Privacy Policy
1. Introduction
WLX Limited (“WLX”, “we”, “us”, or “our”) respects your privacy and is committed to protecting personal data. This Privacy Policy explains how we collect, use, disclose, store, and protect personal data when you visit our website, create an account, use our customer portal, purchase services, submit tickets, communicate with us, or use WLX infrastructure and connectivity services.
This Privacy Policy applies to personal data processed by WLX in connection with our services, including VPS/VDS, dedicated servers, colocation, IP transit, BGP connectivity, LIR coordination, IP resource services, ASN-related services, support, billing, and related technical services.
2. Controller
For personal data processed for WLX’s own business purposes, WLX Limited is the data controller.
Where WLX processes personal data on behalf of a customer through infrastructure services, the customer may be the controller and WLX may act as processor or service provider, depending on the circumstances and applicable law.
3. Personal Data We Collect
We may collect the following categories of personal data:
1. Account information: name, username, company name, job title, contact person, email address, phone number, billing address, service address, customer ID, and account credentials.
2. Verification and compliance information: identity documents, business registration information, tax information, beneficial ownership information, network use-case information, sanctions screening results, fraud prevention information, abuse history, and other KYC/KYB information where required.
3. Billing and payment information: invoices, payment status, payment method details, transaction identifiers, payment processor references, tax records, and billing correspondence. We generally do not store full payment card numbers unless expressly stated.
4. Service information: ordered services, IP addresses, prefixes, ASN-related information, routing details, port information, VLAN information, colocation details, equipment information, power usage, bandwidth usage, reverse DNS information, WHOIS/RDAP or registry-related data, LOA and RPKI-related records.
5. Technical and log data: IP addresses, browser type, device identifiers, operating system, referrer URL, timestamps, login records, customer portal activity, API activity, server logs, ticket metadata, abuse logs, routing logs, traffic statistics, monitoring alerts, security events, and diagnostic information.
6. Communications: support tickets, email messages, contact form submissions, chat records, call notes, abuse complaints, legal notices, and other communications with WLX.
7. Customer content and service data: data, files, systems, packets, logs, configurations, or content transmitted, stored, routed, or processed through WLX services, to the extent technically accessible or necessary for providing, securing, supporting, investigating, or complying with legal obligations related to the services.
4. How We Collect Personal Data
We collect personal data:
1. directly from you when you register, order, pay, submit tickets, contact us, or provide information;
2. automatically through our website, customer portal, monitoring systems, security systems, logs, cookies, and similar technologies;
3. from payment processors, fraud prevention providers, identity verification providers, registries, RIRs, LIR-related partners, upstream providers, datacenter partners, carriers, and other suppliers;
4. from public sources, routing databases, WHOIS/RDAP, IRR, RPKI, sanctions lists, abuse databases, and other compliance or network security sources;
5. from third parties who submit abuse complaints, security reports, legal notices, or service-related information.
5. Purposes of Processing
We process personal data for the following purposes:
1. to create and manage customer accounts;
2. to process orders, provision services, perform technical review, and deliver infrastructure and connectivity services;
3. to issue invoices, process payments, manage taxes, handle refunds, and collect unpaid amounts;
4. to provide customer support, technical assistance, service notices, maintenance notices, and administrative communications;
5. to manage IP addresses, ASN-related services, routing, BGP, LIR coordination, RPKI, IRR, reverse DNS, WHOIS/RDAP, LOA, and registry-related processes;
6. to monitor service performance, network stability, security, abuse, capacity, uptime, and operational integrity;
7. to detect, prevent, investigate, and respond to fraud, spam, malware, phishing, DDoS, route hijacking, unauthorized access, policy violations, and other abuse;
8. to comply with laws, sanctions, export controls, court orders, regulator requests, law enforcement requests, registry policies, upstream requirements, datacenter rules, and contractual obligations;
9. to improve our website, services, security, support, billing, and customer experience;
10. to send service-related messages, policy updates, security notices, billing reminders, and, where permitted, marketing communications;
11. to establish, exercise, or defend legal claims.
6. Legal Bases for Processing
Depending on the applicable law and context, we process personal data based on one or more of the following legal bases:
1. performance of a contract with you or steps taken before entering into a contract;
2. compliance with legal obligations;
3. our legitimate interests, including service operation, network security, fraud prevention, abuse handling, billing, business administration, and legal protection;
4. your consent, where required for specific processing such as certain marketing communications or optional cookies;
5. protection of vital interests or public interests, where applicable.
If you are located in the European Economic Area, United Kingdom, or another jurisdiction requiring a specific legal basis, we rely on the relevant legal basis under applicable data protection law.
7. Cookies and Similar Technologies
Our website and customer portal may use cookies, session tokens, local storage, analytics tools, security tools, and similar technologies.
We use these technologies to:
1. keep you logged in;
2. remember preferences;
3. operate shopping cart and order functions;
4. secure the website and customer portal;
5. detect fraud and abuse;
6. understand website performance and usage;
7. improve our services.
You can control cookies through your browser settings. Disabling cookies may prevent some website or customer portal functions from working properly.
8. Server Logs and Security Logs
When you access our website, customer portal, or services, we may automatically collect server logs and security logs, including IP address, browser type, operating system, referrer URL, access time, request details, login activity, session identifiers, and security event information.
We use logs for security, troubleshooting, abuse prevention, service operation, analytics, and legal compliance. Log retention periods vary depending on operational, security, legal, and compliance needs.
9. Customer Portal, Registration, and Support Tickets
When you register for an account or use our customer portal, we collect the information required to create and manage your account, verify your identity or business, provide services, issue invoices, process support tickets, and maintain account security.
Support tickets and communications may contain technical details, personal data, credentials, configuration data, screenshots, logs, and other information submitted by you. You should avoid submitting sensitive personal data unless necessary for the support request.
10. Service Data and Customer Content
WLX generally does not actively review customer content hosted, stored, or transmitted through infrastructure services. However, WLX may access, process, preserve, or disclose customer content or service data where reasonably necessary to:
1. provide, maintain, secure, or troubleshoot the services;
2. respond to support requests;
3. investigate abuse, security incidents, or policy violations;
4. comply with legal obligations, lawful requests, registry requirements, upstream requirements, or datacenter requirements;
5. protect WLX, customers, users, networks, facilities, or third parties.
You are responsible for ensuring that personal data you upload, transmit, host, or process through WLX services is collected and processed lawfully.
11. Disclosures of Personal Data
We may disclose personal data to:
1. WLX employees, contractors, affiliates, and authorized personnel who need access for business purposes;
2. payment processors, banks, accounting providers, tax advisors, and billing service providers;
3. datacenters, upstream providers, carriers, network partners, hardware vendors, software vendors, support vendors, and monitoring providers;
4. registries, RIRs, LIR-related partners, WHOIS/RDAP providers, IRR/RPKI systems, and IP/ASN-related authorities where needed for network resource services;
5. fraud prevention, identity verification, sanctions screening, security, DDoS mitigation, and abuse handling providers;
6. courts, regulators, law enforcement agencies, government authorities, registries, upstream providers, facilities, and other parties where required or permitted by law, contract, or policy;
7. professional advisors, insurers, auditors, and legal representatives;
8. potential or actual buyers, successors, investors, or counterparties in a merger, acquisition, financing, restructuring, or sale of assets.
We do not sell personal data in the ordinary sense. If applicable law defines “sale” or “sharing” broadly, you may have additional rights described in the “Your Rights” section.
12. International Transfers
WLX may process and transfer personal data in Hong Kong and other jurisdictions where WLX, its customers, suppliers, datacenters, carriers, registries, or service providers operate.
Data protection laws in these jurisdictions may differ from those in your jurisdiction. Where required, WLX uses appropriate safeguards for cross-border transfers, such as contractual protections, data processing agreements, or other lawful mechanisms.
13. Data Retention
We retain personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, including service delivery, billing, tax, accounting, dispute resolution, abuse prevention, security, compliance, legal claims, and recordkeeping.
Typical retention considerations include:
1. account and billing records may be retained for legal, tax, accounting, and audit purposes;
2. support tickets may be retained for service history, dispute resolution, and security purposes;
3. logs may be retained for security, abuse prevention, troubleshooting, and legal compliance;
4. verification and compliance records may be retained as required for fraud prevention, sanctions compliance, or legal obligations;
5. customer content may be deleted after service termination, cancellation, suspension, or expiration according to applicable service policies.
Retention periods may be extended where required for legal proceedings, investigations, unpaid balances, abuse history, security incidents, or regulatory obligations.
14. Security
WLX uses reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.
However, no internet-based service, hosting environment, transmission method, or storage system can be guaranteed to be completely secure. You are responsible for protecting your credentials, securing your systems, maintaining backups, applying patches, and configuring your services securely.
15. Your Rights
Depending on your location and applicable law, you may have rights to:
1. access personal data we hold about you;
2. correct inaccurate or incomplete personal data;
3. delete personal data;
4. restrict or object to processing;
5. receive a copy of your personal data in a portable format;
6. withdraw consent where processing is based on consent;
7. opt out of certain marketing communications;
8. complain to a data protection authority.
To exercise your rights, contact us at [Insert privacy/legal email]. We may need to verify your identity before responding. Some rights may be limited by legal, security, billing, tax, abuse prevention, contractual, or technical requirements.
16. Marketing Communications
We may send marketing communications where permitted by law or with your consent where required. You may opt out of marketing emails by using the unsubscribe link or contacting us.
Even if you opt out of marketing communications, we may continue sending service-related, security-related, billing-related, legal, and administrative messages.
17. Children
WLX services are intended for business and technical users and are not directed to children. We do not knowingly collect personal data from children under the age required by applicable law. If you believe a child has provided personal data to us, please contact us.
18. Third-Party Links and Services
Our website, customer portal, or communications may contain links to third-party websites, services, registries, payment processors, social media platforms, or documentation. We are not responsible for the privacy practices, content, or security of third-party services.
19. Customer Obligations
If you use WLX services to process personal data of your own users, customers, employees, or other individuals, you are responsible for:
1. providing required privacy notices;
2. obtaining required consents;
3. establishing a lawful basis for processing;
4. responding to data subject requests;
5. implementing appropriate security measures;
6. entering into a data processing agreement with WLX where required;
7. complying with applicable data protection laws.
20. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Updated versions will be posted on our website or customer portal. The effective date will indicate when the latest version applies.
Your continued use of WLX services after the effective date means you acknowledge the updated Privacy Policy.
21. Contact Us
For privacy questions, requests, or complaints, contact:
WLX Limited
Room 39, 3/F, 143 Wai Yip Street
Kwun Tong, Hong Kong
Email: [email protected]
Website: https://wlx.ee
Tuesday, June 9, 2026
