PRIVACY POLIC | Moblegend Technology Limited

Last updated on May 14, 2024

This Privacy Policy explains how Moblegend entities (for purposes of European data protection laws, those entities providing the Moblegend Advertising Service, which are subject to GDPR, can be viewed HERE) collect your information through our advertising platform (“Advertising Service”) and our website at www.moblegend.net (“Site” or “Website”).

This Privacy Policy is governed by any service agreement between Moblegend and you. By using the Advertising Service or this Site, you acknowledge that you have read and understood this Privacy Policy. Please review it before using the Advertising Service or the Site.

We periodically evaluate and improve our privacy policies and practices. This Privacy Policy will be reviewed and updated as necessary, at least every 12 months. If we make significant changes to this Privacy Policy, we will notify you with a prominent notice on the Site prior to the changes taking effect.

Privacy Policy of Moblegend’s Website

1. Introduction

This Privacy Policy of Moblegend’s Website applies to information collection and use including while you are visiting and using the Site. For the purposes of EU General Data Protection Regulation (“GDPR”), Moblegend is the data controller of your personal information.

2. What Information We Collect

As you navigate through this Site, some of your personal information may be actively collected (for example, names, birth dates, personal ID card numbers, addresses, telephone numbers, E-mail addresses, occupations, education, work experience and related information) or passively collected (which you did not actively provide) 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. In order to improve our service quality, it may be necessary to ask for personal information to fulfill your requests and provide a better service. Moblegend is entitled to take measures to validate the authenticity of personal information you provide. If you give us personal information of somebody else, we will assume that you have their permission to do so. Transmissions to and from this Site may not be confidential and consequently, may be read or intercepted by others.

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 Moblegend products or services or information in relation to the same; (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 personalise your visit to the Site and to assist you while you use the Site; or (vi) to improve the Site by helping us understand who uses the Site.

4．The Legal Basis for Our Processing of Your Personal Information

We may process your personal information based on your consent. You can withdraw your consent at any time.

If you are located in the EEA, we may use your personal information based on the "legitimate interests" set forth in the GDPR, in necessary cases. Our legitimate interests include: remove technical obstacles to system operation and ensuring systems and processes work properly and securely.

5．Disclosure of Your Personal Information

We may use selected third parties to provide us with services, including companies that assist with programming and technical aspects of hosting and operating the Site, who may have access to your personal information. Our affiliates may also have access to your personal information including through or in connection with this Site for the purposes set out in this Privacy Policy.

The servers used in the operation of the 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 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, reorganisation or otherwise.

6．International Transfers

When you are located in the EEA, personal information collected from you, including via the Site, will be transferred to recipients in countries located outside the EEA (including in Singapore where the Site is hosted) which do not provide a similar or adequate level of protection to that provided by countries in the EEA.You hereby expressly consent to the transfer of your personal information to recipients, as described in this Privacy Policy, which are located outside the EEA.

Moblegend 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 service@moblegend.net.

For the transfer of personal information to AroundDeal, we have entered into an EU Standard Contract Clause with AroundDeal (" AroundDeal Standard Contract ") for the transfer of personal information to AroundDeal. You can request a copy of your AroundDeal standard contract by sending an email to service@moblegend.net.

When you are located in the mainland areas of China, we store your personal information inside the mainland areas of China. Where it is necessary to provide your personal information to recipient outside mainland areas of China, we will transfer your personal information according to the requirement of any applicable data protection law.

7．Your Data Rights

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, effective from January 1, 2020, you can request the following information about how we have collected and used your Personal Information during the past 12 months:

You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.You may submit requests to exercise your California privacy rights described above by writing to us at: service@moblegend.net You can provide opt-in consent for sale of personal information about them by writing email to us at service@moblegend.net.

These rights are not absolute, and in some instances, we may decline your request as permitted by law. We will need to verify your identity by_examining the information you provide (e.g. device id, email address) according to our internal guidelines, to process your information, access, and deletion requests and reserve the right to confirm your California residency. 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 clarity, we do not sell or share (as defined under the CCPA) your personal information.

If you are residents of the State of Utah in the United States, effective from December 31, 2023, you have rights to:

As set out in the the Utah Consumer Privacy Act (“UCPA”), you have the right to exercise the above rights without discrimination.

You may exercise your UCPA personal information rights as described above by sending a written request to service@moblegend.net.

If you fail to provide us with valid information for effective feedback, etc. when exercising the above rights, we may refuse to exercise your rights, and if you have a different opinion, you may further send a written complaint to service@moblegend.net.

If you are residents of the State of Connecticut in the United States, effective from July 1, 2023, you have rights to:

As set forth in the Connecticut Data Privacy Act (“CDPA”), you have the right to exercise the above rights without discrimination.

You may exercise your Connecticut personal information rights described above (i) by sending a written request to service@moblegend.net;

If you fail to provide us with valid information for effective feedback, etc. when exercising the above rights, we may refuse to exercise your rights, and if you have a different opinion, you may further send a written complaint to service@moblegend.net.

If you are residents of the State of Colorado in the United States, effective from July 1, 2023, you have rights to:

As set forth in the Colorado Privacy Act (“CPA”), you have the right to exercise the above rights without discrimination.

You may exercise your Colorado personal information rights described above (i) by sending a written request to service@moblegend.net;

If you fail to provide us with valid information for effective feedback, etc. when exercising the above rights, we may refuse to exercise your rights, and if you have a different opinion, you may further send a written complaint to service@moblegend.net.

If you are a resident of the State of Virginia in the United States, as of January 1, 2023, you may exercise the following personal information rights with us:

As set forth in the Virginia Consumer Data Protection Act (“VCDPA”), you have the right to exercise the above rights without discrimination.

You may exercise your Virginia personal information rights described above (i) by sending a written request to service@moblegend.net; >

If you fail to provide us with valid information for effective feedback, etc. when exercising the above rights, we may refuse to exercise your rights, and if you have a different opinion, you may further send a written complaint to service@moblegend.net.

8．Security of Your Personal Information

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. 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:

https://support.google.com/analytics/answer/7667196?hl=en

9．The 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 the Privacy Policy.

10．Marketing

We 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 service@moblegend.net.

11．Use of Cookies and Other Tracking Technologies

Moblegend may use cookies, or other technology (collectively "Cookies") to collect certain information about you when you are visiting the Site. Cookies is a small 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. Generally, the purpose of Cookies is to provide convenience. You may reject our Cookies or delete them manually. Please however note, that, if you delete or reject Cookies, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly. To find out more about Cookies generally, please visit www.allaboutcookies.org.

12．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"). Moblegend 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. Moblegend permits certain third party links to the home page of its Site, provided that Moblegend is provided with notice of such links and does not thereafter object to such linking. Moblegend 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.

13．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 Moblegend, 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 Moblegend 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.

14．Trademarks

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

15．Online Conduct

Any conduct by a person that in Moblegend'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.

16．Termination of Usage

Moblegend 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 Moblegend, in its sole discretion, believes is in violation of any applicable law, or is harmful to the interests of another user, a third-party, a merchant, a sponsor, a licensor, a service provider, or the Site.


Privacy Policy of Moblegend’s Advertising Service

1. Introduction

This Privacy Policy of Moblegend’s Advertising Service applies to information collection and use while you: (i) view ads served by Moblegend’s Advertising Service; (ii) interact with Moblegend’s Advertising Service; or (iii) interact with the platforms, applications, websites or any other service provided by Moblegend’s business partners (e.g. app publisher, advertiser) . Unless otherwise explicitly stated hereunder, Moblegend acts as a data controller under the GDPR when processing your personal information in the provision of Moblegend’s Advertising Service.

2．What Information We Collect

When you: (i) view ads served by Moblegend’s Advertising Service; (ii) interact with Moblegend’s Advertising Service; or (iii) interact with services provided by Moblegend’s business partners, we and/or our business partner may collect the following personal information from you: Device make, device model, operating system (e.g. iOS), device type (e.g. smartphone, tablet, etc.), device properties related to screen size and orientation, audio volume and battery, network connection type, IP address, Internet browser user-agent used to access the Advertising Service, identifier for advertisers (IDFA), timestamp, iOS identifier for advertising, OS version of device, international mobile equipment identity (IMEI), geo-location data, information about when and for how long you use the Advertising Service or any service provided by Moblegend’s business partners, transactional data related to your interaction with an application, website, platform, or service provided by Moblegend’s business partners, such as information about the actions taken in an application like purchases or application installations; device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL. We also provide Advertising Service for our advertisers and publishers through our ad platform. We may collect the email address, account name and password, IP address and address of individuals using our ad platform.

3．How We Use Your Information

We use your personal information to display advertising on your device, which may include interest-based advertising customized to individuals’ inferred interests, preferences, locations and other features. Where required, our business partners will obtain your consent for and on our behalf for the processing of your personal information to display advertising on your device. You can withdraw your consent at any time. 

Where necessary in our legitimate interests we use your personal information: (i) to understand and analyze your usage trends and preferences and improve our Advertising Service; or (ii) for purpose of anti-fraud and traffic quality monitoring in order to perform the contractual obligations to our advertisers and publishers. We may also use your personal information to comply with applicable laws, regulations or codes of practice.

For the purpose of ads attribution and making settlement, detecting fraud and resolving dispute related to Moblegend’s Advertising Service, Moblegend acts as a data processor.

4．The Legal Basis for Our Processing of Your Personal Information

Our legal basis for processing your personal information is your consent. Where required by applicable law, our business partners (e.g. advertisers, publisher) will obtain your consent for and on our behalf of our processing of your personal information described in this Privacy Policy. You can withdraw your consent at any time.

If you are located in the EEA, we may use your personal information based on the "legitimate interests" set forth in the GDPR, in necessary cases. Our legitimate interests include: remove technical obstacles to system operation and ensuring systems and processes work properly and securely.

5．Disclosure of Your Personal Information

We may disclose your personal information to our business partners, including advertisers, publishers, and data tracking companies. These business partners may use your personal information to show you advertisements, measure your ad/site interaction, and better understand the site and app traffic usage or user behaviour in order to improve their services. Such partners’ use of the information that we disclose to them will be governed by their privacy policies. We may disclose your personal information to our trusted agents and service providers so that they can perform requested services on our behalf. For example, we may share payment information with a third party service provider in order to assist us with processing credit card payments. These entities are prohibited from using User’s information for any purposes other than providing us with requested services. We may also share aggregate or anonymous information with other third parties in accordance with the terms of this Policy. Our affiliates may also have access to your personal information collected through our Advertising Service for the purposes set out in this Privacy Policy. 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, reorganisation or otherwise.

6．International Transfers

When you are located in the EEA, personal information collected from you, including though our Advertising Service, will be transferred to recipients in countries located outside the EEA (including China, US, India, Korea, Singapore, Australia, Japan, Canada, France, Ireland, Britain, Germany, Brazil), which do not provide a similar or adequate level of protection to that provided by countries in the EEA. Where required by law, the publisher and/or advertiser will obtain your consent to the transfer of your personal information to recipients, as described in this Privacy Policy, which are located outside the EEA. You may withdraw your consent at any time. Moblegend 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 service@moblegend.net.

7．Your Data Rights

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 you 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, effective from January 1, 2020, you can request the following information about how we have collected and used your personal information during the past 12 months:

These rights are not absolute, and in some instances, we may decline your request as permitted by law. We will need to verify your identity by_examining the information you provide (e.g. device id, email address) according to our internal guidelines, to process your information, access, and deletion requests and reserve the right to confirm your California residency. 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.

We have sold and shared the personal information listed out in the Section 2 of this Privacy Policy to our affiliates for a business or commercial purpose in the preceding 12 months. We do not sell personal information of minors under the age of 16 without affirmative authorization.

If you are residents of the State of Utah in the United States, effective from December 31, 2023, you have rights to:

As set out in the the Utah Consumer Privacy Act (“UCPA”), you have the right to exercise the above rights without discrimination.

You may exercise your UCPA personal information rights as described above by sending a written request to service@moblegend.net.

If you fail to provide us with valid information for effective feedback, etc. when exercising the above rights, we may refuse to exercise your rights, and if you have a different opinion, you may further send a written complaint to service@moblegend.net.

If you are residents of the State of Connecticut in the United States, effective from July 1, 2023, you have rights to:

As set forth in the Connecticut Data Privacy Act (“CDPA”), you have the right to exercise the above rights without discrimination.

You may exercise your Connecticut personal information rights described above (i) by sending a written request to service@moblegend.net;

If you fail to provide us with valid information for effective feedback, etc. when exercising the above rights, we may refuse to exercise your rights, and if you have a different opinion, you may further send a written complaint to service@moblegend.net.

If you are residents of the State of Colorado in the United States, effective from July 1, 2023, you have rights to:

As set forth in the Colorado Privacy Act (“CPA”), you have the right to exercise the above rights without discrimination.

You may exercise your Colorado personal information rights described above (i) by sending a written request to service@moblegend.net;

If you fail to provide us with valid information for effective feedback, etc. when exercising the above rights, we may refuse to exercise your rights, and if you have a different opinion, you may further send a written complaint to service@moblegend.net.

If you are a resident of the State of Virginia in the United States, as of January 1, 2023, you may exercise the following personal information rights with us:

As set forth in the Virginia Consumer Data Protection Act (“VCDPA”), you have the right to exercise the above rights without discrimination.

You may exercise your Virginia personal information rights described above (i) by sending a written request to service@moblegend.net;

If you fail to provide us with valid information for effective feedback, etc. when exercising the above rights, we may refuse to exercise your rights, and if you have a different opinion, you may further send a written complaint to service@moblegend.net.

8．Security of Your Personal Information

The security of your 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 Advertising 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 your 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 not collect your sensitive personal information without your consent. (For purposes of GDPR, CCPA, CDPA, CPA, UCPA and VCDPA, we do not process your sensitive personal information.) We also seek appropriate contractual protection from our partners regarding their treatment of user data. Moblegend may retain the information relating to you collected as necessary for internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the services and operate the business; (ii) the type of personal information 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．Children

We ensure that we comply with the Children's Online Privacy Protection Act (COPPA), and does not knowingly collect personal information about users of websites or apps directed to children under the age of thirteen (13). 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

We 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 service@moblegend.net.

Contact Us

If you have any question or comment about this Policy, please contact Moblegend's Data Protection Officer at service@moblegend.net. You can also write to the data protection representative Eurocore B.V. in the EEA at:

Hullenbergweg 278, 1101BV Amsterdam