This privacy policy ("Policy") describes how zoneads TECHNOLOGY PTE. LTD. ("zoneads TECHNOLOGY PTE. LTD", "we", "us" or "our") collects, protects and uses the personally identifiable information ("Personal Information") you ("User", "you" or "your") may provide on the zoneads.com website and any of its products or services (collectively, "Website" or "Services"), including through mobile applications using our SDK. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Collection of personal information

We receive and store any information you knowingly provide to us when you create an account, as well as when you fill any online forms on the Website. When required, this information may include your email address, name, phone number, or other Personal Information. You can choose not to provide us with certain information, but certain features of the Website may not be accessible. Users who are uncertain about what information is mandatory are welcome to contact us.

When you are using a mobile application that utilizes our mobile SDK, we also automatically collect information about your device such as the advertising ID, the model of your device, and your screen size.

When you visit the Website, our servers automatically record information that your browser sends. This data may include information such as your device's IP address, browser type and version, operating system type and version, language preferences, the webpage you were visiting before you came to our Website, pages of our Website that you visit, the time spent on those pages, information you search for on our Website, access times and dates, and other statistics.

Managing personal information

You are able to access, add to, update and delete certain Personal Information about you. The information you can view, update, and delete may change as the Website or Services change. When you update information, however, we may maintain a copy of the original unrevised information in our records. Some information may remain in our private records after your deletion of such information from your account. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

Use and processing of collected information

Any of the information we collect from you may be used to improve customer service and respond to queries and emails of our customers; run and operate our Website and Services. Information collected via our mobile SDK is used for the purpose of delivering ads that we believe you may be interested in. Non-Personal Information collected is used only to identify potential cases of abuse and establish statistical information regarding Website usage. This statistical information is not used in such a way that would identify any particular user of the system.

We may process Personal Information related to you if one of the following applies: 1. You have given consent for one or more specific purposes. Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. This, however, does not apply, whenever the processing of Personal Information is subject to EU General Data Protection Regulation (GDPR) under the European Data Protection Law; 2. Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; 3. Processing is necessary for compliance with a legal obligation to which you are subject; 4. Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; 5. Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. In any case, we will be happy to clarify the specific legal basis that applies to the processing in your case, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Disclosure of collected information

We share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us, pursuant to written instructions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use PI they receive from us for any other purpose. We may share your information with business partners and other third parties in order to allow them to provide you with offers, promotions, or ads that we think you may enjoy. If you do not want us to share your personal information with these companies, please contact us using the information below.

International users

If you are visiting our Website from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to various locations and processing globally. By providing your personal information, you consent to any transfer and processing in accordance with the Policy.

Information transfer and storage

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by inquiring with us using the information provided in the contact section.

The rights of users

You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

The right to object to processing

Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. Should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner(person who exercising power)through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Privacy of children

Our Website and Service, including our mobile SDK, are not directed to children under the age of 13, and we do not knowingly collect any personal information from children under the age of 13. Please do not submit any Personal Information through our Website or Service if you are under the age of 13. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our Website or Service. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through our Website or Service, please contact us, and we will delete that information immediately.

If you are a developer using our SDK in a child-directed mobile application or you have actual knowledge that a user is under the age of 13, please notify us using the mechanisms provided through our platform or tools, or contact us using the information below.

Opting Out of Interest-Based Advertising on Mobile Devices

Mobile users can opt out of having their Mobile IDs used for certain types of interest- based mobile advertising, including those performed by zoneads, by accessing the settings on Apple or Android mobile device, as follows: Apple Devices: If you have an Apple device, you can opt out of most interest-based advertising by updating to iOS 6.0 or higher and enabling "Limit Ad Tracking." iOS 7 and Higher: Go to Settings → Privacy → Advertising, and toggle "Limit Ad Tracking" to 'ON.' iOS 6: Go to Settings → General → About → Advertising, and toggle "Limit Ad Tracking" to 'ON.' Android Devices: If you have an Android device, you can opt out of most cross-app advertising by going to Google Settings → Ads, and selecting the option to opt out of interest-based ads. Users also have the right to clean the Personal Data concerning them that we hold as a data controller. The above opt-out process satisfies this right. When an End User opts-out through device settings, and we receive this signal from our Clients, the Personal Data we use to provide our services will be deleted within 30 days (if you have an Android device) or permanently rendered disconnected to your device (if you have an iOS device). zoneads service team will also manually delete users' Personal Data, please contact us at privacy@zoneads.com for further instructions on exercising this right manually.

Newsletters

We offer electronic newsletters to which you may voluntarily subscribe at any time. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transaction-related emails.

Cookies

The Website uses "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To learn more about cookies and how to manage them, visit internetcookies.org

In addition to using cookies and related technologies as described above, we also may permit certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Website. These companies may deliver ads that might also place cookies and otherwise track user behavior.

If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:

1. Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http:// optout.aboutads.info/) and mobile application-based "AppChoices" download page (https://youradchoices.com/appchoices). 2. European Interactive Digital Advertising Alliiance (EDAA)'s consumer opt-out page (http://youronlinechoices.eu). 3. Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).

In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple's IDFA or Android's GAID), visit the device manufacturer's current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: http:// www.networkadvertising.org/mobile-choices.

Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt-out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.

Do Not Track signals

In the event we become aware that the security of the Website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, send you an email.

Legal disclosure

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. Our Website does not track its visitors over time and across third party websites. However, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

Links to other websites

Our Website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third-parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect Personal Information.

Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite all best efforts.

Data breach

In the event we become aware that the security of the Website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website and/or send you an email.

Legal disclosure

We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and personal data will likely be among the assets transferred.

Changes and amendments

We may update this Privacy Notice and the “last updated” date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. We will provide notice of substantial changes of this policy on the homepage of the Site,or we will send you an e-mail to the e-mail address that you may have provided us of such changes. The changes will be made within 7 days after the notification was provided. Continued use of the Website after any such changes shall constitute your consent to such changes.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.

Contact Us

If you have any questions about this Policy, please contact us. privacy@zoneads.com This document was last updated on May 7, 2020.