Privacy Statement

Privacy Statement

This document describes how we (Gadsbee Limited, a Hong Kong company) collect, use, and treat your information that we collect while you use our services. This privacy policy relates to Publishers/Sellers on our service. We maintain a separate Privacy Statement for users who receive advertisements or visit the websites of our affiliates and partners.
    In this Privacy Statement, your information and data is collectively referred to as “user information.” And we use the term “process” to mean any operation or set of operations performed on user information, whether by automated means or otherwise, including, without limitation, handling, collecting, storing, recording, organizing, structuring, adapting, altering, retrieving, consulting, using, disclosing, disseminating (or otherwise making available), combining erasing, or destroying.

What User Information Do We Collect?
    While you are using our services, we may collect general data about you, including, without limitation, your last IP address used to log in, cookie information that we may have previously given to you, and information about your usage of our services (e.g., time and date). We may also use your IP address to determine your general geographic location and store that information.
    We will also collect any other information and data that you willingly provide to us when contacting us in any form of communication for any reason. This includes all contact information for you and/or your company, including name, address, telephone number, contact name, email address, banking information, and any other information provided as part of signing up for our service.
    User information may be collected directly from you or through one of our affiliates that use our services for their own products or services which you use directly.
    We use cookies to determine whether a user is a first-time user or whether they are a returning user. The cookie contains a unique identifier with the date that the cookie was created. Cookies are also used to distinguish you from other users of our services and provide contractual obligations at a higher level of quality, resulting in smoother operation and an improved experience. We recommend that you also review our Cookie Policy for more information about cookies and their use on our website.

Why Do We Collect User Information and How Do We Use It?
We collect user information for a wide range of reasons, including, without limitation, as follows:

To provide you the services available on and through our services, including the purchasing of traffic from you and payments to you for traffic that we purchase.
To collect information about the quality of traffic on our services for analysis, internal business, and security purposes.
To check for and protect against fraud, bots, or any other type of inorganic traffic for the benefit of users, affiliates, advertisers, and other parties.
To comply with legal obligations to which we may be subject (e.g., court orders, subpoenas, warrants, etc.).
For our legitimate interests or those of third parties in compliance with applicable law. A legitimate interest includes, without limitation, when we have a business or commercial reason to use your information. Examples of such purposes include, but are not limited to: (i) initiating legal claims and preparing for litigation and other dispute resolution proceedings and procedures, (ii) measures to manage business and for further developing products and services, (iii) to promote safety, security, and operation of our services, including by investigating suspicious or fraudulent activities or violations of rules, laws, or procedures, and (iv) providing you the services available on and through our services.
Other compatible purposes for which the user information was collected.

    Please note that certain user information may be used for multiple purposes and more than one reason for processing personal data may apply in each situation.
    You are not subject to decisions based solely on automated processing, including profiling, that produces legal effects concerning you. However, automated processes are used to review traffic through our system to detect and block spam, fraud, and other unlawful or undesirable activities.

Where Is User Information Stored and Who Receives It?
    User information is stored on servers managed and operated by us, but which may be owned by third parties (e.g., Amazon Web Services). We use a variety of security technologies and procedures to protect user information from unauthorized access, use, or disclosure. For instance, we store user information on servers with limited access that are located in controlled facilities.
    We do not sell user information. However, we may change this policy from time to time at our sole discretion subject to applicable law.
    We may also disclose your user information to the third parties listed below. When we do so, we require those third parties to have appropriate technical and organizational measures in place to protect user data. We will not share any user data for any purpose other than the purposes described in this policy. Third parties that may receive your information: (a) Any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) to the extent reasonably necessary for the purposes, and on the legal bases, set forth herein; (b) To our insurer and/or professional advisors to the extent reasonably necessary for the purposes of managing risks, obtaining professional advice, or in connection with legal claims, whether in court proceedings or in an administrative or out-of-court procedure; (c) Payment services providers and banking institutions that we have selected in connection with financial transactions relating to our services, with whom we share transaction data to the extent reasonably necessary for the purposes of processing payments or refunds and dealing with complaints and investigations in connection with the same; (d) Government and regulatory bodies, including law enforcement authorities, in connection with investigations, proceedings, or other actions by such parties in order for us to comply with our legal and regulatory obligations; and (e) Out partners, contractors and vendors in order to perform the contract(s) that we have with you.
    We may disclose user information to third parties when required to do so by law or in the event that we must initiate or otherwise engage in litigation or other dispute resolution proceedings and procedures.

How Long Do We Keep User Information?
    Given the contractual obligations and legal obligations, we keep user information indefinitely.

What Are Your Rights?
    Depending on your jurisdiction, you may have the following rights in connection with your user information that can be used to personally identify you:

The right to access. You may have the right to receive a copy of your personal data.
The right to rectification. You may have the right to rectify any inaccurate personal data and to have any incomplete personal data about you completed.
The right to erasure. In some circumstances, you may have the right to the erasure of your personal data without undue delay.
The right to object to or restrict processing. Under some circumstances, you may have the right to object to the processing of your personal data or request restricting the processing of your personal data.
The right to data portability. You may have the request to receive a copy of your personal data in a format that can be transmitted to other organizations.
The right to complain to a supervisory authority. You may have the right to complain to your relevant supervisory authority.
The right to withdraw consent. You may have the right to withdraw consents that you have given to us regarding the processing of your personal data.