Revision 3.1 · Last Updated: August 22, 2026

This Ethics Policy (the “Policy”) sets forth the core principles for the responsible and good-faith use of the Proxyma services provided by PROSOX LLC (the “Company,” “we”). This Policy supplements the Company’s Terms of Service, Privacy Policy, and other applicable Company documents. In the event of any conflict, the terms of the applicable binding agreement or the requirements of applicable law shall govern. Capitalized terms not defined in this Policy shall have the meanings assigned to them in the Terms of Service.

1. Lawful and Ethical Access to Data

1.1. The Services are intended for lawful access to internet resources and the collection of data to which the user is entitled to access. The mere fact that information is publicly available or technically accessible does not, in itself, mean that no restrictions apply to its collection, use, storage, or further dissemination.

1.2. The user shall take into account applicable law, the rights of third parties, the terms of use of the relevant internet resources, and requirements relating to confidentiality, personal data protection, intellectual property, and other mandatory restrictions.

1.3. It is prohibited to use the Services to obtain or attempt to obtain unauthorized access to protected resources, accounts, restricted data, or systems, including by circumventing authentication, access controls, or other technical restrictions, unless such action is authorized by the resource owner or applicable law.

2. Good-Faith Use of the Services

2.1. The following actions are prohibited when using the Services, where such actions are directed at:

• impairing the operability, security, or availability of the Company’s systems, networks, sites, applications, or Services;
• creating an excessive or manifestly malicious load, conducting denial-of-service attacks, unauthorized vulnerability scanning, or otherwise interfering with the operation of third-party infrastructure;
• password cracking, credential stuffing, account takeover, or circumventing CAPTCHA or other protective mechanisms for purposes of unauthorized access;
• distributing malicious software, phishing, fraud, spam, or other misleading or unlawful activity;
• infringing copyrights, trademark rights, database rights, trade secrets, or other rights of third parties;
• unlawfully collecting, profiling, selling, disclosing, or otherwise using personal or sensitive data;
• harassment, discrimination, unlawful surveillance of individuals, or causing harm to them;
• obtaining, storing, distributing, or facilitating the distribution of child sexual abuse material, or any other exploitation of minors;
• circumventing sanctions, export control, AML/KYC, or other mandatory legal restrictions applicable to the user or to the specific use of the Services.

2.2. The user shall not conceal an unlawful purpose for using the Services, impersonate another person or organization, or use the Company’s infrastructure in a manner that may create the false impression that the Company endorses the relevant activity.

3. Personal Data and Confidentiality

3.1. Where the use of the Services involves the processing of personal data, the user shall independently determine the existence of a lawful basis for such processing and shall comply with applicable data protection principles, including purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality.

3.2. The user shall not use the Services for the targeted collection of special categories of personal data, data relating to minors, or other sensitive information in the absence of an appropriate legal basis and the necessary safeguards.

3.3. The Company may apply technical and organizational measures aimed at preventing abuse, investigating incidents, and protecting the rights of users, network participants, the Company, and third parties, to the extent permitted by applicable law and contractual terms.

4. Consent of Network Participants

4.1. Network resources used within the infrastructure of the Proxyma residential and mobile proxies shall be provided by network participants on the basis of proper, informed, and revocable consent (opt-in) or another permissible legal basis, where expressly required by the applicable connection model and applicable law.

4.2. Network participants shall be provided with clear information regarding the nature of their participation, the principal consequences of providing network resources, and the available means of terminating participation, as further described in the applicable Privacy Policy and related notices.

5. User Responsibility and Account Security

5.1. The user shall be responsible for actions performed using its account, API keys, credentials, and other access means provided to it, unless otherwise required by mandatory provisions of applicable law.

5.2. The user shall take reasonable measures to protect its credentials and shall promptly notify the Company of any suspected unauthorized access, key compromise, or other misuse of the Services.

6. Abuse Monitoring and Response Measures

6.1. The Company may review reports of potential abuse and, where reasonably warranted, request additional information from the user regarding the nature of its use of the Services.

6.2. Where there are reasonable grounds to believe that the Services are being used in violation of this Policy, the Terms of Service, or applicable law, the Company may restrict, suspend, or terminate access to the Services in the manner provided for in the contractual documents and applicable law.

6.3. Reports of suspected abuse of the Services may be sent to: abuse@proxyma.io. Inquiries regarding privacy and personal data: privacy@proxyma.io.

7. Transparency and Responsible Provision of Services

7.1. The Company endeavors to provide clear information about the Services, their principal characteristics, and the applicable restrictions. Trial access, where provided, is intended for the preliminary assessment of technical compatibility and an appropriate scope of use, and does not waive the requirements of this Policy.

7.2. The Company may enhance its technical and organizational anti-abuse measures, including in light of the nature of the Services, identified risks, and changes in applicable law.

8. Amendments to the Policy

8.1. The Company may periodically update this Policy. The current version is published on the website, indicating the date of the last update. Where amendments materially affect the rights or obligations of users, the Company may provide additional notice in the manner provided for in the Terms of Service or applicable law.

9. Language and Contacts

9.1. This Policy is published in Russian for the convenience of users. The primary, legally authoritative, and controlling version is the English-language version. In the event of any discrepancy, difference in interpretation, or conflict between the English version and this translation, the English version shall prevail to the extent permitted by applicable law.

9.2. For inquiries regarding this Policy: privacy@proxyma.io. Abuse reports: abuse@proxyma.io.

PROSOX LLC (State of Delaware, USA) · Proxyma is a service of PROSOX LLC · Global presence: USA, Hong Kong, and Da Nang, Vietnam · Hong Kong contact address: SUITE C, LEVEL 7, WORLD TRUST TOWER, 50 STANLEY STREET, CENTRAL, HONG KONG · Vietnam contact address: 229 Chinh Huu Street, An Hai Ward, Da Nang City · privacy@proxyma.io · abuse@proxyma.io · https://proxyma1.io · © 2026 PROSOX LLC. All rights reserved. PROXYMA® is a trademark of PROSOX LLC.