Privacy Policy

SOLID NET LIMITED

Last updated on October, 2024.

This Privacy Policy is effective [November 1,], 2023 for all users.

We are committed to respecting and protecting each individual’s privacy rights. This Privacy Policy explains how SOLID NET LIMITED, its wholly-owned subsidiaries and holding subsidiaries (SOLID NET LIMITED, its wholly-owned subsidiaries and holding subsidiaries are jointly referred to as “Company”, “we”, “our”, or “us”; and “holding” means direct or indirect ownership reaches or exceeds 50%.) collect, use, disclose or share end user (“you” or “your”) information through our advertising platform (“Advertising Service”), our website at https://www.adeliver-media.com/ (“Website”), our mobile applications (“App”), and any of our products and/or services (collectively, the “Services”), and whether you access the Services directly or through a third party.

Please understand that, except as specifically described below, this Privacy Policy does not apply to information collected by third parties, such as other companies, or third-party websites or mobile applications, even if any are linked to or accessible through the Services.

We collect information from users when users (i) visit our Website; (ii) view ads served by our Advertising Service; (iii) interact with our Advertising Service; or (iv) interact with the platforms, applications, websites or any other products and/or services provided by our business partners (e.g. app publisher, advertiser).

When you use the Services, where applicable under relevant laws, you consent to our collection, use, and disclosure of information about you as described in this Privacy Policy. Under other applicable relevant laws, we may collect, use, disclosure, or otherwise your information based on the appropriate legal basis. Please review this Privacy Policy before using our Services or visiting our Website. We may amend this Privacy Policy from time to time. The amended Privacy Policy will be displayed on our Website. Please check our Privacy Policy regularly to ensure you have read the latest version. Where applicable under relevant laws, continued use of the Services after the effective date will be your acknowledgement that have accepted the revised Privacy Policy.

If you have any questions or concerns about our information practices, please contact us at dataprivacy@adeliver-media.com.

What Information Is Collected and How Do We Collect Your Information?

We may collect, transmit, store, and otherwise process information about you in connection with your use of the Services, including any information you send to or through the Services. We use that information to provide the Services’ functionality, fulfill your requests, improve the Services’ quality, engage in research and analysis relating to the Services, personalize your experience, track usage of the Services, provide feedback to third party businesses that are listed on the Services, display relevant advertising, market the Services, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Services, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our servers initially and stored long enough to process.

We may collect the following information from or about our users when they access our Services:

• Information which users provide to us, including names, gender, birth dates, personal ID card numbers, addresses, telephone numbers, email addresses, occupations, education, work experience and related information.

• Passive information collected when users use the Services, such as a user’s browser information (user agent), browser type, IP host address, mobile device type, the Identifier for Advertising (IDFA), Google Advertising ID (GAID), whether user viewed, clicked or otherwise interacted with the advertisement, and other device identifiers, domain name, pages visited, and the length of your user sessions using various technologies and means, such as IP address, cookies, internet tags and navigational data collection.

• We also use cookies to collect certain information about our users. Cookies collect information on the device and network used to access the domain, and the date and time that users access the domain. This information is for internal use only, such as optimizing performance of the Services. The information cannot identify the individual user.

• Information from other third party partners of us, such as companies that provide services to us and our business partners.

How Do We Use Your Information?

We use the information, including any personal information, provided by users to provide our Services and for internal business purposes, such as improving our services and assist our customers and partners in improving their products and services; compiling aggregate data for internal and external business purposes; preventing potentially illegal activities; in support of user accounts or customer service requests; in relation with any required governmental or legal action ; and other uses in accordance with our respective Terms and Conditions.

We may also use the information that we collect about your device to display advertisements on your device, which may include interest-based advertising customized to your interests, preferences, locations, for bidding to serve advertisements and to determine which ads are most effective, to analyze and provide our demand partners or advertisers reports on the effectiveness of advertisements and campaigns, including across different types of devices based on our determination of devices that are related to the same person, and to build custom audience segments to enable our customers and partners better target their advertisements and offers.

The legal basis for using your personal information

We will only collect, use, share and otherwise process your personal information where we are satisfied that we have an appropriate legal basis to do this. Our processing activities and our legal basis are set out below:

Categories of personal information

Contact information:

For example:

Names ;Addresses;

Telephone numbers;

Email addresses; etc.

Other information about you which you provide to us such as your gender, date of birth, and education.

Device information:

IDFA/GAID/AID; Device type; User agent; Operating system;Operating system version;IP address; MSISDN;Device ID; IMSI; and browser information.

Processing activities

Providing services and optimizing services:

(1)To meet the requirement of ad offer.

(2)Analyse device data to determine performance of advertisement

campaigns and to verify the validity of the traffic.

(3)Further optimize the effectiveness of ads and to exclude malicious fraudulent traffic.

(4)Analyse ongoing business.

(5)Optimize in-house App.

The legal basis we rely upon

We rely on our legitimate interests:

We rely on our legitimate interests:a) to track and reduce the amount of fraudulent traffic and to verify the success of advertising campaigns; andb) To prevent and detect crime, and in each case we have assessed and determined that our legitimate interests are not overridden by the rights and freedoms of the data subject to whom such personal data relates

We may also use your personal information where necessary to comply with a relevant legal or regulatory obligation that we have.

How Do We Share Your Information?

We may share your personal information with our business partners, including publishers, supply partners, demand partners, advertisers, marketing partners, data tracking companies, service providers (which may include IT and related services; fraud detection, information and services; payment processors; customer service providers; and vendors to support the provision of the Services) and with our subsidiaries and affiliates so that we can better provide our Services.

In particular, we will share your personal information with:

• our advertisers, to identify and verify the validity of advertising promotion placed, and to verify the success of advertising campaigns;

• third party attributions, such as Appsflyer or Adjust, for monitoring and fraud detection purposes; and

• government and/or regulatory authorities, to comply with our legal and regulatory obligations. Except as otherwise described in our Privacy Policy, we will not disclose personal information to any third party unless we believe that disclosure is necessary: (1) to comply with applicable law or to respond to a subpoena, court order, search warrant, or other legal process received by us , whether or not a response is required by applicable law; (2) to protect or enforce our rights or the rights of a third party; (3) to protect the safety of members of the public and our users; or (4) to respond to an emergency. We reserve the right to transfer your information in connection with a merger, division, sale of our assets or financing to another company or the acquisition of all or part of our business. We also reserve the right to disclose personal information as necessary to enable third-party service providers to support and maintain the operation of our Services, or to disclose personal information to other third parties performing services in connection with the operation of our business.

Transferring Personal Information Globally

We operate on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the Peoples Republic of China(“PRC”), the European Economic Area (“EEA”) and the United Kingdom (“UK”), such as US, Brazil, Singapore, that are subject to different standards of data protection. We will take appropriate steps to ensure that transfers of the personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interest and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To ensure the protection of your personal information consistent with applicable law, such transfer takes place outside the PRC, the EEA and the UK as follows:

• If it is necessary to transfer such data from within the PRC to outside PRC, such transfer will be made pursuant to relevant laws and regulations.

• Outside of the EEA and the United Kingdom, such transfer will be made pursuant to the EU Model Clauses, the EU-US Privacy Shield certification, or other acceptable legal mechanisms of which you can request a copy via dataprivacy@adeliver-media.com.

How Do We Protect the Information?

We use various safeguards to protect the personal information submitted to us, both during transmission and after we receive it. For example, we have implemented and maintain appropriate technical and organizational security measures to protect the information we collect. We use multiple electronic, procedural, and physical security measures to protect against unauthorized or unlawful use or alteration of information, and against any accidental loss, destruction, or damage to information.

We also have a Data Protection Officer (“DPO”) according to GDPR. The DPO is responsible for monitoring our compliance with GDPR and cooperating with supervisory authority. His contact is dataprivacy@adeliver-media.com.

However, no method of transmission over the internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

How Long Do We Keep the Information For?

We may retain the information relating to a user for as long as a user uses the Services and for the purposes as stated in this Privacy Policy, unless otherwise required by law or applicable regulations. In specific circumstances, we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealing.

Notwithstanding the foregoing, we may retain and use such information in a non-identifiable, aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, to resolve disputes and enforce agreements. We will make efforts to guarantee that personal information is kept for no longer than is necessary for the purposes for which the personal information is processed.

User Rights to Their Information

Users have certain rights available to them when it comes to their information.

In accordance with the Personal Information Protection Law of the People's Republic of China, we shall process your personal information only under the premise that there is a legal basis. You have the following rights to your personal information:

Right to access and copy personal information

You have the right to access your personal information and to receive copies of your personal information, subject to the exceptions provided by laws and regulations.

Right to correct or delete personal information

If you find that we have processed errors in the personal information, you have the right to request us to make corrections. We may verify the accuracy of the personal information prior to correcting it.

You may request us to delete your personal information in the following situations:

• The handling purpose has been achieved, is impossible to achieve, or the personal information is no longer necessary to achieve the handling purpose;

• Personal information handlers cease the provision of products or services, or the retention period has expired;

• You withdraw consent;

• We process personal information in violation of laws, administrative regulations or agreements;

• Other circumstances provided for by laws or administrative regulations.

• If the the retention period provided by laws or administrative regulations has not expired or the deletion of the personal information is technically difficult to accomplish, we will stop processing the information other than storage and adoption of necessary security protection measures.

Right to transfer your personal information

You may make a request for us to transfer your personal information to a designated personal information processor.

Right to withdraw your consent

You have the right to withdraw your consent for the processing of personal information based on your consent.

Right to request us for explaination

You have the right to request us to explain the rules governing the processing of personal information.

If you have any questions about our compliance with this Privacy Policy and relevant data protection laws, or if you wish to exercise your rights, you can contact us at dataprivacy@adeliver-media.com..

European Union and United Kingdom Residents

For residents of the EU and UK, we collect and process information about the users who live in the EEA and the UK only on where we have legal bases under applicable EU and UK laws.

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information, including:

Right to access personal information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.

Right to rectify or erase personal information

You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.

You can also request that we erase your personal information in limited circumstances where:

• it is no longer needed for the purposes for which it was collected; or

• you have withdrawn your consent (where the data processing was based on consent); or

• following a successful right to object (see right to object below); or

• it has been processed unlawfully; or

• to comply with a legal obligation to which we are subject.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

• for compliance with a legal obligation; or

• for the establishment, exercise or defence of legal claims.

Right to restrict the processing of your personal information

You can ask us to restrict your personal information, but only where:

• its accuracy is contested, to allow us to verify its accuracy; or

• the processing is unlawful, but you do not want it erased; or

• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or

• you have exercised the right to object, and verification of overriding grounds is pending.

• We can continue to use your personal information following a request for restriction,

• where:

• we have your consent; or

• to establish, exercise or defend legal claims; or

• to protect the rights of another natural or legal person.

Right to transfer your personal information

You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

• the processing is based on your consent or on the performance of a contract with you; and

• the processing is carried out by automated means.

Right to object to the processing of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to object to how we use your personal information for direct marketing purposes

You can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EU or UK. Where applicable under relevant laws, we may redact data transfer agreements to protect commercial terms.

If you have any questions, concerns or complaints regarding our compliance with this Privacy Policy and the relevant data protection laws, or if you wish to exercise your rights, we encourage you to first contact our Data Protection Officer at dataprivacy@adeliver-media.com.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way