Terms of Service & Privacy Notice

Version 1.1 · Effective 31 August 2026

In short

This summary is for convenience only and is not part of the agreement. The numbered sections below are what applies.

  • The router is lent to you free of charge and stays our property.
  • We record your email, device identifiers, your current IP address and how many bytes you use. We do not record which websites you visit.
  • We never use your email for marketing.
  • You are responsible for whether using a VPN is lawful where you are.
  • Illegal or prohibited use may result in immediate suspension or termination.
  • We cannot promise the service will work on every network, or that it will get past any particular restriction.
  • The Service is best-effort. We may change, restrict or discontinue it at any time.
  • Payments are generally final. Paying does not buy an uptime guarantee or a guarantee that the Service will remain available throughout the validity period.

1. Who these terms are with

The RaaS VPN service (the “Service”) is operated by RaaS VPN (“we”, “us”, “our”). You can contact us at admin@tmrmedia.com.

By creating an account or using the Service, you agree to these terms. If you do not agree, do not use the Service.

2. What the Service is

A subscription service under which you purchase a specified data allowance, which you may use while the Service remains available and up to the end of its validity period. It consists of: a Wi-Fi router we lend you, encrypted proxy servers we operate, this web portal, and optional client applications for phone and computer.

3. Eligibility and the law where you are

  • You must be at least 18 years old to hold an account.
  • VPN laws differ from country to country. In some places, using or paying for a VPN service is restricted, requires a licence, or carries penalties. You are solely responsible for determining whether your use of the Service is lawful where you are, and you use it at your own risk. We do not advise you on this and cannot do so.
  • Nothing in the Service is intended to encourage you to break any law that applies to you.

4. Your account

  • One account per person. You are responsible for everything done through your account, so keep your password secure and do not share it.
  • Give us an email address you control. We use it for password resets and service notices, and you may miss important messages if it is wrong.
  • We may close an account that has been inactive for more than 12 months, after emailing you first.

5. The router (free hardware)

  • The router is supplied free of charge, on loan. Title to it remains with us at all times. You have the right to use it while your subscription is active.
  • Because you pay nothing for the hardware, it is provided “as is” with no warranty of any kind, and we are not liable for its failure or for any loss arising from it. This is subject to section 15, which we do not exclude.
  • Remote updates. We update the router’s software remotely, automatically, and without asking you each time. You consent to this. Updates are necessary for security and to keep the Service working. An update can, rarely, fail and leave the router unusable. If that happens we will repair or replace the router at our cost. That is the full extent of what we will do in respect of the router, and section 15 applies to any other loss.
  • Do not modify, resell, rent out, or reverse-engineer the router, and do not pass it to anyone else without telling us.
  • If your subscription ends, we may ask for the router back and will pay the return cost. If we have not asked within 60 days, you may keep or dispose of it.

6. Your network and other people using it

The router carries all traffic on the network it serves — every connected device, and everyone in your household or premises who uses that network.

You confirm that you are entitled to control that network, and you agree to tell anyone else who uses it that their traffic passes through this Service.

7. Acceptable use

You must not use the Service to:

  • break any law that applies to you;
  • send spam or bulk unsolicited messages of any kind;
  • attack, scan, probe, overload or gain unauthorised access to any system, including denial-of-service attacks, port scanning, and credential brute-forcing;
  • infringe copyright or other intellectual property rights, including unlicensed sharing or distribution of files;
  • distribute malware, operate phishing pages, or commit fraud;
  • access, store, or distribute child sexual abuse material. We have zero tolerance for this: it means immediate permanent termination without refund and referral to the authorities.
  • harass, threaten, defame or stalk any person;
  • resell, sublicense, share or commercially redistribute the Service without our written agreement;
  • deliberately circumvent quota limits, device limits, or any other technical restriction of the Service.

We may suspend or terminate your account immediately and without refund if we receive a credible report of any of the above, or if a hosting or network provider requires us to act. Where we are legally required to, we may pass the information we hold to that provider or to an authority.

8. Data allowance and how we measure it

  • Each plan provides a specified data allowance which you may use during its validity period, while the Service remains available. Unused data does not carry over and expires at the end of the validity period.
  • We measure traffic at our servers, after encryption. That figure includes encryption and protocol overhead, so it is normally somewhat higher than the figure your own device or router reports. Our measurement is the one that determines your allowance.
  • Usage is collected periodically rather than instantly, so a small amount of use above your allowance may occur before enforcement takes effect. We will not charge you for that overrun.
  • When your allowance or your validity period is exhausted, we stop the encrypted tunnel for that device until you purchase again. The router continues to work as an ordinary router — your internet access is not cut off.

9. Payment and renewal

  • Prices are in Hong Kong dollars. You pay by FPS transfer and upload proof of payment. We review it manually; an automated check may assist, but a person makes the decision.
  • Your subscription starts when we approve the payment, not when you send it.
  • Subscriptions do not renew automatically. Nothing is ever charged to you without you choosing to pay again.
  • The Service is provided on a best-effort basis and without any guarantee of continuous availability, performance, compatibility, or ability to operate on any particular network or in any particular location. Your decision to subscribe is entirely your own, and you should not pay for the Service unless you accept this.
  • All payments are final and non-refundable, except where a refund is required by applicable law. No refund, credit or extension is provided merely because the Service is interrupted, degraded, unavailable on a particular network or in a particular location, or subsequently suspended or discontinued.
  • We may, at our sole discretion, offer a credit or refund in an individual case. Doing so on one occasion does not oblige us to do so again and creates no right for you or anyone else.
  • We may change prices at any time.

10. No guarantees, and withdrawal of the Service

  • The Service is provided “as is” and “as available”, on a best-effort basis and without any guarantee of continuous availability, performance, compatibility, or ability to operate on any particular network or in any particular location. To the fullest extent permitted by law, we exclude all implied terms, conditions and warranties that may lawfully be excluded.
  • There is no uptime guarantee and no service level agreement.
  • We may suspend, restrict, degrade, modify, or discontinue the Service — in whole or in part, for one user or for everyone — at any time and at our discretion, including for operational, security, legal, commercial or technical reasons, with or without notice. This includes shutting the Service down permanently. We will try to give notice where it is practical to do so, but we are not obliged to.
  • We do not promise that the Service will get past any particular network restriction, firewall, or censorship system. Those systems change constantly and are entirely outside our control. The Service may stop working in a given country or on a given network at any time and without notice. The Service being blocked or restricted in those circumstances does not, by itself, constitute a defect or entitle you to a refund or credit, except where required by applicable law.
  • A VPN does not make you anonymous. It hides your traffic from your local network and your internet provider. It does not hide you from services you log in to, and it does not protect you against malware, phishing, or anything happening on your own device.

11. Known limitations

To stop traffic leaking outside the encrypted tunnel, the router deliberately changes how your local network behaves:

  • QUIC (UDP port 443), DNS-over-TLS (port 853) and DNS-over-HTTPS are blocked.
  • IPv6 is disabled on the local network.
  • As a result, some applications, game consoles, smart-home devices and streaming boxes may not work as you expect. This is inherent to how the Service protects you, not a fault.
  • Streaming and other online services may detect and block VPN use. We do not guarantee access to any third-party service.

12. What data we hold

We keep the minimum we need to run the Service.

What we record

  • Your email address — to identify your account, reset your password, and send service notices. We do not use it for marketing and will not send you marketing.
  • Your password — stored only as a bcrypt hash. We cannot read it.
  • Display name and phone number — optional, and only if you choose to give them.
  • Your router’s MAC address and a token derived from it — to identify your router without you having to store credentials on it.
  • Your current public IP address and approximate country — to deliver the Service and select an appropriate server. We keep only the most recent value, not a history.
  • The total number of bytes transferred, per device, over time — for quota and billing.
  • Router firmware version, and diagnostic output when you or we run a diagnostic.
  • Payment records — amount, date, FPS reference, and the payment screenshot you upload.

What we do not record

  • The websites, domains or IP addresses you connect to.
  • Your DNS queries.
  • The content of your traffic.
  • Any browsing history whatsoever.

Our servers are not configured to collect this and we do not hold it. If that ever changes, we will update this notice and tell you before the change takes effect.

How long we keep it

  • Account data — while your account is open, then 12 months after it closes.
  • Payment screenshots — deleted 90 days after the payment is reviewed. The transaction record (amount, date, reference) is kept for 7 years as a business record.
  • Usage records — 13 months.
  • Diagnostic output — 30 days.

Who we share it with

We do not sell your data and we do not share it for advertising. We share it only with the hosting and server providers we need to run the Service, and with authorities where we are legally required to — see section 13.

Your rights

Under the Hong Kong Personal Data (Privacy) Ordinance you may ask us for a copy of the personal data we hold about you, ask us to correct it, or ask us to delete your account and its data. Email admin@tmrmedia.com and we will reply within 40 days.

13. Requests from authorities

  • We respond only to a legally valid request from an authority with jurisdiction over us or over the server concerned.
  • We can only provide what we actually hold, which is listed in section 12. We cannot produce browsing history, because we do not keep any.
  • Where we are legally permitted to do so, we will tell you before we disclose your data.

14. Suspension and termination

  • You may stop using the Service at any time and close your account from the portal.
  • We may suspend or terminate your account for breach of section 7, for non-payment, or where a provider or authority requires it. For serious breaches we act immediately; otherwise we will normally warn you and give you a chance to put it right.
  • If we terminate your account because you breached these terms, you are not entitled to a refund.

15. Our liability

  • Nothing in these terms excludes or limits any liability that cannot lawfully be excluded or limited.
  • Subject to that, and to the fullest extent permitted by law, the Service, the router and related software are provided without liability on our part for loss arising from your use of, or inability to use, them.
  • In particular, to the fullest extent permitted by law, we are not liable for loss arising from: any interruption, degradation, suspension, restriction, modification or discontinuation of the Service; the Service being unavailable or blocked on a particular network or in a particular location; failure of a third-party network or hosting provider; failure of your own equipment; or any action taken by an authority.
  • We are not liable for indirect or consequential loss, or for loss of profit, revenue, business, opportunity, data, goodwill or anticipated savings, to the fullest extent permitted by law.
  • You remain responsible for your use of the Service and for complying with section 7. We are not liable for loss resulting from your unlawful or prohibited use of the Service.
  • Nothing in these terms excludes or limits our liability for death or personal injury caused by our negligence, for fraud or fraudulent misrepresentation, or for any other liability that applicable law does not permit us to exclude or limit.
  • Where liability cannot lawfully be excluded but applicable law permits it to be limited, our aggregate liability arising from the relevant event will, to the fullest extent permitted by law, be limited to the greater of (a) the total amount you paid us during the three months immediately preceding that event, and (b) the amount you paid for the data allowance giving rise to the claim.
  • If any provision of this section is held to be invalid or unenforceable, the remaining provisions continue in full force to the maximum extent permitted by law.

16. Changes to these terms

We may update these terms at any time by publishing a new version here with a new version number. For a material change we will make reasonable efforts to notify you by email. If you do not accept the change, your only remedy is to stop using the Service; no refund or credit is due. Continuing to use the Service after the effective date means you accept the new version.

17. Governing law

These terms are governed by the laws of the Hong Kong Special Administrative Region. You and we submit to the non-exclusive jurisdiction of the Hong Kong courts. Nothing in these terms affects any right you have to bring a claim in the Small Claims Tribunal.

Version 1.1 · Effective 31 August 2026 · Questions: admin@tmrmedia.com

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