The main difference between EntityProxy and ValueProxy is that EntityProxy have an "identity": there's an ID that can be used to map to a given "entity" on the server. This is what enables the use of deltas (because you can retrieve the entity the diff should be applied to) but that's a bonus feature, not a "discriminator".
In other words: to be able to benefit from "deltas", your data must first be "identifiable". If that's the case, then you have the choice of EntityProxy vs. ValueProxy (and I'd rather go for EntityProxy). Otherwise, you have no choice but using ValueProxy.