Partner Policy

This Partner Policy (the "Policy") is issued by HONG KONG ZHIONE TECHNOLOGY CO., LIMITED and its afiliates, hereby incorporated into the Service Agreement with the TradPlus Partner. In case of any conflict between this policy and the Service Agreement, the provisions of the Service Agreement shall prevail.

Developers, advertisers, publishers, advertising platforms, demand-side platforms (“DSP”) , supply-side platforms (“SSP”) and other partners (hereinafter collectively referred to as "You") will cooperate with TradPlus in corresponding advertising business during the use of TradPlus services. To ensure the compliance of the cooperation between the two parties, such as data security, data protection, advertising behavior and other compliance requirements, you shall comply with this policy. Otherwise, TradPlus has the right to unilaterally restrict, suspend or terminate the provision of services to you at any time, and has the right to hold you accountable for the relevant responsibilities.

1.Definition.

TradPlus. It refers to HONG KONG ZHIONE TECHNOLOGY CO., LIMITED and its affiliates, which provides TradPlus Services under this Agreement.

Affiliate. That means, as to an entity, any other entity directly or indirectly controlling, controlled by, or under common control with, such entity.

Advertising/Ad/Ads. That means any advertising content including any graphic and/or, audio, and/or audio-visual video advertising to be displayed on the Supply Inventory in different formats.

Advertising Inventory. That means any and all digital advertising inventory, including (but not limited to) websites, applications, mobile websites, mobile applications, and any other digital properties for the display of Ads.

Advertising Creatives. That means artwork, copy, or active URLs for Ads.

Data Protection Laws. That means any applicable laws, rules, regulations, policies and industry self-regulatory regimes in any relevant jurisdiction relating to the collection, use, processing, sharing and/or disclosure of data including: (i) in China, the personal data Protection Law of the People’s Republic of China (“PIPL”); (ii) in the European Union, the General Data Protection Regulation (“GDPR”); (iii) in the United States, the Children’s Online Privacy Protection Act (“COPPA”) , the California Privacy Rights Act (“CPRA”) ; (iv) in the United Kingdom, the Data Protection Act 2018 (“DPA”); and (v) the above laws as updated, amended or replaced from time to time.

Service Agreement. It refers to the various service agreements signed by TradPlus and you based on the advertising business cooperation, such as the aggregation Agreement, ADX Agreement, etc.

Personal Data. It refers to all kinds of information recorded electronically or otherwise and related to the identified or recognizable natural persons, excluding the anonymized information.

Data Processing.It refers to any operation or a series of operations on the data, including but not limited to data collection, recording, analysis, storage, inquiry, use, transmission, disclosure, sharing, transfer, correction, deletion, backup, or destruction and other operations.

Invalid Traffic. It refers to the click or display that leads to the advertiser fee or publisher revenue to increase through cheating. The activity that results in an invalid traffic is called an invalid activity.

2.Data Protection.

You promise and guarantee that you have all the necessary qualifications and legal authorization for the performance of the Service Agreement and this Agreement, and you have complied with the provisions of the relevant Data Protection Law. Including but not limited to:

(1) For the personal data you have provided to TradPlus, you have been legally authorized by the relevant individual or comply with the relevant data protection laws.

(2) You have fully fulfilled the relevant obligations stipulated in the data protection laws for your personal data cooperation behavior under this policy, including but not limited to informing individuals and obtaining personal consent.

(3) You have legal rights or legal authorization for other data other than personal data involved in the data cooperation agreed in this Policy, and may cooperate in accordance with the provisions of this Policy.

When you provide the data to TradPlus, you should clearly inform TradPlus of the following:

(1) For the personal data of cooperation, TradPlus shall be clearly informed: the source of relevant personal data, the type of personal data of cooperation, and the scope of authorization of personal data processing you have obtained.

(2) For other data except personal data, TradPlus shall be clearly informed of the ownership, data type, scope of purpose, etc.

You promise and guarantee that:

(1) The personal data you collect and provide to TradPlus has been legally authorized by the relevant individuals, and the cooperation with TradPlus is within the scope of the individual's authorization for you to process. TradPlus has the right to view the text of your personal authorization consent, and you should cooperate to provide it;

(2) Your data processing request to TradPlus shall not violate the provisions of any data protection laws or other laws and regulations, and does not infringe on the legitimate rights and interests of any person, otherwise TradPlus has the right to take measures such as refusing your data processing request, immediately terminating the data processing behavior, and has the right to terminate the service;

(3) You shall strictly follow the provisions of any applicable data protection laws, this Policy, the TradPlus Terms of Service andTradPlus Privacy Policy. Data processing results reported by TradPlus shall not be transferred, shared or disclosed to any third party without the consent of TradPlus. If required by TradPlus, you should delete the data processing results reported by TradPlus in the cooperation matters before the end of the cooperation.

(4) You are prohibited from transmitting or sharing any data of children under the age of 16 to TradPlus.

3.Advertising Policy.

You shall not engage in any violation of laws and regulations, including but not limited to below, nor shall you publish, release, provide or facilitate other third parties (including but not limited to the behavior of developers, users) to publish the following violations:

contains or promotes obscenity, pornography, gambling, superstition, terror, or violence;

contains discrimination or denigration of any race, religion, gender, sexual orientation or national origin;

contains guns, ammunition, or other weapons;

contains false, empty (no content), misleading and deceptive statements;

contains automatic jumps, forced/malicious loading, illegal links, Trojan horse programs, etc.;

contains or promotes illegal activities including but not limited to hacking, phone fraud, and Internet fraud;

spreading rumors, disturbing social order or undermining social stability;

spreading obscenity, pornography, gambling, violence, murder, terror or abetting crimes;

insulting or defaming others, or infringing upon the legitimate rights and interests of others

contains or promotes other illegal or inappropriate activities.

You shall also take further measures to prevent and resist the following negative information:

(1) Using exaggerated titles, the content of which is seriously inconsistent with the title;

(2) Hype about gossip, scandal, bad deeds, etc.;

(3) Inappropriate comments on natural disasters, major accidents and other disasters;

(4) Containing sexual innuendos, sexual provocations, etc. that can easily cause people to have sexual associations;

(5) Displaying blood, horror, cruelty, etc. that cause physical and mental discomfort;

(6) Inciting discrimination against groups of people, regional discrimination, etc.;

(7) Promoting vulgar, banal, and kitsch content;

(8) May cause minors to imitate unsafe behaviors and violate social morality, induce minors to have bad habits, etc.;

(9) Inciting illegal gatherings, associations, marches, demonstrations, and gatherings to disturb social order;

(10) Activities in the name of illegal non-governmental organizations;

(11) Other content that has a negative impact on the network ecology.

4.Anti-traffic Fraud.

TradPlus prohibits any improper means to create false or invalid traffic, clicks, downloads, or illegal embedding, including but not limited to the following forms:

(1) Illegal promotion traffic.

It is prohibited to earn promotion traffic by self-, forced, induced, or programmatic access, automatic refresh and other related means to perform invalid or hidden promotion behaviors.

(2) Modification of promotion content.

a. Redirect the promotion page clicked by the user to another place, which is different from the page seen by the end user when directly accessing the promotion page;

b. Use "crawl", "spider", index or any other method to store or cache any part, copy or derivative information of the promotion content;

c. After the promotion content is displayed, change the attributes of the promotion content, such as: change the promotion location, promotion content size, etc., any attribute of the promotion element.

(3) Inducing or forcing users to click.

a. In non-incentive advertising cooperation, exchanging resources and rewards for user clicks;

b. Forcing users to click on promotions in exchange for the number of times they use the app or continue to use the app;

c. Blocking or hiding any part of the promotion display area, including logos, links, descriptions, etc., causing the promotion content to overlap with the page content;

d. It is prohibited to falsify clicks to obtain revenue through other illegal means.

(4) The following brushing and cheating behaviors occur, including but not limited to:

a. Hiring or instigating others to click on a large number of delivery content;

b. Downloading delivery products for users through mobile phone stores and pre-installed channels;

c. Using test machines or simulators to download in large quantities;

d. Using technical means to simulate clicks or download activation;

e. Using technical means to change the display form of SDK, JS, API ads (such as ad strips and clickable operations of inserts);

f. Modifying device information through manual means to achieve the effect of brushing;

g. Any other brushing or cheating behaviors, etc.

5.Anti-commercial Bribery.

You hereby promise to TradPlus that you, your affiliates, your or its affiliates' managers, directors, legal representatives, shareholders, consultants, agents, employees (including temporary), staff, and obligors who assist you in fulfilling the contract (hereinafter collectively referred to as "your staff") will voluntarily abide by the provisions of this policy and shall not seek profit through TradPlus, TradPlus' affiliates, TradPlus or its affiliates' staff (hereinafter collectively referred to as "TradPlus staff") or their close associates (including but not limited to spouses, relatives, lovers, teachers and students, classmates, comrades-in-arms, friends, former colleagues, etc., the same below).

You and your staff shall not directly or indirectly, expressly or implicitly propose, promise, agree, acquiesce, ratify, or deliver any form of benefits to TradPlus personnel or their close associates in any name, including but not limited to money, consumer cards, dry stock dividends, securities, equity debts, financial products, virtual property, gift samples, rebates, banquets, entertainment and travel, consumption arrangements, property borrowing, debt deductions, fee reductions, labor services, employment and housing, medical treatment and education, honorary titles, qualification assessments, special treatment, etc.

You and your staff shall not engage in any form of economic transactions (including but not limited to loan investment, borrowing and leasing, guarantee and mortgage, etc.) or cooperation (including but not limited to equity investment, consulting, employment, etc.) with TradPlus personnel or their close associates in any name.

You and your staff shall not provide any form of assistance to TradPlus personnel or their close associates in seeking, obtaining, disguising or concealing interests under this policy, including but not limited to mediation, custody holding, lending accounts, destroying credentials, fabricating facts, hiding assets, etc. and providing convenient conditions for the implementation of the aforementioned behaviors.

You and your staff shall not seek or obtain any benefits or competitive advantages arising from personal relationships or improper behavior of TradPlus personnel or their close associates.

You and your staff shall cooperate with the investigation and interviews of TradPlus and its affiliates, and provide all relevant information and assistance (including but not limited to providing detailed relevant accounts and supporting materials), and cooperate with TradPlus in reviewing and assisting any compliance audits and investigations conducted by TradPlus.

6.Indemnification.

If any dispute arises between TradPlus and any third party or is punished by the regulatory authorities due to your violation of laws and regulations or any agreement, representation or warranty under this Policy, you shall assist TradPlus in handling and properly resolving the dispute. You shall also fully compensate TradPlus for any losses incurred thereby (including but not limited to fines paid by TradPlus, compensation paid to third parties, settlement funds, attorney fees, appraisal fees, litigation costs, travel expenses and other reasonable expenses).