1. INTRODUCTION

Prime Solutions, including its operating divisions Prime Computer Solutions & Networking and PrimeFiber Lco., provides Internet, networking, IT, and VPN-related services.

We respect the privacy of our customers and are committed to protecting personal information and maintaining the confidentiality of customer activities to the maximum extent permitted by law.

This Privacy Policy explains:

• What information we collect;

• What information we do not routinely monitor;

• How our VPN service operates from a privacy perspective;

• How information is used and protected;

• When information may be disclosed;

• How we respond to lawful government and law-enforcement requests;

• How we handle abuse and illegal activity;

• How long information may be retained; and

• Your rights and responsibilities as a customer.

By using Prime Solutions VPN services, you acknowledge and agree to this Privacy Policy and the applicable Terms of Service.

2. OUR VPN PRIVACY PRINCIPLE

Prime Solutions is committed to providing VPN services with a strong focus on customer privacy.

We do not routinely monitor customers' Internet activities.

When providing our VPN service, we do not intentionally inspect, read, analyse, profile, or commercially monitor the contents of customers' Internet communications or browsing activities as part of ordinary service operation.

We do not operate our VPN service for the purpose of building advertising profiles based on customers' browsing activities.

We do not sell customers' private Internet activity to advertisers or data brokers.

However, privacy does not mean immunity from law.

We may be legally required to collect, retain, preserve, disclose, or provide certain information to competent authorities where required by applicable law, lawful order, valid legal process, regulatory requirement, cybersecurity requirement, or other legally enforceable direction.

3. IMPORTANT: VPN PRIVACY DOES NOT MEAN ABSOLUTE ANONYMITY

Prime Solutions does not represent or guarantee that use of our VPN service makes a person completely anonymous, untraceable, or immune from identification.

A VPN can provide significant privacy by encrypting traffic between a customer's device and the VPN infrastructure and by masking the customer's originating IP address from websites and other Internet destinations.

However, identification may still be possible through:

• Information held by the VPN provider;

• Customer registration information;

• Payment records;

• Device information;

• Account information;

• Authentication records;

• IP allocation records;

• Network logs;

• Information held by websites or third parties;

• Information held by Internet Service Providers;

• Browser or device fingerprints;

• Cookies or tracking technologies;

• DNS or application-level information;

• Lawful interception or monitoring;

• Information obtained from other service providers;

• Information voluntarily disclosed by the customer; or

• Other technical or legal means.

Accordingly, Prime Solutions does not advertise its VPN service as an “untraceable” service or as a method of avoiding lawful identification.

Our privacy commitment means that we do not routinely monitor customer Internet activity beyond what is necessary for service operation, security, compliance, troubleshooting, billing, and legally required purposes.

4. INFORMATION WE COLLECT FOR VPN SERVICES

To provide VPN services and comply with applicable law, we may collect and maintain certain information.

This may include:

Account Information

• Full name;

• Email address;

• Mobile/telephone number;

• Customer ID;

• Username;

• Account status;

• Service plan;

• Subscription dates;

• Contact information;

• Billing information.

Customer Verification Information

Where required by law or applicable regulatory requirements, we may collect:

• Identity information;

• Address information;

• Government-issued identification;

• KYC information;

• Verified contact information;

• Other information required for customer verification.

Payment Information

We may maintain:

• Payment amount;

• Payment date;

• Transaction ID;

• Invoice information;

• Payment status;

• Billing history;

• Tax information.

Payment processors may separately process payment-card or banking information under their own privacy policies.

Technical Information

Depending on the VPN service architecture and applicable legal requirements, we may process:

• IP addresses used to register or access the service;

• IP addresses allocated to or used by customers;

• Connection/authentication information;

• Login and logout timestamps;

• Service activation and termination information;

• Device or client information;

• Technical diagnostic information;

• Security logs;

• Network infrastructure logs;

• Error logs;

• Abuse and security-event information.

5. VPN TRAFFIC MONITORING

Prime Solutions does not routinely monitor or inspect the content of customer VPN traffic for ordinary commercial purposes.

In particular, we do not intentionally use routine VPN traffic inspection to:

• Read customers' private communications;

• Monitor individual browsing histories for advertising;

• Sell browsing activity;

• Build commercial profiles based on browsing activity;

• Intentionally track every website visited by a customer; or

• Sell customers' Internet activity to third parties.

However, technical systems may automatically generate certain operational or security information necessary to operate and protect the VPN infrastructure.

Examples may include:

• Authentication events;

• Connection events;

• Error logs;

• Security events;

• Abuse indicators;

• Network performance information;

• Infrastructure health information.

The existence, type, retention period, and availability of such technical records may vary depending on our infrastructure, service configuration, security requirements, and applicable law.

6. NO GUARANTEE OF ZERO LOGGING

Prime Solutions does not describe its VPN service as a legally guaranteed “zero-log” or “completely log-free” service.

This is because certain information may be required to be collected or retained under Indian law and regulatory requirements.

For example, applicable CERT-In directions concerning VPN service providers require specified subscriber/customer information to be maintained, including validated customer information, period of service, IP information, registration information, purpose of hiring, address/contact information, and ownership information, with specified retention requirements.

CERT-In directions also contain requirements relating to ICT-system logs and cybersecurity incident reporting.

Accordingly, our privacy promise should be understood as:

We do not routinely monitor customers' private Internet activities for commercial purposes, but we will collect, retain, preserve, or disclose information where required by applicable law, security requirements, or valid legal process.

7. LAWFUL DISCLOSURE TO AUTHORITIES

Prime Solutions respects customer privacy.

At the same time, we do not provide our VPN service for the purpose of enabling criminal activity, evading lawful investigation, hiding illegal conduct, or obstructing law enforcement.

If we receive a legally valid request, order, notice, warrant, summons, statutory direction, or other legally enforceable demand from a competent authority, we may be required to disclose information available to us.

Depending on the circumstances, this may include:

• Customer registration information;

• KYC information;

• Account information;

• Subscription information;

• Payment information;

• IP address information;

• Connection information;

• Authentication records;

• Technical logs;

• Security or abuse records;

• Other information lawfully available to us.

We will disclose only information that:

1. We possess or control;

2. We are legally required or authorised to disclose; or

3. Is otherwise necessary to comply with applicable law.

Where legally permitted, we may challenge or seek clarification of an invalid, overbroad, or improperly issued request.

8. LAW ENFORCEMENT AND ILLEGAL ACTIVITIES

Prime Solutions does not support, encourage, facilitate, or authorise the use of its VPN services for unlawful activities.

Prohibited activities include, but are not limited to:

• Child sexual abuse material (CSAM);

• Sexual exploitation of children;

• Human trafficking;

• Illegal drug trafficking or sale;

• Illegal weapons or ammunition trading;

• Terrorist activity;

• Financing of terrorism;

• Fraud;

• Phishing;

• Identity theft;

• Malware distribution;

• Ransomware;

• Cyberattacks;

• Unauthorised access to computer systems;

• Hacking;

• Credential theft;

• Distribution of stolen data;

• Financial crimes;

• Extortion;

• Blackmail;

• Distribution of illegal material;

• Copyright infringement where unlawful;

• Online scams;

• Botnet operation;

• Abuse of telecommunications infrastructure;

• Threats or harassment involving criminal conduct; and

• Any other activity prohibited by applicable law.

The examples above are illustrative and do not limit the scope of prohibited unlawful activity.

9. CHILD SEXUAL ABUSE MATERIAL

Prime Solutions has a strict prohibition against using its services to create, possess, request, access, distribute, transmit, advertise, promote, exchange, or otherwise facilitate child sexual abuse material.

Under Section 67B of the Information Technology Act, 2000, various activities involving electronic material depicting children in sexually explicit or obscene conduct are criminal offences.

Prime Solutions will cooperate with competent authorities in relation to legally valid investigations involving child exploitation, child sexual abuse material, or other serious offences.

Where legally required, we may preserve and disclose relevant information available to us.

10. OTHER SERIOUS CRIMINAL ACTIVITY

Prime Solutions may take appropriate action where its services are used for serious unlawful activities.

Depending on the circumstances, actions may include:

• Investigation of an abuse report;

• Suspension of an account;

• Restriction of access;

• Termination of an account;

• Preservation of relevant records;

• Disclosure of information to competent authorities;

• Cooperation with lawful investigations; and

• Other measures permitted or required by law.

We may take immediate action where necessary to protect our infrastructure, customers, employees, the public, or the security of our systems.

11. ACCOUNT TERMINATION FOR ILLEGAL OR ABUSIVE USE

Prime Solutions reserves the right to suspend, restrict, or terminate a VPN account where we reasonably believe that the account:

• Is being used for unlawful activity;

• Is being used for serious abuse;

• Is being used to attack or compromise computer systems;

• Is being used for fraud;

• Is being used to distribute malware;

• Is being used for child exploitation;

• Is being used for illegal drug or weapon trafficking;

• Is being used for terrorism or other serious criminal activity;

• Violates applicable law;

• Violates our Terms of Service; or

• Creates a significant security or operational risk.

Where appropriate and legally permitted, we may notify the customer.

However, we may restrict or terminate an account without prior notice where immediate action is reasonably necessary for security, legal, regulatory, fraud-prevention, or abuse-prevention reasons.

12. LAW ENFORCEMENT REQUESTS ARE NOT LIMITED TO “SOLID EVIDENCE”

Customers should understand that Prime Solutions does not require law enforcement to provide us with a criminal conviction before we comply with a lawful request.

Where a competent authority provides a legally valid order, notice, warrant, statutory direction, or other legally enforceable request, we may be required to comply regardless of whether a criminal case has already resulted in a conviction.

We may also preserve information where legally required to prevent destruction or alteration of relevant records.

13. LAWFUL INTERCEPTION AND MONITORING

Prime Solutions may be subject to applicable telecommunications and information-technology laws concerning lawful interception, monitoring, information disclosure, cybersecurity, and cooperation with authorised agencies.

The Telecommunications Act, 2023 and the Telecommunications (Procedures and Safeguards for Lawful Interception of Messages) Rules, 2024 establish a legal framework for lawful interception by authorised agencies under specified procedures and safeguards.

Nothing in this Privacy Policy prevents Prime Solutions from complying with a lawful interception, monitoring, preservation, disclosure, or assistance requirement imposed by a competent authority.

Where legally permitted, we will maintain customer confidentiality regarding such requests.

Where disclosure of the existence of an investigation or request is prohibited, we will not notify the affected customer.

14. CYBERSECURITY AND CERT-IN REQUIREMENTS

Prime Solutions may be subject to cybersecurity requirements issued under applicable Indian law, including directions issued by the Indian Computer Emergency Response Team (CERT-In).

CERT-In's directions under Section 70B of the Information Technology Act include requirements concerning cybersecurity incident reporting, maintenance of ICT logs, and specified information relating to VPN service customers.

Accordingly, we may collect, retain, preserve, or disclose information necessary to comply with applicable CERT-In requirements.

Where a legal or regulatory requirement conflicts with a general privacy commitment in this Policy, the applicable legal requirement will prevail.

15. DATA RETENTION FOR VPN SERVICES

We retain personal and technical information only for as long as reasonably necessary or required by applicable law.

Retention periods may depend on:

• The type of information;

• The nature of the service;

• Security requirements;

• Contractual requirements;

• Tax and accounting obligations;

• Customer disputes;

• Fraud investigations;

• Cybersecurity investigations;

• Legal proceedings;

• Government requirements;

• Telecommunications requirements;

• CERT-In requirements; and

• Other applicable legal or regulatory requirements.

Certain VPN customer information may be required to be retained for periods prescribed by CERT-In or other applicable authorities.

Where applicable CERT-In requirements prescribe retention for VPN service provider customer information, we will comply with those requirements.

After the applicable retention period expires, information may be securely deleted, anonymised, or otherwise disposed of, unless continued retention is required or permitted by law.

16. SECURITY OF VPN INFRASTRUCTURE

We implement reasonable technical and organisational measures designed to protect VPN infrastructure and customer information.

Measures may include:

• Access controls;

• Authentication mechanisms;

• Firewalls;

• Network segmentation;

• Secure server configurations;

• Encryption where appropriate;

• Security monitoring;

• Vulnerability management;

• Administrative access restrictions;

• Logging and auditing;

• Backup and recovery procedures;

• Incident response procedures; and

• Other security measures appropriate to the service.

No Internet-based service can guarantee absolute security.

Customers acknowledge that no VPN provider can guarantee protection against every possible technical attack, compromise, endpoint infection, browser fingerprinting technique, malware infection, or other security threat.

17. VPN ENCRYPTION

Where our VPN service provides encrypted VPN tunnels, encryption is used to protect traffic between the customer's device and the relevant VPN endpoint according to the protocols and configurations supported by the service.

VPN encryption does not necessarily encrypt traffic after it leaves the VPN server.

For example, if a customer accesses a website using HTTPS, the website's HTTPS encryption provides an additional layer of protection between the customer and that website.

Customers should keep their devices, operating systems, browsers, applications, and security software updated.

18. INFORMATION FROM THIRD PARTIES

We may receive information from:

• Payment providers;

• Hosting providers;

• Network providers;

• Upstream Internet providers;

• Fraud-prevention services;

• Cybersecurity providers;

• Government authorities;

• Law-enforcement agencies;

• Business partners;

• Customer support platforms; and

• Other service providers.

We may process such information where necessary to provide services, protect security, investigate abuse, comply with law, or perform other legitimate and legally permitted activities.

19. PAYMENT INFORMATION

VPN subscriptions may be processed through third-party payment gateways, banks, UPI providers, card processors, or other payment services.

We may receive transaction information such as:

• Transaction ID;

• Amount;

• Date;

• Payment status;

• Customer/account reference;

• Refund information.

Payment providers may separately process sensitive payment information under their own terms and privacy policies.

20. COOKIES AND WEBSITE TECHNOLOGIES

Our website may use cookies and similar technologies to:

• Maintain website functionality;

• Maintain security;

• Remember preferences;

• Analyse website performance;

• Understand website usage;

• Detect abuse;

• Improve services; and

• Provide requested features.

Third-party services integrated with our website may also use cookies or similar technologies.

Customers can manage cookies through their browser settings.

21. DATA SHARING

We do not sell or rent customers' personal information or private VPN activity to advertisers or data brokers.

We may share information with service providers and authorities where reasonably necessary for:

• Providing the service;

• Processing payments;

• Customer support;

• Network infrastructure;

• Security;

• Fraud prevention;

• Legal compliance;

• Regulatory compliance;

• Cybersecurity;

• Law enforcement;

• Accounting;

• Legal advice;

• Auditing; or

• Other legitimate operational purposes.

Third-party service providers may be subject to confidentiality and security requirements.

22. GOVERNMENT AND REGULATORY AUTHORITIES

We may disclose information to:

• Government authorities;

• Law-enforcement agencies;

• Courts;

• Regulatory authorities;

• CERT-In;

• Department of Telecommunications;

• Cybercrime authorities;

• Tax authorities;

• Security agencies;

• Other competent statutory authorities.

Disclosure will occur where required or authorised by applicable law or valid legal process.

23. DATA PROTECTION AND DPDP ACT

To the extent applicable and in force, we process digital personal data in accordance with the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025.

The DPDP framework establishes obligations concerning lawful processing, security safeguards, data principals' rights, consent where applicable, grievance redressal, and other matters.

Because the DPDP Act's provisions have been brought into force through a phased commencement framework, the rights and obligations applicable to a particular processing activity will depend on the provisions in force at the relevant time.

24. USER RIGHTS

Subject to applicable law, customers may have rights including:

• Requesting access to relevant personal information;

• Requesting correction of inaccurate information;

• Requesting updating of information;

• Requesting deletion where legally permitted;

• Withdrawing consent where processing is based on consent;

• Filing privacy-related grievances;

• Exercising other rights available under applicable law; and

• Exercising nomination rights where provided by applicable law.

These rights are subject to legal and regulatory exceptions.

For example, we may be unable to delete information where we are legally required to retain it.

25. INTERNATIONAL USERS

Our primary operations are in India.

Where customers access our services from another jurisdiction, additional privacy laws may apply depending on the circumstances.

Where applicable, such laws may include:

• GDPR;

• UK GDPR;

• CCPA/CPRA; or

• Other applicable local privacy laws.

Where such laws legally apply to our processing activities, we will seek to comply with applicable requirements.

Nothing in this Policy is intended to provide contractual rights beyond those required by applicable law.

26. CHILDREN

Our VPN services are not intended to be used by children without appropriate parental or legal supervision.

We do not knowingly collect unnecessary personal information from children.

Where applicable law requires parental consent or additional safeguards, we will comply with those requirements.

Our services must never be used to access, create, distribute, request, possess, or facilitate child sexual abuse material.

27. ACCEPTABLE USE

Use of Prime Solutions VPN services must comply with applicable laws and our Terms of Service.

Customers must not use the service to:

• Commit crimes;

• Attack computer systems;

• Distribute malware;

• Conduct phishing;

• Steal credentials;

• Commit fraud;

• Conduct illegal drug transactions;

• Conduct illegal weapons transactions;

• Facilitate terrorism;

• Exploit children;

• Distribute CSAM;

• Conduct unauthorised surveillance;

• Conduct unlawful harassment or threats;

• Operate malicious botnets;

• Conduct unauthorised network intrusion;

• Distribute stolen personal information;

• Circumvent lawful restrictions for criminal purposes; or

• Otherwise violate applicable law.

Use of a VPN for legitimate privacy, security, remote work, research, lawful access to information, or protection against insecure networks is permitted subject to our Terms of Service and applicable law.

28. PRIVACY DOES NOT MEAN PERMISSION TO COMMIT CRIMES

Prime Solutions strongly supports the legitimate right to privacy and secure communications.

However, privacy technology must not be interpreted as permission to commit unlawful acts.

We provide VPN services to help customers improve privacy and security, not to facilitate criminal activity.

We will protect customer privacy to the maximum extent legally permitted while cooperating with lawful investigations and complying with mandatory legal requirements.

29. ACCOUNT SUSPENSION AND TERMINATION

We may suspend or terminate VPN services if:

• The customer violates our Terms of Service;

• The account is involved in unlawful activity;

• The service is used to attack or compromise infrastructure;

• The account presents a serious security risk;

• Payment obligations are not met;

• The customer provides materially false information;

• A competent authority requires suspension or termination;

• Continued service would violate applicable law; or

• Other circumstances permit termination under the customer agreement.

Where legally permitted, customers may be notified of termination.

We may withhold details of an investigation where disclosure would compromise an investigation, violate law, or create a security risk.

30. DATA BREACHES AND SECURITY INCIDENTS

If we become aware of a security incident involving personal information, we will investigate and take reasonable steps to contain, mitigate, and remediate the incident.

Where applicable law requires notification to customers, authorities, regulators, or other parties, we will make such notification in accordance with the applicable legal requirements.

Cybersecurity incidents may also be subject to CERT-In reporting and preservation requirements.

31. LEGAL CLAIMS AND DISPUTES

We may retain information necessary to:

• Establish or defend legal claims;

• Investigate disputes;

• Enforce agreements;

• Recover unpaid amounts;

• Respond to legal notices;

• Comply with court orders;

• Protect our rights; or

• Comply with applicable law.

Such information may be retained beyond ordinary operational retention periods where legally permitted or required.

32. CORPORATE TRANSACTIONS

If Prime Solutions or any relevant business division is involved in a merger, acquisition, restructuring, sale, transfer, or other corporate transaction, customer information may be transferred as part of that transaction where legally permitted.

Any such transfer will remain subject to applicable privacy, confidentiality, security, and legal requirements.

33. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

• Changes in our VPN services;

• Changes in technology;

• Changes in our data-processing practices;

• Changes in applicable law;

• Changes in regulatory requirements;

• Changes in cybersecurity requirements; or

• Changes in our business operations.

The updated policy will be published on our website with a revised “Last Updated” date.

34. GRIEVANCE AND PRIVACY CONTACT

For privacy-related questions, complaints, data requests, or concerns, contact:

Grievance Officer:
Sarath A J

Organisation:
Prime Solutions

Operating Divisions:
Prime Computer Solutions & Networking
PrimeFiber Lco.

Email: info@primetekasia.com

Phone: +91 62828 33783

Address:
GX1, Ground Floor, Prime Building,
NREP Road, Aroor Gram Panchayat,
Kerala – 688534, India

We will handle privacy-related grievances within the timeframe required by applicable law and regulations.

35. CONTACT INFORMATION

Prime Solutions
Including:

Prime Computer Solutions & Networking
IT & Networking Division

PrimeFiber Lco.
ISP Unit

Email: info@primetekasia.com
Phone: +91 62828 33783
Website: www.primetekasia.com

Address:
GX1, Ground Floor, Prime Building,
NREP Road, Aroor Gram Panchayat,
Kerala – 688534, India

36. FINAL PRIVACY COMMITMENT

Prime Solutions believes that customers should be able to use privacy and security technologies without unnecessary surveillance.

Accordingly, our VPN service is designed around the principle that:

We do not routinely monitor our customers' private Internet activities for commercial purposes.

We do not sell customers' private VPN activity to advertisers or data brokers.

At the same time:

We do not guarantee absolute anonymity or untraceability.

We will comply with applicable Indian law, valid legal processes, lawful government and regulatory requirements, cybersecurity requirements, and legally binding orders.

Where information is lawfully required from us, we will provide the information that we possess or control and are legally required or authorised to disclose.

Our commitment is therefore:

Maximum privacy within the limits of applicable law, responsible operation of our VPN infrastructure, and zero tolerance for using our services to facilitate illegal activity.

Effective Date: 7 August 2026
Last Updated: 7 August 2026