retention, accuracy and deletion
We retain data only for as long as needed for the purposes described in this policy, contract performance, dispute handling, security, and accounting, tax or legal obligations. When no longer required, we take reasonably practicable steps to delete, anonymise or restrict use of the data.
Certain order, accounting, security and audit records may be retained longer where required by law or necessary to establish, exercise or defend legal rights.
6. Security
We use technical and organisational measures proportionate to risk, including access controls, transport protection, logging, credential separation, backups and security monitoring. No internet transmission or storage system is completely secure, and we cannot guarantee that all risk will be eliminated.
Protect your account password, API credentials and proxy credentials. Change them and contact us promptly if you suspect compromise.
7. Direct marketing
If we propose to use personal data for promotional communications, we will obtain any consent required by applicable law and provide an opt-out. You may stop direct marketing at any time through the unsubscribe method provided or by contacting support. Service and security notices are not marketing.
8. Access, correction and other requests
You may request access to or correction of personal data we hold, and may ask for deletion, processing restriction or withdrawal of consent. Requests may be limited by statutory exemptions, identity verification, record-retention duties or the need to perform the service.
Send requests to [email protected] with enough information to verify your identity and locate the relevant data. We may charge a reasonable fee for processing a data-access request where permitted by law.
9. Minors
The service is not intended for persons under 18. If we learn that we collected a minor’s personal data without appropriate authorisation, we will take reasonable steps to delete it.
10. Updates and contact
We may update this policy when our services, technology or legal obligations change. We will give reasonable notice of material changes through the website, dashboard or another appropriate channel and update the date on this page.
Data user: PHOENIX BLAZENET SOLUTIONS LIMITED (香港鳳凰網絡科技有限公司). Email: [email protected]. Correspondence address: UNIT E35 ON 3RD FLOOR SUPERLUCK INDUSTRIAL CENTRE (PHASE 2) NO.57 SHA TSUI ROAD TSUEN WAN NEW TERRITORIES HONG KONG.