Privacy Policy
Updated date: June 15, 2023
Effective date: June 15, 2023
Introduction
This Privacy Policy (“Policy”) is issued by Shanghai Shiquan Network Technology Co., Ltd. (“We” 、“Us” or “TradPlus”) and applies to: (i) the websites owned and operated by TradPlus (https://www.tradplusad.com/、https://www.tradplus.com/ and their subdomains); (ii) TradPlus Platform; (iii) any other products and services linked or referred to this Policy, including but not limited to API codes, Tools, Documentation, etc. We respect your privacy rights and value your trust. This policy describes how we collect, use, store, share, transmit and process your personal information and your right to decide what we do with the information we collect or hold about you.
In order to make it easier for you to read and understand, we try our best to use simple and easy-to-understand sentences and define key terms. Please refer to the “Appendix: Keyword Definitions” of this policy. This policy does not apply to the products/services provided by third parties through the TradPlus Platform, or to the products/services linked to by the TradPlus Platform. In this case, it is recommended that you carefully read and understand the privacy policies of the third party.
Please read this policy carefully, and when using the TradPlus products or services, you confirm that you have read, understood and agreed to this policy.
Information We Collect
(1)Information collected through TradPlus Website (“Website Information”)
When you browse and use our website, we collect the following information:
a.Registration Information: When you register for our website, we will collect your company name, email address, WeChat ID, mobile phone number, product type and product links.
b.Technical Information: When you visit our website, technical information about your browser will be automatically collected, including browser type; domain name, IP address; browsing information (pages visited and duration), Cookies, and Internet tags.
(2)Information collected through TradPlus Platform (“Platform Information”)
When you use the services of the TradPlus Platform, we or our business partners may need to collect the following information:
- a.Identifier: advertising ID, IP address.
- b.Device Information: memory size, CPU model, OS type, system version, system kernel version, device type, device manufacturer, device model, network connection type, IDFA, IDFV, GAID, OAID, ISO (area code), device screen size, device screen direction, operator information, time zone, language, ATT status, User Agent.
- c.Application Information: application version, application package name, application installation time, application installation channel and sub-channel, user ID, age, gender, in-app payment amount、currency and times, crash data.
- In addition to the above information, when you use the business functions of the TradPlus Platform, we may need to apply to you for the corresponding system permission:（i）Android: network permissions (android.permission.INTERNET), WIFI status permissions (android.permission.ACCESS_NETWORK_STATE), network status permission;（ii）iOS: network permission.
(3)You understand that the TradPlus Platform is only an advertising mediation platform, before sharing end user information to us to achieve business functions or fulfill the contract, you shall confirm and guarantee that:（i）you have notified end users and obtained their consent to allow us to collect and use their information in accordance with this policy;（ii）you have complied with and will continue to comply with any applicable laws, regulations and policies;（iii）you have disclosed your privacy policy and this policy to end users, and provided an easy-to-operate user rights implementation mechanism, and explained to users how to exercise their information rights and specific operations;（iv）If the data processing of end users in Europe is involved, you must correctly integrate the TradPlus SDK, and you shall provide end users with a clear notice and obtain all necessary consents to allow TradPlus to collect, use, share, and other data processing for advertising purposes, and you are fully responsible for the correct delivery to TradPlus of the end user's consent flag values;（v）if you are a child-directed application, you shall abide by the rules of COPPA, and obtain the explicit consent of their parents or guardians through verifiable means before collecting or using children's personal information.
How We Use the Information
We will comply with any applicable laws and regulations, including but not limited to, the Personal Information Protection Law of the People's Republic of China (“PIPL”), the EU General Data Protection Regulation (“GDPR”), the Children's Online Privacy Protection Act of Children (“COPPA”) and the California Consumer Privacy Act (“CCPA”), and only use user information and/or end user information for the purposes described in this policy, as follows:
(1)The website information we collect is used to: operate our website; help you complete registration and manage accounts; understand your business and product types and customer service needs, and respond in a timely manner; show you and recommend products and services that meet your needs; conduct research and analysis to provide you with better service quality.
(2)The platform information we collect is used to: (i) realize the basic functions of our advertising mediation platform and provide aggregation support for your advertising monetization; (ii) statistical analysis and detection reports: generate reports for application developers using our advertising mediation platform, traffic statistics, monitor and prevent fraud, and ensure the correct and safe operation of systems and processes; (iii) internal operations, debugging, support, security and improvement of our services; (iv) understand and analyze your usage trends and hobbies, improve service quality, and develop new products.
How We Store the Information
(1)Storage location
We comply with any applicable laws and regulations on the storage of personal information, including but not limited to any local laws and regulations, for example, the personal information we collect and generate 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 purpose described in this policy and for the shortest period stipulated by laws and regulations. When the storage period expires, we will delete or anonymize your personal information. But for the purpose of litigation defense, safeguarding public interest, protecting personal property safety or legal rights, we may extend the storage period of your and/or your end users' personal information.
How We Share the Information
(1)On the premise of complying with applicable laws and regulations, we will share or disclose your personal information to third parties of advertising partners other than affiliates and internal employees for the purpose of realizing the product functions of TradPlus Platform and/or fulfilling contract:
Third-party advertising platform/ DSP (demand-side platform)
a.The Shared Information Name：
Device identifiers: GAID, OAID, IDFA, IDFV, etc.;
Device information: OS type and version, device type/brand/model, network status, screen orientation/width/height, etc.
b.Use Purpose：programmatic advertising
c.Use Scene：Advertising request
d.Sharing Way：Background interface transmission
e.Third Party Rules：If you want to know the link to a specific third-party data rule (such as privacy policy), you can get it by sending an email to privacy@tradplus.com.
App developer/Third party attribution platform
a.The Shared Information Name：
Device identifiers: GAID, OAID, IDFA, IDFV, etc.;
Device information: ATT status;
Advertising data: display, click and other data.
b.Use Purpose：Advertising attribution
c.Use Scene：Connect traffic purchase and monetization data
d.Sharing Way：Background interface transmission
e.Third Party Rules：If you want to know the link to a specific third-party data rule (such as privacy policy), you can get it by sending an email to privacy@tradplus.com.
Advertising monitoring service provider
a.the Shared Information Name：
Device identifier: GAID, OAID, IDFA, IDFV, etc.
b.Use Purpose：Advertising monitoring
c.Use Scene：Advertising request
d.Sharing Way：Terminal initiates transmission
e.Third Party Rules：If you want to know the link to a specific third-party data rule (such as privacy policy), you can get it by sending an email to privacy@tradplus.com .
(2) We will also share or disclose your personal information for the following legal reasons:
a. Comply with any applicable law, regulation, legal process or governmental requests;
b. Enforce our agreements and policies, including investigating possible violations;
c. Investigate, detect, prevent, or take action against illegal activity or other misconduct, suspected fraud, or security concerns;
d. Establish or exercise our rights to defend against legal claims;
e. Prevent damage to the rights, property or safety of us, our users, yourself or any third parties;
f. For the purpose of cooperating with law enforcement agencies, or where we believe it is necessary to enforce intellectual property or other legal rights.
About Cookie
When you visit or use the Site, we may use industry-wide technologies such as "cookies" (or similar technologies), which store certain information on your computer or mobile device, which will enable us to automatically activate certain features and to make your experience with the Services more convenient and easy.
You can manage or delete cookies according to your preferences: (i) edit your preferences through the cookie setting link of the website; (ii) clear all saved cookies through the computer or mobile device settings; (iii) block cookies through the web browser settings. However, your online experience may be limited, if you block or delete cookies.
How to Control Information
New versions of iOS and Android enable you to control how the application collects advertising IDs. Follow the following instructions:
(1)iOS devices (iOS 14+): Go to Settings `>` Privacy `>` Tracking `>` Allow apps to request tracking. Please note that if you use more than one device, you will need to opt out on each device individually.
(2)Android devices: Please follow the instructions at: https://support.google.com/ads/answer/1660762 (under Mobile Controls). Please note that you will need to opt out on each device individually, if you use more than one device.
Information Protection Measures
(1)Data confidential measures we take
We will use industry prevailing and reasonable standards to provide security for your information and/or your end users to prevent unauthorized access, disclosure, abuse, tampering, damage, or loss of data. We will also take reasonable steps to protect your and/or your end-user data. For example, we use encryption technology (TLS, SSL) and anonymization processing to protect the personal information of you and/or your end users.
You understand that there is no transmission method on the Internet, or the electronic storage method is 100 percent secure, and despite our reasonable efforts, there is a risk of theft, property, or reputation, or abuse to you and/or your end users. You are fully aware of the above risks and voluntarily undertake them.
(2) Emergency response and early warning
After the unfortunate occurrence of a personal information security incident, we will promptly notify you by one or more methods such as email, letter, phone call, push notification, in-site message, and contact information reserved by the customer in accordance with the requirements of laws and regulations: the basic situation of security events and possible impact, the disposal measures we have taken or will take, suggestions for you to prevent and reduce risks independently, remedial measures for you, etc. If it is difficult to notify the personal information subject one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also actively report the handling of personal information security incident in accordance with the requirements of the regulatory authorities.
Your Information Rights
In accordance with applicable laws and regulations, and common practices in other countries and regions, we guarantee that you and/or your end users exercise the following rights to their personal information:
(1)Access to your personal information
You have the right to access your personal information, except for exceptions prescribed by laws and regulations. If you would like to exercise such right, you may email to privacy@tradplus.com.
- (2)Correct your personal information
When you find any error in the personal information we process about you, you have the right to ask us to make corrections. You can email it to privacy@tradplus.com filed a request for correction.
- (3)Delete your personal information
In the following situations, you can email to privacy@tradplus.com requests us to delete our personal information:
a.If our processing of personal information violates laws and regulations;
b.If we collect and use your personal information without obtaining your consent;
c.If we violate our agreement by processing personal information;
d.If you no longer use our products or services, or you cancel your account;
e.If we no longer offer you 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)Withdraw your consent
Every business function requires some basic personal information to be completed. For the collection and use of your personal information, you can give or withdraw your consent at any time by changing the corresponding authorization settings or sending an email directly to privacy@tradplus.com. When you withdraw your consent, we will no longer process the corresponding personal information. However your decision of withdrawing your consent, which will not affect the previous processing of personal information based on your authorization.
- (5)Cancel your account
You may cancel your previously registered account at any time by sending an email to privacy@tradplus.com. After canceling the account, we will stop providing you with products or services, and delete your personal information according to your request, unless otherwise stipulated by laws and regulations.
- (6)Copy your personal information
- You have the right to obtain a copy of your personal information by emailing privacy@tradplus.com. Under the premise of technical feasibility, such as data interface matching, we can also directly transmit a copy of your personal information to the third party that you designate according to your request.
- (7)Response to your above request
To ensure safe, you may need 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 within 15 days to all requests you make under this section. If you are not satisfied with our reply, you may file a complaint by email, please send an email to privacy@tradplus.com. Especially if you think that our processing behavior has damaged your legal rights, you may also send an email to the corresponding regulatory authorities such as department of network Information, telecommunications, public security or industrial commercial to file complaints or reports.
For your reasonable request, we do not charge fees in principle, but for those that are repeated or exceed reasonable limits, we will charge a certain cost depending on the circumstances. These unnecessarily repetitive requests, which may require excessive technical means (for example, requiring the development of new systems or fundamental changes in existing practices), pose a risk to the legal rights of others, or are very impractical (for example, involving information stored on backup tapes) , we may refuse.
We will not be able to respond to your request in the following circumstances:
a.Related to our performance of the obligations prescribed by laws and regulations;
b.Directly related to public safety, public health and major public interests;
c.We have sufficient evidences that you have subjective malice or abuse of rights;
d.It is difficult to obtain the consent of the person for the purpose of safeguarding your or other personal life, property and other major legal rights and interests;
e.Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations;
f.Involving trade secrets.
(8)If you are an end user of integrated TradPlus SDK applications, rather than our direct customer, we recommend that:
Please send the request related to your personal information directly to the relevant application software developers for processing and seeking help according to the privacy policy of them. After receiving the relevant request from your application software developer and validating the authenticity, we will actively cooperate and respond to the requests.
Promotional Marketing
If you are our business partner, we may regularly provide you with information about our products and services and content that you may be interested in by email. If relevant laws require us to obtain your consent before sending you marketing information, we will only send you relevant marketing information after obtaining your consent.
If you do not wish to receive such marketing information, you may unsubscribe at any time through the guidelines provided in the marketing information or request not to receive such information by sending an email to privacy@tradplus.com.
Sensitive User Data
Sensitive user data includes, but isn't limited to, personally identifiable information, financial and payment information, authentication information, phonebook, contacts, device location, SMS and call related data, health data, Health Connect data, inventory of other apps on the device, microphone, camera, and other sensitive device or usage data. If your app handles personal and sensitive user data, then you must.
We will not collect Sensitive User Data from you and/or your end users without your express consent. We may collect sensitive user data only if all of the following conditions are met at the same time:（i）Obtain the corresponding explicit consent;（ii）It is necessary to provide services or perform contracts;（iii）Comply with applicable laws and regulations, this policy and all requirements of other relevant policies.
If we collect sensitive user data under the requirements of the preceding paragraph, we will take corresponding security measures to protect such data, such as using new encryption technologies (like HTTPS) to transmit data. At the same time, we will not sell sensitive user data.
Children's Privacy
Although different laws and customs define a child differently, we consider anyone under the age of 16 to be a child. We will not actively or intentionally collect personal information from children. You must be at least 16 years old to create a TradPlus account or use TradPlus services. If you are a parent or legal guardian and believe that your child under the age of 16 has not obtained your consent, consent or authorization to submit his or her personal data or other data——Please notify us immediately and we will take immediate action to delete your child's data from our databases and cease use of such data.
If you are child-directed application or online service and will collect or may collect any personal information about children, please comply with any applicable laws and regulations including but not limit COPPA, CCPA, GDPR, PIPL and Google Play Families Policies, and ensure that the registration and use of your application is conducted with the consent or permission of the child's parents or legal guardian by taking the necessary technical means. At the same time, you have established sufficient and compliant user terms and privacy policies and obtained all necessary authorization consent. In addition, you shall also guarantee that you have to immediately inform TradPlus in writing of the purpose and specific type of processing of the children's information and the corresponding proof of compliance, if you share the necessary personal child information with TradPlus in accordance with the policy or the performance of the contract. For the collection of children's personal information with parental consent, we will only use or publicly disclose this information when permitted by law, with the explicit consent of parents or guardians, or when it is necessary to protect children.
If we become aware that a child's personal information has been collected without prior verifiable parental consent, we will endeavor to delete the relevant data as soon as possible.
Cross-border Transmission
We may transmit the information internationally between different countries/regions. Using our platform products and services means that you agree to any such transmission. We comply with the applicable laws and regulations governing the transmission of personal information between countries/regions to ensure that the personal information of you and/ or your end users is protected anywhere.
(1)If you and/or your end user are located within the People's Republic of China, personal information about you or your end users collected in accordance with this Policy will be stored within the People's Republic of China. If the information is necessary to transfer cross-border for carring out business,etc., we will strictly abide by PIPL and other relevant laws/regulations for the transmission.
(2)If it is necessary to transmit you and/or your personal information/data cross-border to provide you with the required services or products when you and/or your end users are located in the European Economic Area, we will strictly abide by the policy and the EU GDPR rules, such as the EU Standard Contractual Clauses (“SCC”).
COPPA
In this section, we explain how we work with mobile apps that indicate to us that they are child-directed apps subject to the US Children’s Online Privacy Protection Act (“COPPA”), and/or to Google Play’s “Designed For Families” program, that restrict processing of information collected from children.
When a developer adds a new app to the TradPlus Platform, or at any time while using the TradPlus Platform, the developer must inform TradPlus if the app is directed to children, as required by applicable law, as explained in this section.
(1)As a developer, you are responsible for:
a.Evaluating your apps, and determining if your apps are child-directed.
b.TradPlus SDK offers a client-side API that allows developers to "tag" specific end users as children, properly tagging your device according to the following:
(i) That is not directed to children
(ii) That is directed to children
c.Ensuring that your apps comply with applicable laws.
To further understand your obligations under the COPPA, we recommend that you read the materials: https://www.ftc.gov/tips-advice/business-center/privacy-and-security/children%27s-privacy
(2)TradPlus Platform and child-directed apps
TradPlus SDK offers a client-side API to allow developers to “flag” specific end-users as children (as described above).
Please note that mediated apps that are “Directed to Children” must use the API if they would like to communicate to supported networks the status of the end-user. Such apps should use the API to flag all end users as children under 16.
Below is a list of SDK networks which currently support the API. For SDK networks that are not listed in the below table, you should contact them directly for information on how to properly flag end-users as children.
(3)App developers under the age of 16
TradPlus prohibit app developers who are under age 16 from using our services as our customers.
CCPA
We may collect personal information about California residents, and these residents have additional rights under CCPA, such as you can exercise the right to request to know, disclose, obtain and delete the collected data; request to prohibit the sale of your data; opt out, etc.
We will not “sell” (as defined in CCPA) we have collected or may collect your personal information, if we sell your personal information, we will update this Policy according to Article 17 (Modification of This Policy) to inform you, and we will also provide you with the option of opting out of such “sales”.
Under the CCPA, as a California resident, you have certain rights with respect to your personal data, including the right to access, delete, and opt-out of the “sale” of your personal data. You may contact us by emailing privacy@tradplus.com. Upon your request, we will verify that you are the person making the request and, for this purpose, we may ask you to provide identification documents.
GDPR
We may collect personal data about the European Economic Area(“EEA”), and if you are located in the European Union, you have the following rights under the GDPR: (i) request access to, amend or delete your personal data; (ii) restrict or object to the processing of your personal data; and (iii) request that an electronic copy of the personal data be provided to another person or third party. At the same time, you have the right to file a complaint with the local data protection authority in EEA regarding the processing of your personal data.
We will process your personal data under the GDPR regulations and provide services to you based on our legitimate benefits. If we process your personal data for such benefits, for example for security and product improvement, that are generally intended to provide an effective, secure, and dynamic platform.
We value your privacy and rights as a data subject. As far as GDPR is concerned, our Data Protection Officer (DPO) is Anthony (for contact information, see Article 18 “Contact Us” of this policy), he will provide you with an easy way to exercise your privacy-related rights (such as requesting access to or deleting of personal data).
Modification of This Policy
In order to provide you with better services, we may revise the content of this policy in due course, and these revisions constitute a part of this policy and have the same effect as this policy.
We will not reduce your rights under this policy without your express consent. After the update of this policy, we will issue the updated version on the official website and remind you of the updated content before the change takes effect, so that you can keep abreast of the latest version of this policy.
For major changes, we will also provide more prominent notices (notifications sent by one or more methods such as website letters, emails, announcements, etc.). Therefore, you shall please check and understand the update of this policy in time, if you do not agree to accept this policy and its latest version, please stop accessing and using our services.
Major changes referred to in this policy include but are not limited to:
(1)Significant changes have taken place 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 undergone significant changes in ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers, etc.;
(3)Changes in the main objects of personal information sharing, transfer or public disclosure;
(4)There are major changes in your rights to participate in the processing of personal information and how to exercise them;
(5)When our responsible departments, contact methods and complaint channels for handling personal information security change;
(6) When the personal information security impact assessment report indicates that there is a high risk.
We will also archive previous versions of this Policy for your review.
Contact Us
We have set up a special data and privacy protection center. If you have any questions about this policy or personal information related matters, you can send an email to privacy@tradplus.com or send a letter (Attn: Ministry of Data and Privacy Protection Center Shanghai Shiquan Network Technology Co., Ltd. ; Address: Room 1512-1514, Upper West Shanghai T3, No. 69, Lishang Road, Shanghai, China.) or contact us through our Data Protection Officer Anthony (TEL: 021 6222 9589). We will promptly verify the identity of the requester and review the issues involved as soon as possible, and reply within 15 working days.
Appendix: Key word definition
Specific words used in this policy have the following meanings:
We or US or TradPlus: means Shanghai Shiquan Network Technology Co., Ltd. and its affiliates.
TradPlus SDK: means the SDK developed by us for advertising purposes.
TradPlus Platform: means an advertising mediation platform owned and operated by us with traffic access and code bit management functions.
You: means the registered user who uses our products and/or services and the buyer of paid services.
End User: means the individual users who are targeted by the application software or other product services that you own or operate, integrated into the TradPlus SDK.
Personal Information or Personal Data: means various information recorded electronically or in other ways that can identify a specific natural person or reflect the activities of a specific natural person either alone or in combination with other information.
User Information: means the personal information owned by you as our business partner and entity registered to use the TradPlus Platform.
End User Information: means the personal information of your end users.
De-identification: means the process of technically processing personal information to make it impossible to identify the subject of personal information without additional information.
Anonymization: means the process of technically processing personal information so that the subject of personal information cannot be identified, and the processed information cannot be restored.
China or within China: means the mainland of the People's Republic of China, for the purpose of this policy only, excluding Hong Kong Special Administrative Region, Macao Special Administrative Region and Taiwan.
Laws and Regulations: means locally applicable laws and regulations on information protection. for example, in China, refers to the “Network Security Law of the People's Republic of China”, “Data Security Law of the People's Republic of China”, “Personal Information Protection Law of the People's Republic of China” (“ PIPL”); in the European Union, refers to the General Data Protection Regulation (“GDPR”); in the United States, refers to the Children’s Online Privacy Protection Act (“COPPA”) and the California Consumer Privacy Act (“CCPA”).