AdPlex Privacy Policy

December 9^th 2025

AdPlex entities (for purpose of applicable data protection laws, AdPlex entities providing AdPlex Service which are subject to applicable disclosure requirements can be viewed HERE collectively, “AdPlex”, or “we”, “us”, “our”) provide this privacy policy to explain how we collect, use, and share information. This privacy policy (“Policy”) covers AdPlex’s handling of two types of information:

1. Information we receive when we provide our service, including (i) device information about end users we collect through our software development kit (“SDK”), application programming interface (“API”), our platforms, services or technologies from traffic supply partners such as mobile app developer, ad exchange platform, supply-side platform, mediation platform; (ii) information about end users’ interaction with ads collect through our SDK, API or other technologies, or collected and transferred to us by our Business Partners (e.g. mobile app developers, advertisers, hereinafter referred to as “Business Partners”) or any third party designated by them; (iii) device information generated during end users’ use of our Business Partners’ mobile apps, websites, platforms or services and information collected and transferred to us by our Business Partners or any third party designated by them; (iv) information provided by Business Partners when they use AdPlex’s platforms, technologies, services. In the Privacy Policy of the AdPlex Services, the end users mentioned in this section are collectively referred to as “User”, “you” or “your”; the SDK, API, any technology, platform or service provided by AdPlex mentioned in this section are referred to as “AdPlex Service”. Please click on the following link to access detail about Protection for Minors under the process of collecting this type of information.

2. Information we receive through the following websites from website visitors (hereinafter referred to as “Visitors”, “you” or “your”) in the Privacy Policy of AdPlex Website: (i) our website at: adplex.kton.cn www.mintegral.net or any other website on which this Policy is posted, as well as (ii) any website we provide to Business Partners or potential clients in order to provide our services. Please click on the following link to access detail about Protection for Minors under the process of collecting this type of information.

This Policy is subject to any service agreement between AdPlex and you. By using the AdPlex Service or AdPlex Site, you acknowledge that you have read, understood and agreed to this Policy. Please review this Policy before using the AdPlex Service or the AdPlex Site.

We evaluate this Policy and procedures to implement improvements and refinements from time to time.

Data protection and ensuring our Business Partners‘ and your trust is at the core of AdPlex’s business principles. Accordingly, being compliance with applicable data protection laws is our top priority and this Policy is updated to be compliance with the applicable data protection laws, including but not limited to the EU General Data Protection Regulation (“GDPR”), the Children’s Online Privacy Protection Act (“COPPA”), the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais) (“LGPD”), the US Executive Order 14117 and relevant laws and regulations (“DSP”), and the US States Privacy Laws (“US States Privacy Laws”) including but not limited to California Customer Privacy Act (“CCPA”), Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act (“CPA”), the Utah Consumer Privacy Act (“UCPA”), the Connecticut Data Protection Act (“CDPA”), the Oregon Consumer Privacy Act (“OCPA”), and the Texas Data Privacy and Security Act (“TDPSA”).

For the purpose of this Policy, “Processor” means an “entrusted handler” under the PIPL, a “processor” under the US States Privacy Laws, excluding CCPA, and a “service provider” under the CCPA. “Controller” means a “personal information handler” under the PIPL, a “controller” under the US States Privacy Laws, excluding CCPA, and a “business” under the CCPA.

Privacy Policy of the AdPlex Services

1. Introduction

This Policy describes AdPlex’s information collection and use while (i) Users view ads served by the AdPlex Services or interact with AdPlex’s Services in any manner; (ii) Users interact with platforms, applications, websites or other services provided by Business Partners; (iii) Business Partners interact with AdPlex’s Service. Except as explicitly stated in this Policy, AdPlex acts as a Controller under the GDPR when processing Users' personal information in the provision of AdPlex Services.

Our technology enables our partners to show Users more relevant advertising that is based on Users’ interests and behaviors. In order to provide AdPlex Services, we may collect and use certain information about User activity and preferences. We understand how important it is to keep such User’s personal information confidential and discrete, especially in today’s online world. To this end, we have designed this Policy in a format that is easy to navigate and read so that our privacy practices can be clearly understood.

The AdPlex Services may link to third party websites, Apps or other third party content. Please note that we cannot control the treatment of a User’s information by such third parties, and that the privacy practices of third parties likely differ from those described in this Policy.

2. How We Collect Users’ Information

Source of Personal Information: Depending on the nature of a User’s interaction with the AdPlex Services, or any service provided by AdPlex’s Business Partners, we may collect information directly from such User or from our Business Partners (e.g. mobile application developers, ad exchange platforms, supply-side platform and advertisers). For example, (1) we may collect user information through AdPlex SDK embedded by mobile application developers in mobile apps or by advertisers in their websites; (2) our Business Partners such as ad exchange platform and supply-side platform may share user information with us when they initiates an ad request to our DSP; (3) our advertisers or their third-party attribution platforms may share user information with us.

Therefore, in the process of providing AdPlex's services, we have no direct contact with users. We will obtain authorized consent from users regarding the collection and use of personal information through AdPlex's business partners (e.g., mobile application developers, website developers or advertisers). In our cooperation agreements with AdPlex's business partners, we have required them to commit to and guarantee the legitimacy of the data source, and they will inform users of the specifics of our processing of personal information as required by applicable law and obtain valid consent from users (obtaining separate consent as required by applicable law if necessary), and guarantee that users can revoke such consent at any time.

3. Information We May Collect From Users

When you view ads served by AdPlex Service or interact with services provided by AdPlex’s Business Partners, we and/or our Business Partners may collect your information.

(1) The information we collect through our SDK may include the following types：

a. Location Information: IP, Country, Time Zone and Locale Setting (include country information and preferred language).

b. Device ID/ Avertising ID: ,IDFV, IDFA,GAID,Amazon ID. We will not collect such information if you restrict your device or the app from acquiring device ID or advertising ID according to Article 7 of this Policy.

c. Device Information: device make, device model, information of operating system, device type, information of screen, device volume and font size, whether the it is an emulator, information of network, information of hardware, Limited Ad Tracking (LAT) status, system boot time, information of storage capacity;

d. Application Information: package name of the app of AdPlex’s Business Partners, whether it is downloaded from App Store, version and characteristic of the app used by you when you interact with AdPlex’s Service, SDK version;

e. Interactive Information: when you view ads served by us or have other interaction with ads served by us, we may collect information about your interaction with such ads, for example, information that you have viewed or clicked an ad, the ad type and the creative id.

f. Others: timestamp, device event information such as crashes, system activity, user-agent.

g. Web browser information, such as user agent, operating system, language, browser name, screen information, window information, physical memory, processor information, time zone

h. Page information: Page URL, page title, page performance metrics

i. Event information: Page load completion, page stay time, clicks, scrolls, and other events voluntarily reported by website owners

(2) When you install and use the product (e.g. app) after you view and click an ad served by us, we may collect information from advertisers or their attribution measurement partners including the following types:

① Location information: IP address, country, city;

② Device/advertising ID: IMEI, OAID, IDFV, IDFA, GAID, Amazon ID, MAC address;

③ Device information: device manufacturer, device model, device operating system information, device language, device type, device network information, device operator;

④ Application information: application version;

⑤ Usage data: timestamp of when the installation event other other event occurred;

⑥ Other information: user agent. TCF string.

Special note: The TCF string is a machine-readable string defined by IAB Europe that encodes your consent choices regarding the processing of your personal information by us. For more information about the TCF string, you can visit the IAB Europe website. Please note that we only collect your TCF string information when you are located in the European Economic Area (“EEA”).

We may also collect the following information from the mediation platforms that the advertiser works with:

① Location information: IP address, country, city;

② Device/advertising ID: IMEI, OAID, IDFV, IDFA, GAID, Amazon ID, MAC address;

③ Device information: device manufacturer, device model, device operating system information, device language, device type, device network information, device operator;

④ Application information: application package name;

⑤ Usage data: timestamp of the occurrence of the monetization event;

⑥ Other information: user agent.

(3) Where AdPlex acts as Demand Side Platform (“DSP”), the ad exchange platform or supply-side platform may share with us your personal information through API may include the following:

① Location Information: IP, Country, Time Zone and Locale Setting (include country information and preferred language).

② Device ID/ Advertising ID: IMEI, Android ID, OAID, IDFV, Mobile Ad Identifier such as Apple IDFA or Google Advertising ID, Amazon ID, MAC address.

③ Device Information: device make, device model, information of operating system, device type, information of screen, information of network, Limited Ad Tracking (LAT) status;

④ Application Information: version and characteristic of the app used by you when you interact with the AdPlex Services, user-agent;

⑤ Interactive Information: we may also collect information about your interaction with ads served by us, such as information that you have viewed or clicked an ad;

⑥ Others: other information transferred by the ad exchange platform or supply-side platform.

We cooperates with reputational ad exchange platforms and supply-side platform including Google Doubleclick Ad Exchange. The ad exchange platforms or the supply-side platform may receive an ad request containing your personal information and, to the extent permitted by applicable law or with User’s valid consent, transfer to AdPlex to build your profile, personalize your ad experience, and serve future ads you may see on the internet.

(4) As we provide AdPlex Service for our Business Partners, we may collect name, job title, email address, contact address and the account name and password used to access AdPlex websites, IP address of the individuals using AdPlex services on behalf of such Business Partners.

ABOUT SENSITIVE PERSONAL INFORMATION

Sensitive Personal Information refers to personal information that, once leaked or illegally used, will easily lead to infringement of the human dignity or harm to the personal or property safety of a natural person. The scope of sensitive personal information may vary pursuant to different applicable data protection law.

AdPlex Services, excluding AdPlex Websites, will not collect your sensitive personal information. Only our Business Partner will transmit or authorize us to process your sensitive personal information after they notifying you the necessity of processing your sensitive personal information and the impact of your rights and interests with your consent.

4. How We Use Users’ Personal Information

We use your personal information for the following purpose:

Type of Personal Information
Data Processing Activities
Device Related Information and User Behavior Information
Including all types of personal information described in paragraphs (1) to (3) of Article 3 of this Policy
Basic business functions: Your device might be distinguished from other devices based on information it automatically send. We use your personal information to display ads on your device through automatic decision making process. We use de-identification techniques and algorithms based on machine learning, model prediction, and more. Ads may be shown to you based on information we legally collected such as the content you’re viewing, the app you’re using, your approximate location, your device type and your device status. We may create tag, features and build profile about you and your interest. According to the calculation results of the recommendation algorithm based on the profile, we may show you personalized ads or behavioral ads which are relevant to you and customized to your inferred interests, preferences, approximate locations and other features. Our recommendation algorithm does not identify the true identity of a particular natural person.
We also perform secondary processing of aggregated data in accordance with data security technologies such as de-identification and anonymization, which are commonly implemented in the industry, to form a database of features and tags that cannot identify the true identity of a specific natural person, conduct group analysis, and optimize algorithm training models to better understand and analyze your usage trends and preferences in order to improve the quality of our AdPlex Services and develop our new products.
Extended Business Functions: Your device information will be used to collect information about the cause of application crashes for later crash problem solving.
Including all types of personal information described in paragraphs (1) items (g) (h) (i) of this Policy
When providing advertising placement services to advertisers, we use your personal information to provide advertising attribution services to them.
Contact Information
Including all types of personal information described in paragraphs（4）of Article 3 of this Policy
We may collect and use personal information of Users who are representing our Business Partners to use AdPlex Service (e.g. employees of publishers or advertisers) for purpose of business contact and direct marking (e.g. sending marketing emails).
Sensitive Personal Information
/
We will not collect your sensitive personal information without your consent. Our Business Partners will transmit or authorize us to process your sensitive personal information after notifying you the necessity of processing your sensitive personal information and the impact of your rights and interests with your consent.

5. The Legal Basis for Our Processing of Users' Personal Information

(1) Where required by applicable laws, We have contractually agreed that our Business Partners (e.g. developer of mobile app integrated with AdPlex SDK, advertisers) will obtain consent of a user or their employees for and on our behalf for our processing of his/her personal information described in this Privacy Policy. A data subject can withdraw their consent at any time.

(2) If you are located in the European Economic Area, we may use your personal information based on the "legitimate interests" set forth in the GDPR, in necessary cases. Our legitimate interests include: monitoring and preventing fraudulent activity, remove technical obstacles to system operation and ensuring systems and processes work properly and securely.

6. How We Share, Entrust the Processing, Transfer, Disclose And Transmit Users’ Personal Information

(1) Sharing

We may share personal information collected by us with third parties for the following purposes and scenarios：

No.

Type of Third Parties

Type of Information

Processing Purpose and Processing Method

1

Advertisers, advertising agencies, ad attribution service providers, ad demand-side platforms

①Location Information: IP, Country, Time Zone and Locale Setting (include country information and preferred language).

②Device ID/ Avertising ID: IMEI, Android ID, OAID, IDFV, IDFA，GAID，Amazon ID or MAC address. We will not collect such information if you restrict your device or the app from acquiring device ID or advertising ID according to Article 7 of this Policy.

③ Device Information: device make, device model, information of operating system, device type, information of screen, device volume and font size, whether the it is an emulator, information of network, information of hardware, information of device sensor, Limited Ad Tracking (LAT) status, system boot time, device user name, information of storage capacity;

④Application Information: package name of the app of AdPlex’s Business Partners, whether it is downloaded from App Store, version and characteristic of the app used by you when you interact with AdPlex’s Service, SDK version, list of installed apps*;

⑤Interactive Information: when you view ads served by us or have other interaction with ads served by us, we may collect information about your interaction with such ads, for example, information that you have viewed or clicked an ad.

⑥Others: user-agent.

①for conducting advertising attribution and settlement with advertisers/advertising agencies. In relation to such processing activities of personal information, AdPlex acts as a Processor on behalf of the advertisers/advertising agencies to process Users' personal information;

②for monitoring the quality of advertising delivery;

③ for performing precise targeting.

2

AdPlex Affiliates

including all types of personal information described in items (4) of Article 3 of this Policy

for promoting the products or services of our affiliates to users.

Except as expressly stated in this Policy, we will not disclose User’s personal information to any third party without User’s consent.

We have agreed with the partners who have direct access to the user that the partner will inform the user of the above-mentioned third party information and obtain the user's separate consent.

We may also share aggregate or anonymous information with other third parties in accordance with the terms of this Policy.

(2) Entrusted Processing

Type of Third Parties

Information of Third Parties

Type of Information

Processing Purpose and Processing Method

cloud service providers

See the cloud service providers

Including all types of personal information described in Article 3 of this Policy

① for responding to advertising requests;

② for ensuring systems and processes work properly and securely;

③ for purpose of data storage.

Except as expressly stated in this Privacy Policy, we do not entrust other third parties with the processing of Users' personal information.

(3) Public Disclosure

We do not publicly disclose the personal information of end users, except in the following cases:
① After informing the user of the type, purpose, manner and scope of the personal information to be publicly disclosed and obtaining the user's separate consent;
② When compelled by laws, regulations, legal proceedings, litigation or government authorities.

(4) International Transfers

If you are a United States person, your personal information collected will be securely stored in the United States. We comply with DSP and other applicable United States laws and regulations and will not illegally transfer, share or otherwise make available your personal information.

When you are located in the European Econocim Area (“EEA”), personal information collected about you will be transferred to recipients in countries located outside the EEA or can be remotely accessed in countries located outside the EEA, including in countries which may not be decided by the European Commission that it provides an adequate level of protection to personal information. We have followed requirements as set out in applicable law to provide adequate protection to your personal data. To the extent as required by applicable law, our Business Partner will obtain your valid consent to the extent for us to transfer your personal information to recipients including AdPlex’s affiliates and any other recipients as described in this Policy, which are located outside the EEA. You are entitled to withdraw your consent at any time.

AdPlex has entered into EU standard contractual clauses (“Model Contracts”) for intra-group transfers of personal information to its affiliates. You can request a copy of these Model Contracts by submitting your request via email to privacy@kton.cn

7. Your Data Rights

If you are in the EEA, you have a right to (subject to a limited number of exceptions as permitted by GDPR): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.

If you are residents of the State of California in the United States, you can request the following information about how we have collected and used your personal information during the past 12 months:

The categories of Personal Information we have collected.
The categories of sources from which we collected the Personal Information.
The business or commercial purpose for collecting, selling or sharing Personal Information.
The categories of third parties with whom we disclose the Personal Information.
The categories of Personal Information that we sold, shared or disclosed for a business purpose.
The categories of third parties to whom the Personal Information was sold, shared or disclosed for a business purpose.
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
You can ask us to delete the Personal Information that we have collected from you.
You can ask us to correct inaccuracies of your Personal Information.

You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.You may (i) submit requests to exercise your California privacy rights described above by writing to us at: privacy@kton.cn or send a written document to the following address: Legal Department, 5050 El Camino Real, Suite 400, Los Altos, CA 94022; (ii) opt out of selling or sharing of your data by clicking on the following link: DO NOT SELL OR SHARE MY DATA and (iii) submit requests to restrict the use of your sensitive Personal Information by writing to us at: privacy@kton.cn.

When you submit a request we will verify your request by the information you provide (e.g. device ID, company email) according to our internal guidelines. You may designate an authorized agent to make a request to know or a request to delete your personal information by providing the authorized agent written permission to do so; and by verifying your own identity with us directly. We will deny any requests from agents that do not submit proof of authorization. For request metrics as designated by the CCPA, please see here.

We have sold (as defined under the CCPA) the following categories of Personal Information to the following categories of third parties: please see column “Type of Information” and column “Type of Third Parties” of the 1^st line under Article 6(1) (“Sharing”) of this Policy. We do not sell Personal Information of minors under the age of 16 without affirmative authorization.

You can also find a list of the categories of Personal Information that we collect in the “Information We May Collect From Users” section above. For details regarding the sources from which we obtain personal information, please see the “How We Collect Users’ Information”section above. We collect and use personal information for the business or commercial purposes described in the “How We Use Users’ Personal Information” section above.

If you are (i) a resident of the State of Virginia in the United States, effective January 1, 2023, (ii) a resident of the State of Colorado in the United States, effective July 1, 2023, (iii) a resident of the State of Connecticut in the United States, effective July 1, 2023, or (iv) a resident of the State of Texas in the United States, effective July 1, 2024,you may exercise the following personal information rights with us.

to confirm whether we are processing your personal information and to access that personal information;
to correct any inaccuracies in your personal information;
to delete your personal information;
to obtain a copy of the personal information you have provided to us; and
to request a refusal to allow us to process your personal information for the purposes of (i) personalized advertising, (ii) selling your personal information, or (iii) user profiling that has significant legal or similar implications for you.

As set forth in the VCDPA, CPA, CDPA, and TDPSA you have the right to exercise the above rights without discrimination.

You may (i) exercise your rights to personal information as described above by sending email to privacy@kton.cn and (ii) click on this link to refuse personalized advertising, refuse the sale of your personal information, and refuse user profiles that have a significant legal or similar impact on you. If you fail to provide valid information for our effective feedback, etc. when exercising your rights as described above, we may deny your right to exercise your rights. If you have any dispute on such denial, you may raise such dispute by sending email to privacy@kton.cn.

If you are a resident of the State of Utah in the United States, effective December 31, 2023, you may exercise the following personal information rights with us.

to confirm whether we are processing your personal information and to access that personal information;
to delete your personal information;
to obtain a copy of the personal information you have provided to us; and
to request a refusal to allow us to process your personal information for the purposes of (i) personalized advertising, or (ii) selling your personal information.

As set forth in the UCPA you have the right to exercise the above rights without discrimination.

You may exercise your rights to personal information as described above by sending email to privacy@kton.cn. If you fail to provide valid information for our effective feedback, etc. when exercising your rights as described above, we may deny your right to exercise your rights. If you have any dispute on such denial, you may raise such dispute by sending email to privacy@kton.cn.

If you are a resident of the State of Oregon in the United States, effective July 1, 2024, you may exercise the following personal information rights with us.

a. to confirm whether we are processing your personal information and to access that personal information;
b. to obtain a list of third parties to whom we disclose personal information;
c. to correct any inaccuracies in your personal information;
d. to delete your personal information;
e. to obtain a copy of the personal information you have provided to us; and
f. to request a refusal to allow us to process your personal information for the purposes of (i) personalized advertising, (ii) selling your personal information, or (iii) user profiling that has significant legal or similar implications for you.

As set forth in the OCPA you have the right to exercise the above rights without discrimination.

You may (i) exercise your rights to personal information as described above by sending email to privacy@kton.cn and (ii) click on this link to refuse personalized advertising, refuse the sale of your personal information, and refuse user profiles that have a significant legal or similar impact on you. If you fail to provide valid information for our effective feedback, etc. when exercising your rights as described above, we may deny your right to exercise your rights. If you have any dispute on such denial, you may raise such dispute by sending email to privacy@kton.cn.

Setting about Personalized Ads

You can opt out personalized ads in the following way:

Guidance of Opt out

You can opt-out from receiving interest-based advertising or behavioural advertising from AdPlex on supported devices following the guideline below.

On an iOS device, if you are using iOS 14.5 or above, you can click on "Ask the App Not to Track" in the app's asking pop-up window or manage your "Tracking" settings in [Settings] - [Privacy] . If you ask the App not to track, AdPlex will not access your advertising identifiers and will not use advertising identifiers to infer your interests or serve advertisements to target devices based on your inferred interests.

On Android devices, your settings may allow you to “Opt out of Interest-Based Ads.” When you opt out using this setting on a device, AdPlex will not use information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests.

You can also manage your personalized advertising settings by clicking on the [Settings] section of the mobile app you have downloaded to find privacy-related settings. If you choose not to allow personalized advertising, AdPlex will not use information collected from your device to infer your interests or serve ads to target devices based on inferred interests.

Your mobile web browser may also provide a “Do Not Track” browser setting. When you have enabled this setting in your browser, AdPlex will not use mobile web browsing information from that browser to infer your interests or serve ads to that device that are targeting based on your inferred interests.

8. Security of Users’ Personal Information

The security of User’s information is our utmost priority, and we take strict measures in order to protect our data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for User’s information. Physical access is strictly controlled both at the perimeter and at building ingress points by our staff utilizing video surveillance and other electronic means. We will establish a dedicated security team, security management system, and data security process to safeguard the security of your personal information. We adopt a strict data use and access system to ensure that only authorized personnel have access to your personal information, and conduct security audits of data and technology when appropriate. We will develop emergency handling plans and activate them immediately in the event of a user information security incident, in an effort to prevent the expansion of the impact and consequences of such security incidents. Once a user information security incident (leakage, loss, etc.) has occurred, we will promptly inform you in accordance with the requirements of laws and regulations.

We also protect User’s privacy by seeking to minimize the amount of sensitive data that we store on our servers in the first place. We also seek appropriate contractual protection from our partners regarding their treatment of user data.

At present, AdPlex programmatic interactive advertising platform has passed the international authoritative ISO27001 information security certification and SOC 2 Type 1 and Type 2 audits. mintegral also passed the ePrivacy privacy protection certification of the famous European privacy protection certification agency AdPlex has also been certified by the kidSAFE Seal Program under the U.S. Children's Online Privacy Protection Act, which means that AdPlex's programmatic interactive advertising platform is certified as compliant with GDPR regulations and effective in safeguarding user privacy. AdPlex has been certified by TrustArc, an authoritative privacy and security certification authority, as compliant with CPPA requirements for AdPlex's handling of customer and end-user personal data, further demonstrating that AdPlex's services provide comprehensive privacy protection for customers and end-device users. Users provide comprehensive privacy protection. AdPlex participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies, AdPlex’s identification number within the framework is [Vendor ID: 867].

AdPlex may retain the information relating to you collected from our Business Partners as necessary for the provision of the services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). We will only keep your personal information for as long as necessary and in any event in relation to personal information collected by us according to this Policy we will only keep this personal information for no more than two (2) years. The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

9. Protection for Minors

AdPlex’s service is not mainly for minors. If a User is deemed as minor under applicable law, please make sure that before the use of the application which integrates AdPlex’s product or service or the application of an advertiser that partners with AdPlex for delivering its ads, parents or other guardian and such User have together read the application’s privacy policy with the guardianship and guiding of parents or other guardian, and their consent have been provided for processing of personal information.

We process minor’s personal information according to requirements of related laws and regulations. Except as otherwise provided by law, we will only collect, use, store, disclose, or make available to the public the personal information where permitted by law, with consent of parents or other guardians, or for the necessity of protection of the minors. If we notice the collection of personal information of minors without verifiable consent of parents, we will take measures to delete related information as soon as possible.

If you are parents or other guardian of minors, please contact us via the email we provide in this Policy when you have any question regarding to the protection of minors.

If you are Users in the U.S., we ensure that we comply with COPPA. If our business partners (such as Publishers) operate apps directed to children under the age of thirteen (13) or knowingly collect, use or disclose personal information of children under the age of thirteen (13) during our cooperation, they will obtain verifiable parental consent for AdPlex to collect, use or disclose such personal information according to this Policy. Further, such business partners must enable the COPPA settings when using the AdPlex Services. This allows AdPlex to ensure that any persistent identifiers collected about Users of apps that are flagged as “child-directed” will be processed according to the requirements of COPPA, including not being used to serve behaviorally-targeted ads or track users for such purposes in violation of COPPA. In addition, we will not knowingly collect any other personal information (such as the precise geo-location of Users’ devices) from Users of Apps that we know to be directed to children under the age of thirteen (13).

If you are Users in California U.S.,we ensure that we comply with CCPA. We will not sell or conduct targeted advertising with the data of consumers under the age of 16, unless there is explicit opt-in consent. If the request for consent is declined, we will not ask again for 12 months. Minors under the age of 13 must get permission from a parent or guardian to opt-in.

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 and we take reasonable steps to ensure that such information is deleted from our files.

10. Marketing

If you are our Business Partners, we or our affiliates may contact you periodically by e-mail to provide information regarding our products, services and content that may be of interest to you. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.

If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the communications or request to be opted-out of receiving such communications via email to privacy@kton.cn

11. Contact Us

You can contact our DPO by sending a written request to privacy@kton.cn. You can also contact our data protection representative in the EEA, Eurocore B.V., with address: Hullenbergweg 278, 1101BV Amsterdam.

Privacy Policy of AdPlex Website

1. Introduction

This Privacy Policy of AdPlex Website applies to information collection and use including while you are visiting and using the AdPlex Site. According to the General Data Protection Regulation (GDPR), AdPlex is the data controller of your personal information.

2. What Information We Collect

As you navigate through this AdPlex Site, we may collect information include:

(1) personal information you voluntarily provide (for example, names, birth dates, numbers or copies of your personal ID card/passport/social security card/driver's license/other license, addresses, telephone numbers, E-mail addresses, occupations, education, work experience, account log-in information, debit or credit card or other payment account information and related information). Among them, numbers or copies of your personal ID card/passport/social security card/driver's license/other license may constitute sensitive personal information under the definition of CCPA.

(2) some information that are not voluntarily provided such as your browser type, domain name, IP address, pages visited, and the length of your user session using various technologies and means, such as Internet Protocol Address, cookies, Internet Tags and navigational data collection.

(3) When you initiate a payment with us, you submit the following personal information to us: the name of the entity to whom you are making the payment, payment currency, your name, your order number, your username/user id in our system, order amount, and product information. After you initiate a payment, we collect the following personal information from our payment service provider: your order number, payment result, description of the payment result (if any).

AdPlex is entitled to take measures to validate the authenticity of personal information you provide.

If you give us personal information of somebody else, you should warrant that you have gained their permission to do so.

We may use Google Analysis that assists us with analysing the usage of our website and help to improve the service quality of our website. For the personal information that may be collected by Google Analysis and its processing activities, please visit: Here

3. How We Use Your Information

Based on your consent or based on our legitimate interests, we may use your personal information for the following purposes: (i) to provide you with AdPlex’s products or services or information; (ii) to sign you up for an event or training; (iii) to contact you and respond to your requests and enquiries; (iv) for business administration, including statistical analysis; (v) to personalize your visit to the AdPlex Site and to assist you while you use the Site; (vi) to improve the AdPlex Site by helping us understand who uses the Site; (vii) to periodically provide you with information about our products and services and content that may be of interest to you by email; or (viii) to complete your payment to us.

If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the emails or request to be opted-out of receiving such communications via email to privacy@kton.cn

4. Disclosure of Your Personal Information

Subject to compliance with applicable laws and regulations, we may disclose User’s personal information to AdPlex’s Affiliates and other third parties.

In order to complete your payment to us, we may transfer your following personal information to our payment service provider by means of API: your order number, order amount, payment currency, product information. The payment service provider is our processor and we transfer the above personal information only for the purpose of completing your payment.

We may use Third-party Technology Service Providers to provide us with services who may have access to your personal information, including companies that assist with technical aspects of hosting and operating the AdPlex Site, technical service provider that assists with analyzing the usage of our website, or email service provider. (please see our Cookies Policy for details).

Except as expressly stated in this Policy, we will not disclose User’s personal information to any third party without User’s consent.We may also share aggregate or anonymous information with other third parties in accordance with the terms of this Policy.

We may disclose users' personal information to our affiliates for the purposes set out in this Policy or to promote the products or services of our affiliates to users.

The servers used in the operation of the AdPlex Site automatically identify a computer by its IP address. Although, we will not be able to identify the computer using its IP address once you have left the AdPlex Site. If we, in good faith, determine that you have or are attempting to misuse or harm the Site, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property.

Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.

5. International Transfers

If you are a United States person, we will comply with DSP and other applicable United States laws and regulations and will not illegally transfer, share or otherwise make available your personal information.

When you are located in the European Econocim Area (“EEA”), personal information collected about you will be transferred to recipients in countries located outside the EEA or can be remotely accessed in countries located outside the EEA, including in countries which may not be decided by the European Commission that it provides an adequate level of protection to personal information. We have followed requirements as set out in applicable law to provide adequate protection to your personal data. To the extent as required by applicable law, our Business Partner will obtain your valid consent to the extent for us to transfer your personal information to recipients including AdPlex’s affiliates and any other recipients as described in this Policy, which are located outside the EEA. You are entitled to withdraw your consent at any time.

AdPlex has entered into EU standard contractual clauses ( “Model Contracts”) for intra-group transfers of personal information to its affiliates. You can request a copy of these Model Contracts by submitting your request via email to privacy@kton.cn

6. Your Data Rights

You have the right to access, modify, correct or delete any personal data which we may have collected. To exercise this right please contact privacy privacy@kton.cn

If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.

If you are residents of the State of California in the United States, you can request the following information about how we have collected and used your personal information during the past 12 months:

The categories of Personal Information we have collected.
The categories of sources from which we collected the Personal Information.
The business or commercial purpose for collecting, selling or sharing Personal Information.
The categories of third parties with whom we disclose the Personal Information.
The categories of Personal Information that we sold, shared or disclosed for a business purpose.
The categories of third parties to whom the Personal Information was sold, shared or disclosed for a business purpose.
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
You can ask us to delete the Personal Information that we have collected from you.
You can ask us to correct inaccuracies of your Personal Information.

You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.You may (i) submit requests to exercise your California privacy rights described above by writing to us at: privacy@kton.cn or send a written document to the following address: Legal Department, 5050 El Camino Real, Suite 400, Los Altos, CA 94022; (ii) opt out of selling or sharing of your data by clicking on the following link:DO NOT SELL OR SHARE MY DATA and (iii) submit requests to restrict the use of your sensitive Personal Information by writing to us at: privacy@kton.cn.

We recognize the Global Privacy Control (GPC) available in some web browsers. If your browser is configured to send this signal, we will opt you out of sharing your personal information on that browser.

When you submit a request we will verify your request by the information you provide (e.g. device ID, company email) according to our internal guidelines. You may designate an authorized agent to make a request to know or a request to delete your personal information by providing the authorized agent written permission to do so; and by verifying your own identity with us directly. We will deny any requests from agents that do not submit proof of authorization. For request metrics as designated by the CCPA, please see here.

For clarity, we do not sell or share (as defined under the CCPA) your Personal Information.

You can also find a list of the categories of Personal Information that we collect and details regarding the sources from which we obtain Personal Information in the “What Information We Collect” section above. For the categories of sensitive Personal Information that we collect and details regarding the sources from which we obtain your sensitive Personal Information, please find in the “What Information We Collect” section above. We collect and use personal information for the business or commercial purposes described in the “How We Use Your Personal Information” section above.For sensitive Personal Information we collected of you, we use it for identification for maintaining your account only, and we do not sell or share your sensitive Personal Information. We retain you sensitive Personal Information for as long as you maintain a business relationship with us.

If you are (i) a resident of the State of Virginia in the United States, effective January 1, 2023, (ii) a resident of the State of Colorado in the United States, effective July 1, 2023, (iii) a resident of the State of Connecticut in the United States, effective July 1, 2023, or (iv) a resident of the State of Texas in the United States, effective July 1, 2024, you may exercise the following personal information rights with us:

to confirm whether we are processing your personal information and to access that personal information;
to correct any inaccuracies in your personal information;
to delete your personal information;
to obtain a copy of the personal information you have provided to us; and
to request a refusal to allow us to process your personal information for the purposes of (i) personalized advertising, (ii) selling your personal information, or (iii) user profiling that has significant legal or similar implications for you.

As set forth in the VCDPA, CPA, CDPA , and TDPSA you have the right to exercise the above rights without discrimination.

You may (i) exercise your rights to personal information as described above by sending email to privacy@kton.cn and (ii) click on this link to refuse personalized advertising, refuse the sale of your personal information, and refuse user profiles that have a significant legal or similar impact on you. If you fail to provide valid information for our effective feedback, etc. when exercising your rights as described above, we may deny your right to exercise your rights. If you have any dispute on such denial, you may raise such dispute by sending email to privacy@kton.cn.

If you are a resident of the State of Utah in the United States, effective December 31, 2023, you may exercise the following personal information rights with us.

to confirm whether we are processing your personal information and to access that personal information;
to delete your personal information;
to obtain a copy of the personal information you have provided to us; and
to request a refusal to allow us to process your personal information for the purposes of (i) personalized advertising, or (ii) selling your personal information.

As set forth in the UCPA you have the right to exercise the above rights without discrimination.

You may exercise your rights to personal information as described above by sending email to privacy@kton.cn. If you fail to provide valid information for our effective feedback, etc. when exercising your rights as described above, we may deny your right to exercise your rights. If you have any dispute on such denial, you may raise such dispute by sending email to privacy@kton.cn.

If you are a resident of the State of Oregon in the United States, effective July 1, 2024, you may exercise the following personal information rights with us.

to confirm whether we are processing your personal information and to access that personal information;
to obtain a list of third parties to whom we disclose personal information;
to correct any inaccuracies in your personal information;
to delete your personal information;
to obtain a copy of the personal information you have provided to us; and
to request a refusal to allow us to process your personal information for the purposes of (i) personalized advertising, (ii) selling your personal information, or (iii) user profiling that has significant legal or similar implications for you.

As set forth in the OCPA you have the right to exercise the above rights without discrimination.

You may (i) exercise your rights to personal information as described above by sending email to privacy@kton.cn and (ii) click on this link to refuse personalized advertising, refuse the sale of your personal information, and refuse user profiles that have a significant legal or similar impact on you. If you fail to provide valid information for our effective feedback, etc. when exercising your rights as described above, we may deny your right to exercise your rights. If you have any dispute on such denial, you may raise such dispute by sending email to privacy@kton.cn.

7. Security of Your Personal Information

The security of User’s information is our utmost priority, and we take strict measures in order to protect our data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for User’s information. Physical access is strictly controlled both at the perimeter and at building ingress points by our staff utilizing video surveillance and other electronic means.

We also protect User’s privacy by seeking to minimize the amount of sensitive data that we store on our servers in the first place. We also seek appropriate contractual protection from our partners regarding their treatment of user data.

We will only keep your personal information for as long as necessary and in any event in relation to personal information collected by us on the Site we will only keep this personal information for one (1) year. For personal information collected via Google Analytics the following retention periods apply: Here

8. Protection of Minors

The Site does not knowingly collect any personal information from minors. The personal information of any minor you provide shall be agreed by the minor’s parent or guardian in advance. Minor is defined in accordance with the laws applicable to this Policy of AdPlex Website.

We process minor’s personal information according to requirements of related laws and regulations. Except as otherwise provided by law, we will only collect, use, store, disclose, or make available to the public the personal information where permitted by law, with consent of parents or other guardians, or for the necessity of protection of the minors. If we notice the collection of personal information of minors without verifiable consent of parents, we will take measures to delete related information as soon as possible.

If you are parents or other guardian of minors, please contact us via the email we provide in this Policy when you have any question regarding to the protection of minors.

If you are Users in the U.S., we ensure that we comply with COPPA. If our business partners (such as Publishers) operate apps directed to children under the age of thirteen (13) or knowingly collect, use or disclose personal information of children under the age of thirteen (13) during our cooperation, they will obtain verifiable parental consent for AdPlex to collect, use or disclose such personal information according to this Policy. Further, such business partners must enable the COPPA settings when using the AdPlex Services. This allows AdPlex to ensure that any persistent identifiers collected about Users of apps that are flagged as “child-directed” will be processed according to the requirements of COPPA, including not being used to serve behaviorally-targeted ads or track users for such purposes in violation of COPPA. In addition, we will not knowingly collect any other personal information (such as the precise geo-location of Users’ devices) from Users of Apps that we know to be directed to children under the age of thirteen (13).

If you are Users in California U.S.,we ensure that we comply with CCPA. We will not sell or conduct targeted advertising with the data of consumers under the age of 16, unless there is explicit opt-in consent. If the request for consent is declined, we will not ask again for 12 months. Minors under the age of 13 must get permission from a parent or guardian to opt-in.

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 and we take reasonable steps to ensure that such information is deleted from our files.

9. Use of Cookies and Other Tracking Technologies

AdPlex may use cookies or other technology (collectively “Cookies”) to collect certain information about you when you are visiting the Site. Please read our Cookies Policy for more details.

10. Outside Sites and Linking

The Site may contain links and pointers to other sites on the Internet that are owned or operated by third party vendors and other third parties (the “ Outside Sites “). AdPlex is not responsible for the availability of, or the content located on or through, any Outside Site, including any webcasting or other form of transmission received from any Outside Sites. You should contact the site administrator or Webmaster for those Outside Sites if you have any concerns regarding such links or the content located on such Outside Sites. AdPlex permits certain third party links to the home page of its Site, provided that AdPlex is provided with notice of such links and does not thereafter object to such linking. AdPlex a reserves the right to revoke unilaterally any consent that it may at any time give to any linkage, including linkages to the home page. The Outside Sites are being provided to you only as a convenience and any link or pointer contained on this Site does not imply endorsement of the Outside Sites.

11. Copyright

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 AdPlex, 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 AdPlex 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.

12. Trademarks

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

13. Online Conduct

Any conduct by a person that in AdPlex ‘s sole discretion restricts or inhibits any other person from using or enjoying the Site, is prohibited. You agree to use the Site only for lawful purposes and in accordance with that prohibition. You agree that you will not post on the Site or transmit any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, sexually explicit, profane, hateful, racially, ethnically, or otherwise objectionable material of any kind, including, but not limited to, any material that encourages conduct that would constitute a criminal offense, give rise to civil liability or otherwise violate any applicable local, state, national, or international law.

14. Termination of Usage

AdPlex may, without incurring any liability to you, terminate access by you or suspend any access to all or part of the Site, without notice, for any conduct that AdPlex, in its sole discretion, believes is in violation of any applicable law or this Agreement, or is harmful to the interests of another user, a third-party, a merchant, a sponsor, a licensor, a service provider, or the Site.

Due to the rapidly evolving technologies on the Internet, we may occasionally update this Policy. All revisions will be posted to this website adplex.kton.cn

15. Contact Us

You can (i) contact our DPO by sending a written request to privacy@kton.cn. You can also contact our data protection representative in the EEA, Eurocore B.V., with address: Hullenbergweg 278, 1101BV Amsterdam.

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