Privacy Policy

Effective Date: 2019-03-04

We take your privacy and data security seriously. This privacy policy (“Privacy Policy”) is meant to help you understand what information TouchPal HK Co., Limited and its affiliates and subsidiaries (collectively, “we”, “us” or “our”) collect, how we use such information, and the recipients with whom we share such information.

This Privacy Policy applies to your access and use of our ad exchange platform (including demand side platform and supply side platform) along with any revisions, updates and/or modifications hereto (collectively, the “Platform”) and any data, products, services and associated materials or media supplied with the Platform (the “Services”).

By using the Services, you agree that we may treat your information in the ways we describe in this Privacy Policy. If you do not agree with any term of this Privacy Policy, you may not use the Services. This Privacy Policy contains the following sections:

1. What Information We Collect

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you register for an account, deliver advertisements, use the Services, participate in a survey, contest, promotion or event or otherwise communicate with us.

The types of information we may collect from you include:

  • (a) Account Information: We may collect information relating to your account, such as your name, company, email address, password, location, and any other information you choose to provide.
  • (b) Transaction Information: We may collect information relating to any prepayment you make. We may also collect and store limited payment information from you such as payment type and other payment information provided by you in your account.
  • (c) Other Information You Choose to Provide, such as your contacts, your notices and support requests.

Information We Collect Automatically

When you access or use the Services, the types of information we may automatically collect about you include:

  • (a) Log Information: When you visit the Platform, our servers automatically record certain log file information, such as your Internet Protocol (“IP”) address and other information about your activities on the Services.
  • (b) Information Collected by Cookies and Other Tracking Technologies:We and our service providers use various tracking technologies, such as but not limited to cookies, to collect information about you when you interact with the Services, including information about your browsing and bidding behavior. Cookies are small data files stored on your hard drive or in device memory that help us improve the Services and your experience, see which areas and features of the Services are popular, and count visits. For more information about cookies, and how to disable them, please see “Your Choices” below.

For Supply Partners

  • (c) Device Information of end users: such as device os, IDFA (Identifier For Advertising for iOS) or GAID (google advertising id for Android); operating system and system language; device properties related to screen size & orientation; carrier. This device information may be collected across mobile apps and websites over time.
  • (d) Advertisement and Publication Related Information: such as impression, click, pay, sale, purchase, download, response, install, order, transaction, lead, action, retention rate, publication area.
  • (e) Location Information: such as longitude and latitude of GPS; mac address. We’ll collect end users’ location information when there’s any requirement of personalized advertisement.

For Demand Partners

  • (f) Advertisement-Related Information: such as targeting country or area, targeting customer, the products and/or services for promotion within the advertisement; the landing page of the advertisement, bidding information and other information relating to your participation in a bidding and delivery of advertisement.

2. How We Use Your Information

We may use your information for various purpose, including to:

  • (a) provide, maintain and improve the Services;
  • (b) manage your bidding and advertising-related data, and delivery of advertisement;
  • (c) manage your account and send you related information, including but not limited to confirmations, updates, technical notices, security alerts, support and administrative messages;
  • (d) respond to your comments, questions and requests;
  • (e) communicate with you about the Services, offers, surveys, events and other news and information we think may be of interest to you;
  • (f) monitor and analyze trends, usage and activities in connection with the Services;
  • (g) detect, investigate and prevent unacceptable advertisement, fraudulent transactions and other illegal activities and protect our and others’ rights and property;
  • (h) carry out any other purpose for which the information was collected.

3. How We Share Your Information

We may share your information as follows or as otherwise described in this Privacy Policy:

  • (a) with vendors, consultants, demand partners and supply partners who need access to such information to carry out work or perform services on our behalf;
  • (b) with our service providers such as some information and technology companies that help us monitor advertising-related activities (including but not limited to the verification of the content of advertisement and the monitoring of advertisement delivery behavior), or that provide products or services to you;
  • (c) in response to a request for information if we believe such disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process;
  • (d) to protect our and other party’s rights, property or safety;
  • (e) in connection with, or during negotiations of, any merger, acquisition, sale of assets or any business, other change of control transaction or financing;
  • (f) between and among us and any current or future parent, subsidiary and/or affiliated company;
  • (g) with your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

4. Security

The security of your information is important to us. We implement and maintain reasonable security measures intended to protect against unauthorized use, disclosure, alteration or destruction of the information we collect and maintain. However, please be aware that, despite our efforts, no data security measures, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the absolute security of your information transmitted to, through or on the Services or via the Internet and that, any such transmission is at your own risk.

Where we have given you (or where you have chosen) a password which enables you to access to your account, you are responsible for keeping this password confidential. Please do not to share a password with anyone.

5. Changes to This Privacy Policy

We reserve the right to amend this Privacy Policy at any time. You will know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing using the Platform and the Services after changes have been posted, you are confirming that you have read, understood and consented to the latest version of this Privacy Policy.

6. Your Choices

  • (a) Account Information

    You may update, correct or modify information about you at any time by logging into your online account or by emailing us at if you are a demand partner or at if you are a supply partner. If you wish to deactivate your account, please email us at if you are a demand partner or at if you are a supply partner, but note we may continue to store your information as required by law or for legitimate business purposes.
  • (b) Cookies

    Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services.

7. Contact Information

If you have any questions or opinions regarding this Privacy Policy, you may contact us at if you are a demand partner or at if you are a supply partner.