Privacy Policy

SUPERADS INTERNATIONAL TECHNOLOGY LIMITED and its affiliate companies (“we”, “us”, “our” or “SUPERADS”) respect your privacy. This privacy policy explains who we are, how we collect, use and share personal information through SUPERADS Services and our corporate website www.superads.cn, and how you can exercise your privacy rights.

1. INTRODUCTION

SUPERADS is an ad network providing a technology platform (“Platform”) for Clients who want to advertise and/or monetize their applications, games, and other products. Our “Clients” include “Advertisers” that wish to distribute ad content through the SUPERADS Platform, and “Publishers” of applications and/or websites that want to display relevant ads to end users (“End Users”) of third party applications (“apps”) and/or websites that use our Software Development Kit (“SDK”), Application Programming Interface (“API”), hosted video advertising platform and/or any of our related advertising tools (collectively, the “SUPERADS Services”).

2. PRIVACY POLICY FOR THE SUPERADS SERVICES

This Section describes how SUPERADS collects and uses information we receive form End Users (“you” or “your”) of apps and/or websites that use the SUPERADS Services.

2.1 Information We Collect

When you visit an app or website that uses SUPERADS Technology, we may collect certain device information including the following: The SUPERADS SDK version; IP Address; the Google Advertising ID on Android devices (“GAID”); ID For Advertising (“IDFA”); International Mobile Equipment Identity (IMEI); Device make and model; Device properties related to screen size & orientation, audio volume and battery, device memory usage; Time zone and timestamp; Network connection type and speed; the name and version of the app to which the ad is served; Limit ad tracking status; Operating system name and version; Timestamp; The name of the manufacturer of the device; The language of the operating system; The name of the mobile carrier; Internet browser user-agent used to access the Service; An indication if you viewed or clicked on an ad.

Some of this information (including for example, your IP address and certain unique identifiers), may identify a particular device and may be “personal data” in some jurisdictions. Note, however, that SUPERADS Services do not collect any information that that enables us to identify End Users personally (such as your name, address, or email address).

We may also combine, merge, and/or enhance the information we collect about your device, including the personal data, with information we may collect about your interactions with other Publisher Client's Apps and ads served through SUPERADS's Platform, or with information collected from our Clients and third parties (such as data providers). This may include, for example, mobile device IDs, demographic or interest data, and content viewed or actions taken on an app to help make the ads served to you more relevant while limiting your exposure to less relevant ads. We (or our third party partners) may also use this additional information to undertake “user matching”, which means that in addition to the ID an End User has been assigned in our system, we may also receive a list of unique IDs our external partners or Clients have assigned to an End User.

2.2 How We Collect Your Information

Depending on the nature of your interaction with the SUPERADS Services, or any service provided by SUPERADS's Clients, we may collect information directly from such User or from our business partners (e.g. mobile application developers, Ad Exchange platforms, and advertisers).

We may collect User's Information while Users: (i) view ads served by the SUPERADS Services;(ii) interact with the SUPERADS Services; or (iii) interact with platforms, applications, websites or other services provided by SUPERADS's business partners (e.g. app publisher, advertiser).

We collect information as described in this privacy policy for SUPERADS's own purposes, as a data controller under data protection law where relevant, except ads otherwise indicated herein.

2.3 How We Use Your Information

We use the information we collect (sometimes in combination with information provided and sourced by independent validation partners) for a variety of business purposes. For example, we use the personal information we collect for the following purposes:

Serving Ads – We use the Information collected from your device to serve ads on app developers’ apps, and technically enable the delivering of ads to your device.

Reporting, billing and attribution – We use your Information to generate reports for our publishers and bill advertisers and publishers, including for ensuring that if you interacted with our ads, we will receive payment for our service.

Internal Operations – We use your Information for internal operations, such as debugging, support, security, and improving our services.

Fraud detection and prevention – We use your Information for detecting and preventing fraud, and for ensuring viewability of our ads.

Optimization and frequency capping – We use your Information for optimizing advertising campaigns, including for limiting the number of times you view a specific campaign across our network, or the number of ads you view in a specific app.

Personalized advertising – Our corporate affiliates and advertisers may use your Information for personalized advertising (i.e. ads that are based on your interest or profile).

Optimizing advertising campaigns – We optimize campaigns for our advertisers based, for example, on events that happen in their app or indications of installs received from other apps.

Suppression – We use Advertising IDs of users of an advertiser's app in order not to serve advertising campaigns of such advertiser to such users, as they already have the advertiser's app.

Whitelisting/blacklisting – We allow advertisers to upload lists of device IDs to include/exclude in their advertising campaigns.

2.4 How do We Use Tracking Technologies to Collect Information

We use standard tracking technologies to collect information automatically from your device so that our backend operations can use it to perform many of the functions described in Section 2.3 above. To opt out of our use of such technologies, please follow the instructions for opting out in the apps, as described in Section 2.5 below.

2.5 Your Opt-Out Choices

You can opt out of having your information being used by SUPERADS for performance-based advertising by accessing your mobile device settings. Please following the below instructions:

iOS devices – go to Settings > Privacy > Advertising > enable Limit Ad Tracking. Please note that if you use more than one device, you need to opt-out separately in each device.

Android devices – Please follow the instructions set forth at:https://support.google.com/ads/answer/2662922?hl=en. Please note that if you use more than one device, you need to opt-out separately in each device. Note that if you reset your advertising ID through your device's platform settings, you should follow the steps above to reset your opt-out choice. In addition, opting out may not stop data from being collected from your device or transferred for other, non-personalized advertising purposes such as optimization, reporting, frequency capping, internal operations, and fraud prevention. If you become aware of any third party that received your Ad Network Information from us, and that does not respect your choices, please let us know by contacting us via email privacy@superads.cn.

If you limit ad tracking, you will still see advertisements (even ones sourced from SUPERADS's network), but SUPERADS will no longer be able to use the personal information described above in Section 2.1 to serve you with more relevant ads. In addition, the advertising identifier (along with any information collected about that identifier) that was previously assigned to you will also be disassociated. This means that if at a later stage, you decide to opt back in, we will not be able to use any of your past information, and you will for all practical purposes be a new user to our system. You may also stop the collection of location information by particular apps by changing the preferences on your mobile device.

2.6 Privacy Practices of SUPERADS Clients.

SUPERADS is not responsible for the information practices of our Clients. We require our Clients to comply with all applicable laws and regulations and to provide End Users with notice of the collection of data for advertising purposes as outlined in this Notice. We encourage you to review the privacy policies of apps you visit for information about those apps’ data collection and use practices.

2.7 Children

Our Clients are responsible for ensuring that their mobile apps comply fully with applicable children's data privacy protection legislation, such as the United States’ Children's Online Privacy Protection Act (“COPPA”), including where relevant by obtaining parental consent prior to the collection of personal information. With respect to COPPA specifically, we rely upon our Publisher Clients to confirm whether or not their app is subject to COPPA. As required by COPPA, SUPERADS will enable a flag in our system such that the End User's device history is disassociated, and the only End User “personal information” used by the SUPERADS Services would be Publisher-specific unique digital identifiers (e.g., IP address and device identifiers) to support SUPERADS's internal operations.

We do not collect or otherwise process personal data from individuals in the European Economic Area, the United Kingdom, and Switzerland whom we know to be under 16 years of age, except to comply with law or to support our legitimate interests or the legitimate interests of our app developers as described above.

If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us via email at privacy@superads.cn. We will take reasonable steps to ensure that such information is deleted from our files.

3. PRIVACY POLICY FOR THE SUPERADS WEBSITES

This Section describes how we collect and use Information in the usual course of business, including through our websites (such as www.superads.cn or any other website on which this privacy policy is posted) and other corporate services, web portals, and dashboards we make available to our Clients and End Users (collectively “Websites”), as well as in connection with our events, sales and marketing activities.

3.1 Information We Collect

Information that you provide voluntarily:Certain parts of our Websites may ask you to provide personal information voluntarily. For example, when registering for a SUPERADS account, expressing an interest in obtaining additional information about SUPERADS or our products and services, subscribing to marketing or otherwise contacting us, SUPERADS collects personal information from you. The personal information that you are asked to provide (and the reasons why you are asked to provide it) will be made clear to you at the point we ask you to provide your personal information. We will also let you know prior to collection whether the provision of personal information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information.

Information we collect automatically:When using our Websites, we may automatically collect certain information from your device. In some countries, including countries in the EU, this information may be considered personal data under data protection laws. Specifically, the information we collect automatically may include your IP address, your operating system, your browser ID, your browsing activity, and other information about your system and connection, and how you interact with our Websites and other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies.

Information we collect from third party sources:We may obtain information about you from other sources, such as public databases, joint marketing partners, data providers and social media platforms. Examples of the information we receive from other sources include account information, page-views, and browsing information.

3.2 How We Use Your Information

Send you marketing and promotional communications.For example, we and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. However, you will always be able to opt-out of our marketing at any time.

Send administrative information to you. For example, to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.

Engage in and process transactions. For example, we may use your personal information along with financial, credit card, and/or payment information that you provide to us to process your transactions and for billing purposes.

Respond to your requests.For example, we may use your personal information to fulfill your request for a quote or customer support, or to provide you with information you have requested about the Websites or SUEPRADS Services.

Post testimonials. We post testimonials on the Websites that may contain personal information. Prior to posting a testimonial, we will obtain our consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at privacy@superads.cn and be sure to include your name, testimonial location, and contact information.

Manage your account and provide support or other services.For example, for the creation or administration of your SUEPRADS account, to communicate with you, and to provide you with customer support or other services you have ordered, such as product updates, product patches and fixes and other similar operational communications.

Select content and improve quality.We may use your information to help improve the Website, SUPERADS Services, and to ensure that content on the Websites is presented in the most effective manner for your device (for example, by presenting products and offers tailored to you).

Protect the SUPERADS Websites.We may use your information as part of our efforts to keep the Websites safe and secure (for example, for fraud monitoring and prevention).

For our business purposes.We may use your information for our business purposes, such as data analysis, audits, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our products, services, marketing, and client relationships.

3.3 Cookies and Similar Tracking Technologies

We use cookies and similar tracking technology (collectively “Cookies”) on our Websites to collect and use personal information about you, including to serve interest based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice: This website uses cookies for analytics and advertising purposes. At any time, you can change your cookie preferences using your browser's settings. By continuing to browse, you agree to our use of cookies. To find out more about Cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

4. GENERAL INFORMATION

4.1 How do We Share Your Information

We may disclose your personal information to the following categories of recipients:

Advertiser Clients. If you are an End User, we may share information we collect in connection with the SUPERADS Services with our Advertiser Clients for purposes relevant to our business relationships with them, such as for billing purposes, dispute resolution, or fraud prevention, and to help them identify and/or buy our Publisher Client's advertising inventory. Our Advertiser Clients are obligated to use the information they receive in compliance with applicable laws and regulations.

Attribution Partners. Acting on behalf of our Advertiser Clients, if you are an End User, we may share your information (such as your mobile device ID) with our Advertiser Clients’ attribution partners to validate and measure the success of ads delivered via the Platform for billing purposes.

Vendors, consultants and other service providers. We may share your information with third party vendors, service providers, contractors or agents who perform functions required for the operation of our business. Examples include to provide data storage and processing services, fraud prevention, technical support for our Platform, analyzing data and performing analysis related to the Website, Platform and related services, and delivering content.

Compliance with laws. We may disclose information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Disclosures for national security or law enforcement. Under certain circumstances, we may be required to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Vital interests and legal rights. We may disclose information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Notice, or as evidence in litigation in which SUPERADS may be involved.

SUPERADS affiliates. SUPERADS is headquartered in Guangzhou, China, but we have subsidiary and affiliate offices in Shenzhen, China; Beijing, China; Xi’an, China; Hong Kong, China; and Tel Aviv, Israel. We may share information with our parent companies, subsidiaries and/or affiliates for use and processing purposes described in this privacy policy.

Business transfers. We may share or transfer information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this privacy policy.

Website advertising partners. We may partner with third party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share your personal information with them for this purpose.

Consent. We may share your information with any other person with your consent to the disclosure.

4.2 Your Data Protection Rights

You have the following data protection rights:

You can request access to or that we change, update or delete your personal information at any time by contacting us at privacy@superads.cn. Please note that we may impose a small fee for access and disclosure of your personal information where permitted under applicable law, which will be communicated to you.

In addition, if you are a resident of the European Economic Area, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. To exercise these rights email privacy@superads.cn.

You can opt out of receiving promotional emails from us by clicking the “unsubscribe” link in the email, by emailing unsubscribe@superads.cn. If you choose to no longer receive marketing information, we may still communicate with you regarding such things as your security updates, product functionality, responses to service requests, or other transactional, non-marketing/administrative related purposes.

If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

Please note that because most of the information we store can only identify a particular browser or device, and cannot identify you individually, you will need to provide us with some additional information to enable us to identify the personal information we hold about you and ensure that we accurately fulfil your request.

4.3 Legal Basis for Processing Personal Information (EEA residents only).

If you are an individual from the EEA, United Kingdom and Switzerland, our legal basis for collecting and using personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we normally rely on our legitimate interest to collect personal information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to process your personal information, they include the interests described in the Section 2.2 and Section 3.2 above.

In some cases, we may rely on our consent or have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person. If we rely on consent to collect and/or process your personal information, we will obtain such consent in compliance with applicable laws.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the details provided under the heading “Contact Us” below.

4.4 Third-Party Websites and Apps

This privacy policy only applies to the SUPERADS Websites and SUPERADS Services. We are not responsible for the privacy practices or disclosures of websites, developers, or apps that use or access the SUPERADS Websites or SUPERADS Services. In addition, ads within the SUPERADS Platform may contain links to third-party websites and apps. Any access to and use of such linked websites or apps is not governed by this privacy policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties.

4.5 How do We Keep Your Personal Information Secure

We use appropriate administrative, organizational, technical, and physical safeguards to protect the personal information we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe, secure, and only available to you and to those you provided authorized access. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so you should take care in deciding what information you send us in this way.

4.6 Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such data or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If you are an End User, we typically store the personal information we collect about you, such as your IP address and other information described above, for 13 months from the date of collection before we delete, overwrite, or anonymize that data, unless we are required to keep it to comply with a legal or audit obligation. For personal information collected via Google Analytics the following retention periods apply:

Please contact us at privacy@superads.cn if you have any questions about the information we collect and/or how we use the information we collect.

4.7 International Data Transfers

The SUPERADS Services and SUPERADS Websites are provided, supported, and hosted in the United States and Singapore. If you are using the SUEPRADS Services and SUPERADS Websites from outside the United States or Singapore, be aware that your information may be transferred to, stored, and processed by SUPERADS in our facilities and by those third parties with whom we may share your personal information, in the United States, Singapore and other locations including Guangzhou, Shenzhen, Beijing, Xi’an and Tel Aviv, where we have offices. These countries may have data protection laws that are different to the laws of your country.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Notice. These include implementing the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

4.8 Copyrights

All Site content, design, text, graphics, images, logos, buttons, icons, interfaces, audio and video clips, and the selection and arrangements thereof are the exclusive property of SUPERADS, or its respective content providers, and are protected by Hong Kong SAR and international copyright laws. All software used on the Site is the property of SUPERADS or its respective software suppliers, and such software is protected by Hong Kong SAR and international copyright laws and other applicable laws and treaties. Users of this Site shall not transmit/post any information to this Site that infringes the copyright or other intellectual property rights of others.

4.9 Trademarks

All trademarks, service marks and trade names used on the Site (collectively the “Marks”) are solely owned by SUPERADS. The Marks may not be used in connection with any product or service that is not a product or service of SUPERADS or that is likely to cause confusion among customers, or that in any manner disparages or discredits SUPERADS.

4.10 Changes to This Privacy Policy

SUPERADS will review and update this privacy policy periodically and will note the date of its most recent revision above. If we make material changes to this privacy, we will notify you either by prominently posting a notice of such changes prior to implementing the changes or by directly sending you a notification. All revisions will be posted to this website www.superads.cn. We encourage you to review this privacy policy frequently to be informed of how SUPERADS is protecting your information.

4.11 Contact Us

If you have questions about our privacy practices, or would like to make a complaint, please contact SUPERADS's Data Protection Officer by email at privacy@superads.cn or by post using the details provided below:

SUPERADS INTERNATIONAL TECHNOLOGY LIMITED

RM 1502-A,

EASEY COMM BLDG 253-261,

HENNESSY RD WANCHAI,

Hong Kong 999077

Please be sure to include your personal name (and the full company name, if you are inquiring on behalf of such company), address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.