PERSONAL DATA THAT WE COLLECT

Personal data is information, or a combination of pieces of information that could reasonably allow the person to be identified. We will collect certain personal data about you and your end users as required by law, or because of our contractual relationship. Failure to provide this information may prevent or delay the fulfilment of these obligations.
We may collect the following categories of personal data from and about you:

1. Account information: we may process identity information that you provide to us when registering for an account or using our services, such as your real name, nationality, nickname, phone number, email address, and your account password.

2. Information we collect automatically from you including internet or other electronic network activity information, such as your IP address, network type;

3. Cookie information. Like many websites, we use web log information, along with cookies, pixels, and similar technologies, to operate our Sites, better understand how they are used, resolve technical problems, and enhance your experience on our website. We use strictly necessary Cookies that are required for the operation of our website, for example, Cookies that enable you to log into our website.
You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. If you choose to refuse, disable, or delete Cookies, some of the functionality of the website may no longer be available to you.

We may collect the following categories of personal data from and about your end users:

1. Device identifiers which we collect automatically from your end users including: device ID, Android ID, GAID and other device identifiers assigned by Publishers, Advertisers, or our Partners.

2. Device information which we collect automatically from your end users including: device model, operating system, network connection type (e.g., WiFi, cellular). system language and region.

3.Location information: latitude and longitude as communicated by the device. We only get rough location, not exact location.

HOW WE USE PERSONAL DATA AND THE BASIS ON WHICH WE USE IT

We may use your and your end users’ personal data for the following purposes:

1. identification and authentication: we use your personal data to verify your identity and create a profile for you when you register with us, access and use our services, or otherwise engage with us, and to ensure the security of your personal data. This is necessary to provide the requested service;

2. contractual obligations: we use your personal data to meet our contractual obligations to you under our terms and conditions of use or to take steps at your request prior to entering such contract;

3. service operations: we process your and your end users’ personal data to provide the Services that you request, such as the advertising service;

4. service improvements: we analyse usage information, including site analytics, to continually improve the user experience;

5. communications: communications may include providing information about changes to the terms and conditions, updates regarding our services, or responses to questions you pose;

6. advertising and marketing: we may use you and your end users’ personal data to build a profile, to understand preferences, and to help determine which marketing materials would be of interest to you and your end users. Where required by law, we will obtain your consent before sending such marketing materials;

7. exercising our rights: we may use you and your end users’ personal data to exercise our legal rights where it is necessary to do so, for example to detect, prevent, and respond to intellectual property infringement claims or violations of law;

We must have a legal basis to process your personal data, as specified under applicable laws. In most cases the legal basis will be one of the following:

1. as consented by you in respect of this Policy;

2. to fulfil our contractual obligations to you, for example to provide the services you request;

3. to comply with our legal obligations, for example to obtain proof of your identity to enable us to meet our fraud prevention and anti-money laundering obligations;

4. where permitted under applicable laws, to meet our legitimate interests, for example:
to understand how you use our services and to enable us to derive knowledge that enables us to develop new services;
to carry out data analysis to ensure the stability and security of our Services and prevent crime, fraud and misuse of our Services; fraud and misuse of our Services;
to provide non-personalised advertising, which keeps most of our services free; and to improve user experience.
When we process personal data to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected;

5. we may obtain your separate consent to collect and use certain types of personal data when we are required to do so by law (for example, in relation to our direct marketing activities). If we ask for your consent to process your personal data, you may withdraw your consent at any time by contacting us using the details at the end of this Notice; and

6. as otherwise may be permitted under applicable laws.

Please confirm that you have obtained your end user's legal authorization for the purpose and scope of our processing of your end user's personal information.

HOW AND WHEN WE SHARE PERSONAL DATA

We may share your and your end users’ personal data as follows:

1. With advertisers and advertising demand partners for use in furtherance of their business purposes, including to show how many users of the App have clicked on that advertisement; to choose the best ad for you on our mobile advertising exchange and across the broader advertising ecosystem. etc...

2. With our affiliate companies, joint venture partners, and other partners or collaborators for the purposes of processing, analysing, or storing you and your end users information or otherwise as needed to provide the services to you or achieve other purposes for which we collect information, in each case, consistent with the terms of this Policy.

3. With law enforcement agencies, courts, other government authorities (whether in your jurisdiction or abroad) or other third parties where we or any of our affiliates believe it's necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.

4. With potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer you and your end users’ personal data to use it in a manner consistent with this Policy.

INTERNATIONAL DATA PROCESSING & TRANSFER

Where permitted under applicable laws, your personal data may be transferred to, stored, and processed outside of your jurisdiction, including, if you are an EU or UK-based user of the Services, in a country that is not regarded as ensuring an adequate level of protection for personal data under European Union law / by the European Commission or under UK law / by the UK Government, including Singapore.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protection for your personal data. For more information on the appropriate safeguards in place, please contact us at the contact information below.

DATA SECURITY AND RETENTION

We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data. We evaluate these measures on a regular basis to ensure the security of the processing.

We retain you and your end users’ personal data for as long as we have a relationship with you. After our relationship has ended, we retain the information as long as required by law. We may also retain records to investigate or defend against potential legal claims, deal with any complaints or official enquiries or investigations regarding the Services, or maintain business records for analysis and/or audit purposes.

YOU AND YOUR END USERS’ RIGHTS OVER PERSONAL DATA

You and your end users have certain rights regarding the personal data we hold about you and your end users, subject to local law. These may include the following rights:

1. access – request a copy of you and your end users’ data and information relating to how it is processed;

2. rectify – request any inaccuracies in the data we hold about you and your end users be corrected;

3. erase – request that we erase you and your end users’ data from our records;

4. restrict – request that you and your end users’ data is no longer processed by us to the full extent set out in this Policy;

5. object – object to certain ways that we process you and your end users’ data;

6. transfer – request that you and your end users’ data be shared with a third party;

7. withdraw consent – where we are relying on the consent to process you and your end users’ data, then you and your end users’ can withdraw the consent at any time; and

If you and your end users would like to discuss or exercise any rights may have under law, please contact us at the contact details below.

CHILDREN'S INFORMATION

The Services are not directed to children, and we do not knowingly collect any personal data from children under the age of 13 (or such legally required age of consent as defined under applicable laws) or knowingly allow such person to register on our Services. In the event that we are notified that we have collect personal data from a child of or under the age of 13 (or such legally required age of consent as defined under applicable laws) without parental consent, we will suspend the account and delete relevant information as quickly as possible.

Please ensure that you do not provide our services to children.

CONTACT US

If you and your end users have questions or concerns regarding the way in which personal data has been used or would like to exercise any right, please contact us at: bdpm@ushareit.com.

We are committed to working with you（you and your end users） to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country of residence.

CHANGES TO THE NOTICE

We may modify or update this Policy from time to time.

If we change this Notice, we will notify you of the changes. Where changes to this Notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing) or to terminate your use of the Services. You are obligated to notify your end users synchronously.