Privacy Statement

Release (update) date: November 3th, 2022

Effective date: November 3th, 2022

Introduction

TradPlus SDK is an advertising SDK developed by Shanghai Shiquan Network Technology Co., Ltd. (hereinafter referred to as "we" or " Shiquan Network"), which is integrated into the application software alone or included in a third-party SDK to provide advertising services for developers and their users. We attach great importance to the privacy and personal information security of developer users (hereinafter referred to as "you") and/or your end users, and strictly abide by laws and regulations, and abide by the following principles: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choice and consent, The principle of least sufficiency, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. We promise that we will take strict security measures to protect your and/or your end users' personal information in accordance with industry-proven security and privacy standards.

The "Privacy Protection Statement" (hereinafter referred to as "this Statement") describes the purpose, method, and purpose of collecting, using, saving, sharing, and transferring your and/or your end users' personal information in the products and/or services we provide to you. Scope and information protection security measures, and we provide you with the rights and methods to control personal information such as access, correction, deletion, etc. In order to facilitate your reading and understanding, we try to express in simple and easy-to-understand sentences, and define key terms, please refer to the " Appendix: Definition of Keywords " of this statement.

This statement only applies to the products and/or services we provide you, including but not limited to: the website, SDK, API, code, tools, product documentation, etc. we provide, and does not apply to products and services provided by third parties through the TradPlus platform , or the products and services to which the TradPlus platform link points. In this case, it is recommended that you carefully read and understand the privacy policy of the third party.

You know and confirm that you have read and fully understood all the contents of this statement at the time of registration . We will collect and use the personal information of you and/or your end users after obtaining your consent to realize the relevant functions of the relevant products and/or services we provide you. We allow you to choose not to consent to the collection and use of your and/or your end users personal information, but refusing to provide such information will affect our ability to provide you with relevant services.

It should be noted that when you use TradPlus platform products or services, we will process two categories of personal information:

• 1. Your personal information as a developer user (or potential developer user) of the Shanghai Shiquan Network Technology Co., Ltd.;
• 2. The personal information of your end users, please refer to " Personal Information of Your End Users " for details.

The way we process the above personal information will vary. Because we have a direct contractual relationship with you, which is different from our indirect relationship with your end users. As our customer, if you use our products or services to re-provide services for your end users, you should agree on a separate privacy policy with your end users in accordance with applicable laws and regulations,and disclose this statement and the processing of the data in a timely manner, for which we are not responsible.

This statement will help you understand the following:

• 1、How we collect and use your/or your end users' personal information
• 2、How we use cookies and other similar technologies
• 3、End User Authorization and Consent
• 4、How we share, transfer, and publicly disclose your and/or your end users' personal information
• 5、How we store your and/or your end user's personal information
• 6、How we protect your and/or your end users' personal information
• 7、Your rights
• 8、How we handle children's personal information
• 9、How your and/or your end user's personal information is transferred around the world
• 10、How we update and modify this statement
• 11、Contact us

A、How we collect and use your/or your end users' personal information

We will collect and use your and/or your end-user's personal information in the course of using the TradPlus Platform products and related services in accordance with applicable laws and regulations and the principles of legality, legitimacy and necessity for the purposes set out below in this statement.

Regardless of the following scenarios for collecting and using your and/or your end users' personal information, we will generally only do so with your consent, except in certain circumstances, based on legal obligations or may require protection Important interests of you or others collect personal information from you and/or your end users.

Please understand that in order to better provide you and/or your end users with technologies and services, or due to changes in business strategies, the functions of our products and/or services may also be changed and developed. If we want to use your and/or your end users' personal information for other purposes not stated in this statement, or if the personal information collected for a specific purpose will be used for other purposes, or if our processing methods change, we will inform you in a reasonable manner through the website, and ask for your consent again before using it, please notify your users and obtain their authorization and consent.

(1) Your personal information as a developer user (or potential developer user) of the TradPlus platform

When you are registering/logging in your TradPlus account, you may need to provide us with your company name, email address, WeChat ID , mobile phone number, product link and product type to create an account.

We use this information primarily for:

• 1. Send you confirmation of your registration;
• 2. Understand and manage accounts;
• 3. Respond to your customer service needs;
• 4. Understand your business and product needs to determine applicable products and services;
• 5. To show you and recommend products and services that are better suited to your needs;
• 6. Conduct research and analysis to improve the TradPlus platform and services.

(2) Personal information of your end users

In order to realize the basic business functions of the TradPlus platform, we may need to collect and use the relevant personal information of your end users. The types and purposes of information collected and used will be listed in detail below. The collection and use of such personal information will only be carried out on the premise that you have confirmed that you have obtained the consent of the end user:

1. In order to achieve specific advertising service functions and ensure the accuracy of advertising delivery, we need to collect the following personal information from the application integrated with the TradPlus SDK:

2. In order to provide you with better service, we may also collect the following personal information:

This information is not necessary for the operation of the business function, but it is of great significance to improve service quality, develop new products or services, etc. We will not force you to provide this information. If you refuse to provide the above information, you will not be able to use some business functions of the TradPlus platform .

3. Depending on the type of your mobile application and your requirements for statistical analysis options, we may also collect personal information: user ID, application installation channel, application installation sub-channel, age, gender, in-app payment amount, in-app payment currency species, and the number of in-app payments. If you use our products or services to collect more personal information from your end users, you should disclose this in your privacy policy in accordance with applicable laws and regulations and obtain authorization from end users.

4. When you use this business function, we may apply to you for the following system permissions related to personal information:

You understand and acknowledge that we will collect data only after you apply for permission through the application software function page that integrates TradPlus SDK and obtain the authorization and consent of the end user. You should also inform your end users that if your end users do not wish to grant the above permissions, they can refuse or withdraw their consent by disabling the corresponding permissions.

(3) Exceptions to authorization and consent

Please understand that in the following circumstances, according to applicable laws and regulations, the collection and use of your and/or your end user's personal information does not require your and/or your end user's authorised consent:

• 1. It is necessary to perform legal duties or legal obligations;
• 2. In response to public health emergencies, or in order to protect your and/or your end users or other individual's vital legal rights to life, property, etc., but it is difficult to obtain your consent;
• 3. The handling of personal information within a reasonable range for the purpose of carrying out acts of journalism, opinion monitoring, etc. in the public interest;
• 4. The collected personal information of you and/or your end users is disclosed to the public by you;
• 5. Personal information about you and/or your end users collected from information that is lawfully and publicly disclosed;
• 6. Necessary for the conclusion or performance of the contract at your request;
• 7. Other circumstances as provided for by law and regulations.

In particular, you are reminded that, by law, if the information cannot be individually or in combination with other information to identify you and/or your end-user personally, it is not your and/or your end-user's personal information within the meaning of the law, and that the sharing, transfer, public disclosure of such processed data does not require separate notification and consent from you and/or your end-user. Where information relating to you and/or your end-user can be personally identified to you and/or your end-user, either alone or in combination with other information, or where we use data that cannot be linked to any particular individual in combination with other personal information about you and/or your end-user, such information will be treated and protected as personal information of you and/or your end users in accordance with this statement during the combined use.

B、How we use similar technologies such as cookies

Similar technologies such as cookies and device information are commonly used technologies on the Internet. When you use the TradPlus platform and related services, we may use related technologies to send one or more cookies or anonymous identifiers to your device to collect and identify information when you visit and use this product. We undertake not to use cookies for any purpose other than those described in this Privacy Statement. We use cookies and similar technologies mainly to achieve the following functions or services:

To ensure the safe and efficient operation of our products and services: We may store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. The main function of cookies is to facilitate your use of TradPlus platform products and/or services, and to help count the number of unique visitors to the website. Using cookie technology, we can provide you with more thoughtful personalized services and allow you to set your specific service options. Cookies are sent to your device when you use TradPlus platform products and/or services.

You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer or mobile device , and most web browsers have a cookie-blocking feature. However, if you do this, you will need to personally change your user settings each time you visit our website. However, please note that some features of the TradPlus platform may not be available after disabling cookies.

C、End User Authorization and Consent

In order to provide you and/or your end users with TradPlus platform services, we will use de-identification or anonymization to collect, store and process personal information from end users of your application software. Therefore, by accepting this statement and applying the TradPlus SDK to your product, you confirm and warrant that:

1. You have informed the end user and obtained the full, necessary and explicit authorization, consent and permission of the end user to allow us to collect and use their information for the purpose of providing services;

2. Unless otherwise provided by applicable laws, you have informed the end user and obtained sufficient and necessary authorization, consent and permission from the end user, allowing us to de-identify the collected personal information, allowing us to comply with relevant laws and regulations. Use the collected and processed information for the purposes listed in Article 1 of this Statement;

3. You have complied with and will continue to comply with applicable laws, regulations and regulatory requirements, including but not limited to the development and publication of relevant policies relating to the protection of personal information and the protection of privacy.;

4. You have provided end users with easy-to-use mechanisms for realising their rights, explaining how and when users can exercise the right of choice, how to access, correct their personal information, exercise the right to delete, and change the scope of their authorization and consent.

D、How we share, transfer, and publicly disclose your and/or your end users' personal information

(1) Sharing

Except as described in this statement, information about you and/or your end users will not be shared with third parties in an identifiable form. Except in the following cases:

1. Sharing with express consent: We will share your and/or your end user's personal information with other parties after obtaining your and/or your end user's express consent;

2. We may share your and/or your end users' personal information externally in accordance with laws and regulations, or the mandatory requirements of government authorities;

3. Sharing with our affiliates: Information about you and/or your end users may be shared with our affiliates, and we will only share necessary information and for the purposes stated in this statement. If the affiliated company wants to change the purpose of processing personal information, it will seek the authorization and consent of you and/or your end user again.

4. Sharing with external suppliers: Some specific modules or functions of our business functions are provided by external suppliers only for the purposes stated in this statement. We may share certain personal information about you and/or your end users with external suppliers to provide better customer service and user experience. We will only share personal information of you and/or your end users for legal, legitimate, necessary, specific and explicit purposes, and we will sign strict confidentiality agreements with them, requiring them to comply with our requirements, this statement and other any relevant confidentiality and security measures to handle personal information.

(2) Transfer

We will not transfer your and/or your end user's information to any company, organization or individual, except in the following cases:

• 1. obtain your and/or your end user's express prior consent or authorization;
• 2. In connection with a merger, acquisition, asset transfer or similar transaction.

If it involves the transfer of personal information, we will require new companies and organizations that hold personal information about you and/or your end users to continue to be bound by this statement. If there is any change in the collection and processing of personal information agreed in this statement, the company or organization will seek authorization and consent from you and/or your end users again.

(3) Public disclosure

We will not publicly disclose personal information about you and/or your end users, except in the following cases:

• 1. 1.obtain your and/or your end user's express prior consent or authorization;
• 2. When required by law, legal process, litigation or government authorities.

E、How we store your and/or your end user's personal information

(1) Storage location

We comply with any applicable laws and regulations regarding the storage of personal information, including but not limited to any local laws and regulations, for example, personal information we collected and generated in the mainland of the People's Republic of China will be stored in the mainland of the People's Republic of China .

(2) Storage period

We only store your and/or end users' personal information for the purposes stated in this statement and for the minimum period stipulated by laws and regulations. After the storage period is exceeded, we will delete or anonymize your personal information. However, in order to comply with corresponding laws and regulations,for the purposes of defending a lawsuit, protecting the public interest, protecting the safety of personal property or legal rights, we may extend the period of storage of your and/or your end users' personal information.

F、How we protect your and/or your end users' personal information

(1) Data confidentiality measures we take

We will use industry-wide and reasonable standards to provide appropriate security for your and/or your end user's information to prevent unauthorized access, disclosure, misuse, alteration, damage or loss. We will take reasonable and practicable steps to protect the security of your and/or your end user data. For example, we use encryption technology (TLS, SSL), anonymization and other means to protect your and/or your end users' personal information.

We will take all reasonably practicable steps to ensure that irrelevant personal information is not collected. We will only retain information about you and/or your end users for as long as is necessary to achieve the purposes described in this Statement, unless an extended retention period is required or permitted by law.

We establish special management systems, processes and organizations to ensure information security. For example, we strictly limit the scope of people who have access to information, require them to comply with confidentiality obligations, and conduct reviews.

No method of transmission over the Internet, or method of electronic storage is 100% secure, and despite our reasonable efforts, there is a risk of theft, illegal possession or misuse which could result in damage to you and/or your end-users in respect of your physical, property and reputation. You are fully aware of these risks and voluntarily assume them.

(2) Emergency response and early warning

In the event of an unfortunate personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly notify you through one or more methods such as email, letter, telephone, push notification, on-site letter, and contact information reserved by customers: security incident The basic situation and possible impact, the disposal measures we have taken or will take, the suggestions that you can prevent and reduce risks by yourself, the remedial measures for you, etc. If it is difficult to inform the personal information subjects one by one, we will take a reasonable and effective way to make announcements. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.

G、Your rights

In accordance with applicable laws and regulations, as well as common practices in other countries and regions, we guarantee that you and/or your end users exercise the following rights over their personal information:

(1) Direct users of the TradPlus platform

1. access your personal information

You have the right to access your personal information, subject to exceptions provided by laws and regulations. If you would like to exercise your data access rights, you may send an email to 。

We will provide you with other personal information generated during the use of our products or services as long as we do not need to invest too much.

2. Correct your personal information

You have the right to ask us to make corrections when you find that the personal information we process about you is inaccurate. You may request a correction by sending an email to

3. delete your personal information

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

1）If our processing of personal information violates laws and regulations;

2）If we collect and use your personal information without your consent;

3）If our processing of personal information violates our agreement with you;

4）If you no longer use our products or services, or you log out of your account;

5）If we no longer provide you with products or services.

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us and require them to delete it in a timely manner, unless otherwise required by laws and regulations, or these entities obtain your independent authorization. When you delete information from our service, we may not delete the corresponding information from the backup system immediately, but will delete the information when the backup is updated.

4. Change the scope of your authorised consent

Each business function requires some basic personal information to be completed. For the collection and use of additionally collected personal information, you may give or withdraw your consent at any time by sending an email to . When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization.

5. Personal Information Subject Cancellation of Account

You can cancel your previously registered account at any time by sending an email to . After canceling your account, we will stop providing you with products or services, and delete your personal information according to your request, unless otherwise provided by laws and regulations.

6. Get a copy of your personal information

You have the right to obtain a copy of your personal information by sending an email to . Under the premise of technical feasibility, such as data interface matching, we can also directly transmit a copy of your personal information to a third party designated by you upon your request.

7. In response to your above request

For security, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. We will respond to all requests you make under this section within 15 days. If you are not satisfied with our response, you can file a complaint by email, please send an email to , especially if you think that our personal information processing has harmed your legitimate rights and interests, you can also file a complaint with Netcom , telecommunications, public security and industry and commerce and other regulatory authorities to complain or report.

For your reasonable requests, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost as appropriate. For those that are unnecessarily repetitive, require excessive technical means (eg, need to develop new systems or fundamentally change existing practices), pose a risk to the legitimate rights and interests of others, or are highly impractical (eg, involve backing up information stored on tapes). requests, we may refuse them.

We will not be able to respond to your request in the following circumstances:

1）In connection with our performance of our obligations under laws and regulations;

2）Directly related to public safety, public health, and major public interests;

3）We have sufficient evidence to show that you have subjective malice or abuse your rights;

4）In order to protect your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain my consent;

5）Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

6）involving trade secrets.

application software integrated with TradPlus SDK , rather than our direct customer, we recommend that you:

According to the application software developer's privacy policy, please send the request related to your personal information directly to the relevant application software developer for processing and seeking help. TradPlus will verify the authenticity of the request after receiving the relevant request from your application software developer. After legality, they will actively cooperate and respond to requests.

H、How we handle children's personal information

Our products, websites and services are primarily aimed at adults. Children should not create their own personal information subject account without parental or guardian consent. Although local laws and customs define children differently, we consider anyone under the age of 14 to be a child.

If your application software is designed and developed for children, please make sure that you take necessary technical measures to ensure that the registration and use of the application software by end users are carried out by the guardian of the child. At the same time, you have formulated a sufficient user agreement and privacy policy to fulfill the obligation of notification. For the collection of children's personal information with parental consent, we will only use it when permitted by law, expressly consented by parents or guardians, or necessary to protect children. or publicly disclose this information.

If we discover that we have collected personal information from a child without first obtaining verifiable parental consent, we will try to delete the relevant data as soon as possible.

I、How your and/or your end user's personal information is transferred globally

Since we provide products or services through resources and servers located all over the world, this means that your and/or your end user's personal information may be transferred to you after obtaining your and/or your end user's authorization and consent Use, or be accessed from, jurisdictions outside the country where the product or service is located. We comply with applicable laws regarding transfers of personal information between countries to ensure that your and/or your end users' personal information is protected everywhere.

In particular, if you and/or your end users are located in the People's Republic of China, the personal information we collect about you or your end users in accordance with this Statement will be stored in the People's Republic of China. If it is necessary to carry out business, etc., and it is necessary to transmit to outside the People's Republic of China, we will strictly abide by the requirements of the "Personal Information Protection Law of the People's Republic of China" and other relevant laws and regulations for transmission.

If you and/or your end users are located in the European Economic Area, we will transfer your or your end users’ personal information outside the European Economic Area necessary to perform a contractual obligation to provide you with the services or products you have requested. Strictly abide by this statement and EU GDPR and other rules, you hereby understand and expressly agree to the transfer of your and/or your end user's personal information to recipients located outside the European Economic Area as described in this statement.

J、How we update and revise this statement

In order to provide you with better service, we may revise the contents of this statement in due course, and these revisions form part of this statement and have the same effect as this statement.

We will not reduce your rights under this Statement without your express consent. After this statement is updated, we will issue an updated version on the official website and remind you of the updated content through appropriate means before the change takes effect, so that you can keep abreast of the latest version of this statement.

For major changes, we will also provide more prominent notices (including for some services, we will send notices through one or more methods such as internal letters, emails, announcements, etc., explaining the specific changes to this statement). Therefore, please feel free to review and understand this statement to which you should abide, and if you do not agree to accept this statement, please stop accessing and using our services.

Material changes referred to in this statement include, but are not limited to:

1. There has been a major change in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;

2. We have significant changes in ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.;

3. Changes to the main objects of personal information sharing, transfer or public disclosure;

4. material changes in your rights to participate in the processing of personal information and the way they are exercised;

5. When our responsible department for handling personal information security, contact information and complaint channels change;

6. When the personal information security impact assessment report indicates that there is a high risk.

We will also archive older versions of this Statement for your review.

K、contact us

We have set up a special data and privacy protection center. If you have any questions about this statement or personal information, you can send an email to or by mail (Attn: Legal Affairs of Shanghai Shiquan Network Technology Co., Ltd. Ministry of Data and Privacy Protection Center; Address: Room C405, 4th Floor, No. 258 Yangzhai Road, Changning District, Shanghai; Zip Code: 200042 ) or through our Data Protection Officer Andy Wang (TEL: 021 6222 9589 ) . We will promptly verify the identity of the requester and review the issue as soon as possible, and respond within 15 working days.

Appendix: Keyword Definitions

Certain terms used in this statement have the following meanings:

• 1. We or Shiquan Network: refers to Shanghai Shiquan Network Technology Co., Ltd.
• 2. You : refers to registered users of our products and/or services and purchasers of paid services.
• 3. Your end user: refers to the end user who integrates the TradPlus SDK application software.
• 4. TradPlus Platform: operated by TradPlus and/or TradPlus affiliates (if the domain name is changed, the changed domain name shall prevail). The website has the functions of traffic access and code bit management.
• 5. TradPlus SDK: refers to the SDK developed by Shanghai Shiquan Network Technology Co., Ltd. for advertising purposes.
• 6. Personal information: refers to various information recorded by electronic or other means that can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or in combination with other information.
• 7. Personal information subject: refers to the natural person identified by personal information.
• 8. De-identification: refers to the process of making it impossible to identify the subject of personal information without the aid of additional information through technical processing of personal information.
• 9. Anonymization: refers to the process in which the subject of personal information cannot be identified through the technical processing of personal information, and the processed information cannot be recovered.
• 10. China or within China: refers to the mainland of the People's Republic of China, for the purpose of this statement only, excluding Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan.
• 11. Laws and Regulations: refers to locally applicable laws and regulations on information protection, for example, in China, it refers to the Cybersecurity Law of the People's Republic of China, the Data Security Law of the People's Republic of China, and the Personal Information Protection Law of the People's Republic of China; in the European Union, means the General Data Protection Regulation, or in the United States, the Children's Online Privacy Protection Act of 1998.