Privacy

This Privacy Policy is intended to explain to you how we collect, use, disclose, protect and store your personal information. Please read and understand this Privacy Policy carefully before using our APP (hereinafter referred to as "this App"). If you do not agree to any content of this Privacy Policy, you should immediately stop using this App.

1. Information Collection and Use

Personal Information Collection

When you install and use this application, we may collect your device information, including but not limited to device model, operating system version, device settings, device identification code (such as IMEI, IMSI, Android ID, OAID, GUID, hardware serial number, etc.), device MAC address, software list, unique device identifier and other information. This information is used to identify your device in order to provide you with better services, optimize product performance and ensure safe operation.

We may collect your game behavior data during the use of this application, such as game progress, game scores, in-game operation records, etc., to provide you with a personalized gaming experience, improve game functions and conduct data analysis, but this data will not directly identify your personal identity.

If you choose to use social functions (such as logging in with a social platform account, sharing game scores, etc.), we may collect your public information on the corresponding social platform, such as nicknames, avatars, etc., the specific scope depends on your authorization settings on the social platform.

Purpose of Information Use

Provide you with game services: We use the collected information to operate and maintain this application to ensure that you can play the game smoothly, including but not limited to game account management, game matching, ranking functions, etc.

Personalized services: Based on your game behavior data and preferences, we provide you with personalized game content recommendations, advertising, and personalized in-game feature settings to enhance your gaming experience.

Advertising and optimization: We have access to the TopOn SDK, through which some of your information may be collected for advertising purposes. This information helps advertisers show you advertising content that is more in line with your interests, and also helps us optimize advertising strategies to improve advertising effectiveness and revenue. However, please note that we will not provide your personally identifiable information directly to advertisers, who can only obtain anonymous or de-identified information related to advertising, such as device type, advertising identifier, etc.

Security and compliance: We use the collected information to ensure the safe operation of this application, prevent fraud, malware attacks, and other illegal activities, and comply with relevant laws, regulations, and regulatory requirements.

2. Information Sharing and Disclosure

Sharing with Third Parties

We may share some of your information with third-party service providers, including but not limited to advertising partners, data analysis companies, technical support service providers, etc. When sharing information, we will only share your information for legal, legitimate, necessary and clearly informed purposes, and only share necessary information related to the service. For example, we will share information such as device information and advertising identifiers with advertising partners so that they can show ads to you, but will not share your personally identifiable information or other sensitive information unless you explicitly agree.

Information Disclosure

When laws and regulations require us to disclose your information or when government departments or judicial organs require us to disclose your information in accordance with the law, we will disclose it in accordance with the law. For example, we may disclose your information in response to lawful investigation requests from law enforcement agencies, comply with court orders or legal procedures.

3. Changes to the Privacy Policy

We may revise this Privacy Policy based on business development, changes in laws and regulations, or other reasons. If you continue to use this application after the privacy policy changes, you agree to accept the revised privacy policy. If you do not agree to the revised privacy policy, please stop using this application. Please review this application privacy policy and TopOn official privacy policy in a timely manner to understand the latest privacy policy.

4. Contact Us

If you have any questions, comments or suggestions about this Privacy Policy, please feel free to contact us. You can contact us in the following ways:

Email: ndejoker12@gmail.com

If any dispute arises from this Privacy Policy, the two parties shall first resolve it through friendly negotiation; if the negotiation fails, either party shall have the right to file a lawsuit with the People's Court with jurisdiction.

Please read and understand this Privacy Policy carefully before using this application. We are committed to protecting your privacy and personal information. Thank you for your trust and support.

5. TopOn Privacy Policy

The following is the content of TopOn Privacy Policy.

1. Introduction

TopOn entity (for purpose of applicable data protection laws, TopOn entity providing TopOn Service which is subject to applicable disclosure requirements would be Topon Pte. Ltd., which is referred as “TopOn”, or “we”, “us”, “our”) provide this privacy policy to explain how we collect, use, and share personal data. This privacy policy (“Policy”) covers TopOn’s handling of two types of personal data:

(1) Personal data we receive when we provide our service, including (i) device personal data about end users we collect through our software development kit (“SDK”), application programming interface (“API”), our platforms, services or technologies from traffic supply partners such as mobile app developer, ad exchange platform, supply-side platform, mediation platform; (ii) personal data about end users’ interaction with ads collect through our SDK, API or other technologies, or collected and transferred to us by our Business Partners (e.g. mobile app developers, advertisers, hereinafter referred to as “Business Partners”) or any third party designated by them; (iii) device personal data generated during end users’ use of our Business Partners’ mobile apps, websites, platforms or services and personal data collected and transferred to us by our Business Partners or any third party designated by them; (iv) personal data provided by Business Partners when they use TopOn’s platforms, technologies, services. In the Privacy Policy of the TopOn Services, the end users mentioned in this section are collectively referred to as “User”, “you” or “your”; the SDK, API, any technology, platform or service provided by TopOn mentioned in this section are referred to as “TopOn Service”.

(2) Personal data we receive through the following websites from website visitors (hereinafter referred to as “Visitors”, “you” or “your”) in the Privacy Policy of TopOn Website: (i) our website at: www.toponad.com www.TopOn.net or any other website on which this Policy is posted, as well as (ii) any website we provide to Business Partners or potential clients in order to provide our services.

This Policy is subject to any service agreement between TopOn and you. By using the TopOn Service or TopOn Site, you acknowledge that you have read, understood and agreed to this Policy. Please review this Policy before using the TopOn Service or the TopOn Site.

We evaluate this Policy and procedures to implement improvements and refinements from time to time.We will review and update this Privacy Policy as necessary at least every 12 months.

Data protection and ensuring our Business Partners’ and your trust is at the core of TopOn’s business principles. Accordingly, being compliance with applicable data protection laws is our top priority and this Policy is updated to be compliance with the applicable data protection laws, including but not limited to the EU General Data Protection Regulation (“GDPR”), the Children’s Online Privacy Protection Act (“COPPA”), the California Customer Privacy Act (“CCPA”), Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act (“CPA”), the Utah Consumer Privacy Act (“UCPA”), the Connecticut Data Protection Act (“CDPA”), the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais) (“LGPD”), Virginia Consumer Data Protection Act ("VCDPA") and the any applicable data protection law.

For the purpose of this Policy, a “processor” under the GDPR, VCDPA, CPA, CDPA and UCPA, and a “service provider” under the CCPA. “Controller” means the “controller” under the GDPR, VCDPA, CPA, CDPA and UCPA, and a “business” under the CCPA.

2. How and why we collect user personal data

This Privacy Policy describes TopOn’s personal data collection and personal data use behavior in the following scenarios:

Based on the nature of the user's use of TopOn services or services provided by any of TopOn's business partners, we may directly or through our business partners (such as: mobile application developers, programmatic advertising exchanges, advertising aggregation platforms, advertising demand parties Platform, traffic provider platform) collects personal data. For example:

(1) When we provide traffic monetization services and mobile advertising aggregation tools for mobile application developers, the mobile application developers will embed our SDK in their mobile applications, and we will obtain user personal data through the SDK;

(2) When we cooperate with a programmatic advertising exchange platform or a traffic supplier platform, and the programmatic advertising exchange platform or traffic supplier platform sends advertising needs to our demand-side platform, it may share user personal data with us;

(3) Our advertisers, advertising demand-side platforms, programmatic advertising exchange platforms or the third-party attribution platforms they use will share user personal data with us;

In the process of providing TopOn services, we do not establish direct contact with users. We will obtain users’ personal data on the collection and use of personal data through TopOn’s business partners (such as mobile application developers using TopOn’s SDK, programmatic advertising exchange platforms, advertising aggregation platforms, advertising demand-side platforms, traffic supply-side platforms, etc.) Authorized consent. In our cooperation agreement with TopOn's business partners, we have required them to promise and guarantee the legality of the data sources, and they will inform users of the specific circumstances of our processing of personal data in accordance with the requirements of applicable laws, and obtain valid consent from users ( Where necessary, obtain separate consent required by applicable law) and ensure that users can revoke such consent at any time.

TopOn services may link to third-party websites, applications or other third-party content. Please note that we have no control over the processing of user personal data by third parties, and third parties may have privacy protection regulations that are different from those described in this privacy policy.

When we collect personal data such as name and email address of partners’ business representatives, our purpose is to conduct business communications with them, including necessary communications to perform the contract between us and the partner.

3. Personal information we may collect

When you browse advertisements using TopOn services or use services provided by TopOn's business partners, we and/or our business partners may collect your information. App developers may choose to share their collected personal information with us through our SDK. For more information about how app developers collect, use, and share your personal information and whether you agree to the developer's use of your relevant personal information, please check the privacy policy of the relevant app developer. Please note that we will require our partners to obtain your full consent in advance for the personal information that may be collected and shared during the service process before using our services through our cooperation agreement.

(1) When we collect information through the SDK, the types of information we collect may include:

Location Information

[Required information] IP address

[Optional information] Country, time zone and locale (country and preferred language)

Device/Advertising ID

[Required information] Android ID, OAID, IDFV, mobile advertising identifiers (such as Apple IDFA, Google Advertising ID and Amazon ID)

[Optional information] International Mobile Equipment Identity (IMEI), MAC address, International Mobile Subscriber Identity (IMSI)

Note: If you restrict your device or application from obtaining your device/advertising ID in accordance with Article 7 of this policy, we will not collect the corresponding information;

Device Information

[Required information] Device manufacturer, device model, device operating system information, device type, device screen information, device network information, hardware serial number, device sensor information, Limit Ad Tracking (LAT) status, phone boot time, phone user name summary, device storage capacity information

[Optional information]

CPU type, device battery information, device volume and font size, whether it is an emulator, system build type, system build label, system build user, radio firmware version, system boot program version number, hardware name, host address, system development code, system source control version number, device display version number, device substrate name

Application Information

[Required information] TopOn partner's application package name, application version and features, SDK version

[Optional information]

Whether it is downloaded from the app store, list of installed applications;

Special note: For download ads, we will determine whether you have installed the product promoted by the ad before displaying it. If you have installed it, we will not display the ad (we call it display filtering), and notify the server to no longer return the corresponding ad the next time your device requests an ad, thereby improving the user experience. TopOn will only report the relevant information of the "display filtered" ads in this scenario, and will not collect information about other installed apps.

Usage Data

[Required Information] When you interact with the advertisements we promote, we will collect information about your interaction with the advertisement, such as browsing or clicking on the advertisement.

Additional Information

[Optional information] Device event information (such as system crashes, system activity), timestamp, date and time you made the request, source URL, user agent.

Permission application

Special note: If you use a developer application that integrates TopOn SDK, TopOn SDK will apply for corresponding permissions through the developer application. The developer should inform you of TopOn SDK, subject name, type and purpose of processing personal information, privacy policy, etc., and obtain your consent before using TopOn SDK to carry out relevant business functions. Because different SDK versions may have certain differences in the information fields collected and whether they are optional, the specific collection situation shall be based on the SDK version connected to the developer application you actually use. Developers must ensure that users agree to the "Privacy Policy" before initializing TopOn SDK. TopOn SDK users will only collect information and apply for permissions after agreeing to the "Privacy Policy".

(4) For partners using Google Ad Manager monetization services, in order to improve our service capabilities, we will collect the advertising performance data related to your Google Ad Manager monetization through Google API Services and display it on your account page in our backend, subject to your explicit authorization. The fields and scope of the data we obtain will be subject to your authorization.

We promise that the use of Google API Services and the collection and use of the collected information will comply with the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes), including the restrictive use requirements announced by Google policies. You can learn about all data processing activities involved in our service process through this policy (https://www.toponad.com/en/privacy-policy).

(5) When we provide TopOn services to our business partners, we may collect the name, position, email address, contact address, and user name and password, and IP address of the contact person who uses TopOn services on behalf of such business partners, as well as the user name and password, and IP address used when visiting the TopOn official website.

We will cooperate with partners such as reputable programmatic advertising trading platforms, advertising demand-side platforms, and traffic supply-side platforms. After the advertising information exchange platform or the media platform receives an advertising request with your personal information, it will transmit the personal information to TopOn to build your profile, personalize your advertising experience, and then serve you advertisements on the Internet, if permitted by law.

Exemption from obtaining consent for processing personal information in accordance with the law

In accordance with the requirements of applicable laws, we have contractually agreed that our business partners (such as mobile application developers and advertisers using TopOn's SDK) will obtain the consent of users or their employees for the processing described in this Privacy Policy on our behalf. Users or their employees may withdraw their consent at any time. Please also understand that, in the following circumstances, according to laws and regulations, we do not need to obtain your authorization and consent to process your personal information:

(1) Necessary to conclude or perform a contract according to your request;

(2) Necessary to perform statutory duties or statutory obligations, such as statutory duties or statutory obligations directly related to national security, national defense security, criminal investigation, prosecution, trial and execution of judgments;

(3) Necessary to respond to public health emergencies, or to protect the life, health and property safety of natural persons in an emergency;

(4) Process personal information within a reasonable scope for news reporting, public opinion supervision and other activities for the public interest;

(5) Process personal information that you have disclosed yourself or other personal information that has been legally disclosed (such as legal news reports, government information disclosure and other channels) within a reasonable scope;

(6) Other circumstances stipulated by laws and regulations.

Special note: According to legal provisions, if information cannot be identified to a specific individual alone or in combination with other information, it does not constitute personal information. When your information can identify you alone or in combination with other information, or when we use data that is not linked to any specific individual in combination with your personal information, we will treat it as your personal information and process and protect it in accordance with this Privacy Policy.

If you are located in the European Economic Area, we will use your personal information based on the "legitimate interests" stipulated in the GDPR, if necessary. Our legitimate interests include the following: monitoring and preventing fraud, eliminating technical obstacles to system operation, and ensuring the correct and secure operation of systems and processes.

About sensitive personal information

Sensitive personal information generally refers to personal information that, once leaked or illegally used, is likely to cause infringement of a natural person's personal dignity or endanger personal or property safety. Its scope will vary according to the provisions of different applicable laws.

We will not collect your sensitive personal information without your consent. Our business partners will transfer or authorize us to process your sensitive personal information only after fully informing you of the necessity of processing sensitive personal information and the impact on personal rights and interests and obtaining your consent in accordance with the law.

4. How we use users’ personal information

We use users’ personal information as follows:

5. How we share and disclose users’ personal information

Subject to applicable laws, we may share personal information with third parties for the following purposes and scenarios:

(1) Sharing

When we purchase advertising traffic from mobile app developers to provide them with monetization services, or when we act as a programmatic advertising trading platform or traffic supplier platform, we may share users’ personal information with our business partners in order to fulfill our contractual obligations to our business partners, including reporting to them the performance and effectiveness of the ads that users interact with, including statistics on traffic quality, and for anti-fraud purposes. The personal information we share is personal information related to the performance and effectiveness of ads, such as device information, clicks, impressions, installations, or activations. These business partners may use this user’s personal information to count users’ interactions with ads/websites, evaluate the performance and effectiveness of ads that users view or interact with, identify areas of interest to users, better understand website and app traffic usage or user behavior to improve their services. Our business partners’ use of the information we disclose is subject to their privacy policies.

We may also use third-party technical service providers (such as cloud service providers) to process personal information in order to ensure the correct and appropriate operation of systems and processes and to store data.

We may also share aggregated or anonymized information with other third parties in accordance with the terms of this Privacy Policy.

In particular, if a mobile app developer only chooses to use our aggregation tool service but does not choose our programmatic advertising trading service or does not sell its in-app advertising space to us, other advertising SDKs integrated in our SDK need to obtain the consent of the mobile app developer, and the third-party advertising SDK will collect relevant information.

In particular, if a mobile app developer only chooses to use our aggregation tool service but does not choose our programmatic advertising trading service or does not sell its in-app advertising space to us, other advertising SDKs integrated in our SDK need to obtain the consent of the mobile app developer, and the third-party advertising SDK will collect relevant information. The list, name and personal information processing rules of the third-party advertising SDK are as follows:

Meta
Meta Platforms Inc. Meta Platforms Ireland Limited

The types of information we (Meta here) collect and process depend on how you use our products. For example, we collect different information about someone selling furniture on Marketplace than someone posting a Reels video on Instagram. Even if you don't have an account, we collect some information about you as long as you use our products. The information we collect includes:

Your activity and information you provide

Friends, fans, and other contacts

App, browser, and device information

Information from partners, suppliers, and other third parties

The Meta privacy policy shall prevail. https://www.facebook.com/privacy/policy 

Pangle 

Bytedance Pte. Ltd., 

The types of personal data we (we, or Pangle) process depends on the circumstances of collection and the nature of the services requested or transactions conducted for our partners.

2 We process certain information about you and your device when you interact with partner websites. This information may be automatically collected from your device using our software code (called a “software development kit” or “SDK”) or shared with us by other ad exchanges (such as Google DoubleClick). We also use cookies (text files inserted into your browser when you visit our partners’ or customers’ mobile apps and websites) and other tracking technologies available on your device.

.3 The information we process about you may include some or all of the following categories:

A. Information automatically obtained from your device

I. Identifiers: We may process device-specific identifiers such as your IP address, mobile advertising identifiers (such as the “Google Advertising ID” on Android phones or the “Advertiser ID” on iOS devices), or Pangle-specific identifiers that our SDK has assigned to your device. Mobile advertising identifiers are identifiers provided by your device’s operating system that allow companies such as Pangle to recognize your device across apps for advertising purposes. In addition to mobile advertising identifiers and other similar technologies, Pangle may also obtain your device model, operating system (such as iOS or Android), your device's language settings, general geographic area, time zone, network type (such as 5G or WiFi), your ROM version, screen resolution (to understand which ads are best suited for your device), mobile country code and mobile network code, and when your device was last updated and started.

II. Geolocation data: We may infer your approximate geographic location based on your device's IP address. With your consent or permission under applicable data protection law, we may also use your phone's GPS data to process your precise latitude and longitude.

III. Internet activity: We may process information about your use of apps and websites, including the name and version of the app or website that has integrated Pangle. We may also process information about your interaction with any ads we serve (for example, information about ads served, viewed or clicked, such as the type of ad, where and when the ad was served, whether you clicked on it and whether you visited the advertiser's website or downloaded the advertiser's app, as well as any preferences you may have expressed with respect to that ad).

b. Information from Other Sources

i. We may sometimes receive information about you from other sources. For example, we may receive information about you from third parties (such as ad exchanges that share data with us to serve ads) if the third parties are permitted by law to disclose this information to us.

ii. The information we receive from these sources may include identifiers (such as your IP address or mobile advertising identifier), information about your internet activities (such as information about your interactions with third-party websites, applications, and advertisements), and inferences about your preferences and characteristics (such as your approximate age and gender).

The Pangle Privacy Policy shall prevail https://www.pangleglobal.com/zh/privacy/enduser-en 

Admob & Ad manager

Google LLC and its affiliates

We (we, or we, here Google) collect information about the apps, browsers, and devices you use to access Google services so we can provide useful features like automatic product updates, dimming the screen when battery is low, and more.

The information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information (including carrier name and phone number), and app version number. We also collect information about how your apps, browsers, and devices interact with Google services, including IP addresses, crash reports, system activity, and the date, time, and referrer URL of the request.

We collect this information when Google services on your device communicate with our servers (for example, when you install an app from the Play Store or when a service checks for automatic updates). If you have an Android device with Google apps installed, your device periodically communicates with Google servers to provide information about your device and connection to Google services. This information includes your device type and carrier name, crash reports, apps you have installed, and other information about how you use your Android device (depending on your device settings).

The Admob privacy policy shall prevail https://policies.google.com/privacy 

Appnext
Appnext PTE. Ltd,

Device and Application Information – This category includes your device type and model, system language, device operating system (e.g., Android or iOS), SDK version, mobile operator name, mobile browser installed on your device (e.g., Chrome or Safari), application history and usage information (e.g., information about apps running and installed on your device), information about mobile app downloads and installations and any information about in-app events (e.g., in-app purchases), your device’s IP address, and identifiers assigned to your device, such as the iOS Identifier for Advertising (IDFA), Android Advertising ID, or other types of unique device identifiers (a number uniquely assigned to your device by your device manufacturer).

Advertising Information – This category includes information about online advertising and personalized content that we have served (or attempted to serve) to you. It includes the number of times an ad was served to you, the pages on which the ad appeared, whether you viewed, clicked on, or otherwise interacted with the ad, ad engagement history, and whether you visited the advertiser’s website, downloaded an app, or purchased the advertised product or service.

Location Information – Appnext collects information about your general location (e.g., city and country). For example, we may use an IP address to identify your general location. This information does not tell us the exact location of your device. This information is sent as a normal part of internet traffic. In addition, we collect implicit location information, which allows us to infer that you are interested in a place or that you may be at that place - this information does not actually tell us the precise location of your device. In addition, Appnext may collect the precise location of your device (using GPS signals, device sensors, Wi-Fi access points, Bluetooth signals, beacon signals, and cell tower IDs, which can be used to derive or estimate precise location or other geographic information). When an end user enables location services for a mobile application or website that uses our SDK (you generally have to opt-in to turn on device-based location services).

Log Information – This category includes the application or website visited, session start/stop time, time zone and network connection type (e.g., WiFi, cellular), and cookie information.

Information from advertising partners (“advertisers”) and other third parties – This category includes information we receive from publishers, advertisers, and other partners who help us serve ads and personalize content to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some advertisers or other third-party ad platforms choose to share with us. This information is also used to enhance data points about specific unique browsers or devices.

Appnext's privacy policy shall prevail  https://www.appnext.com/privacy-policy-oem-operators/ 

(2) Disclosure

We may disclose your personal information in accordance with the law to comply with court subpoenas, other similar legal procedures or government requests; or when we believe that disclosure of relevant personal information is required by law or necessary to protect our rights, property, the rights, property and safety of others, we may disclose your personal information, including disclosure to consultants, law enforcement agencies, and judicial supervision agencies. We may also transfer your personal information to a third party that acquires part or all of our property, equity, or acquires part or all of our business by merger, acquisition, reorganization or other means.

For the purposes of this Privacy Policy, our affiliates may also obtain users' personal information.

7. Your information rights

If you are located in the European Economic Area, you have the following rights (subject to a few exceptions provided for in the GDPR): (i) to access, modify or delete your personal information; (ii) to limit or refuse to process your personal information; and (iii) to request an electronic copy of your personal information to another person or third party. At the same time, you have the right to lodge a complaint with the local data protection authority in the European Economic Area regarding the processing of your personal information.

If you are a resident of California, U.S., effective January 1, 2020, you have the right to:

(i) exercise relevant consumer rights, such as requesting to know, disclose, access, and delete data collected over the past 12 months by emailing privacy@toponad.com; and (ii) requesting an opt-out from the sale of your data.

If you are a resident of Virginia, U.S. (effective January 1, 2023), or if you are a resident of Colorado or Connecticut, U.S. (effective July 1, 2023), you may exercise the following personal information rights with respect to us:

Confirm whether we are processing your personal information and access that personal information;

Correct inaccuracies in your personal information;

Delete your personal information;

Obtain a copy of the personal information you have provided to us; and

Request that we object to processing your personal information for purposes of: (i) personalized advertising, (ii) selling your personal information, or (iii) profiling that has a significant legal or similar impact on you.

You have the right to exercise these rights without discrimination, as provided in the VCDPA, CPA, and CDPA.

You may exercise your personal information rights described above by (i) sending a written request to privacy@toponad.com; and (ii) clicking this link to request a ban on personalized advertising, a ban on the sale of your personal information, or a ban on user profiling that has a significant legal or similar impact on you. If you fail to provide us with effective information for us to provide effective feedback when exercising the above rights, we may deny your exercise of your rights. If you disagree, you may further submit a written complaint to privacy@TopOn.com.

If you are a resident of Utah, USA, starting December 31, 2023, you may exercise the following personal information rights with us:

Confirm whether we are processing your personal information and access that personal information;

Delete your personal information;

Obtain a copy of the personal information you provided to us; and

Request that we refuse to process your personal information for the following purposes: (i) personalized advertising, or (ii) the sale of your personal information.

As provided by the UCPA, you have the right to exercise the above rights without discrimination.

Personalized advertising settings

Regardless of the country or region you are located in, you can opt out of interest-based advertising in the following ways.

Opt-out instructions

You can choose to opt out of receiving interest-based or behavioral advertising from TopOn by following the instructions below on devices that support the relevant features.

Your iOS mobile device may provide a "Do Not Track Ads" setting. On Android devices, your settings may allow you to "Stop receiving interest-based ads." If you turn on this setting on your device, TopOn will not use application information collected from your device to infer your interests or provide advertising services to the target device based on your inferred interests.

Your mobile web browser may also provide a "Do Not Track" browser setting. If your browser has this setting turned on, TopOn will not use mobile web browser information collected from your browser to infer your interests or provide advertising services to the target device based on your inferred interests. If you have any questions about your information rights, please contact privacy@toponad.com.

8. Security of User Personal Information

Protecting the security of your personal information is our top priority. We will take strict security measures to prevent your personal information from being obtained, used, disclosed or destroyed without authorization. We will take physical, technical and administrative measures that comply with relevant laws and industry standards. For example, we will use firewalls, encryption technology and other automated software designed to prevent fraud and identity theft; we only store information in devices and places that can provide a high degree of protection. We will also strictly monitor data access in the surrounding area and at the entrance of the building through video and other electronic monitoring methods.

I will minimize the storage of sensitive information on our servers to protect your privacy. We will also require partners to protect user data from the contract.

TopOn may save information about you collected from our business partners for the purpose of providing services, conducting internal analysis, complying with legal obligations, resolving disputes and executing contracts (such as settlement). We will only retain your personal information as long as necessary, and we will retain your personal information collected about you in accordance with this Privacy Policy for no more than 2 years. The criteria for determining retention periods include: (i) how long we need to retain personal information to provide the service and operate our business; (ii) the type of personal information collected; and (iii) whether we are bound by a legal, contractual or other similar obligation to retain the data (for example, mandatory data retention laws, government requirements to retain data related to an investigation, or data that must be retained for litigation or disputes).

9. Protection of minors

TopOn services are mainly for adults. We do not actively or deliberately collect information about minors, nor do we make user profiles or personalized recommendations for minors. In the personal information collection scenarios we disclose, we use device information to distinguish specific information subjects rather than age dimensions. In the scenarios where partners transmit and share data with us, we explicitly require our partners to formulate special policies for the protection of minors' information in accordance with the law and adopt stricter data desensitization and encryption technologies to protect minors based on the actual situation of their own products and services.

If the end user is a minor under applicable laws, please be sure to read the privacy policy of the developer or advertiser's application and this privacy policy carefully under the supervision and guidance of your parents or other guardians before using the developer's application that has integrated TopOn products and services or the advertiser's application that cooperates with TopOn for advertising, and use the application or provide personal information with the consent of the guardian.

We protect the personal information of minors in accordance with the provisions of applicable laws and regulations, and will only collect, use, store, share, transfer or publicly disclose the personal information of minors when permitted by law, with the explicit consent of parents or other guardians, or when necessary to protect minors. If we find that we have collected personal information of minors without obtaining verifiable parental consent in advance, we will take measures to delete the relevant information as soon as possible.

If you are a parent or other guardian of a minor, please contact us through the contact information disclosed in this Privacy Policy when you have questions about the personal information of the minor you are protecting.

If you are a user in the United States, we guarantee compliance with the Children's Online Privacy Protection Act (COPPA). If our business partners (for example, application developers) use applications for children under the age of 13, they need to make relevant COPPA settings for the application on the TopOn platform when using TopOn services, so that TopOn can ensure that the processing of the persistent identifiers collected from the application users complies with the provisions of COPPA, including not being used to deliver behaviorally targeted advertisements or to track users for this purpose. In addition, we will not intentionally collect other personal information (such as accurate geographic location information) from applications that we know are for children under the age of 13.

If a parent or guardian finds that their child has provided us with their personal information without consent, the parent or guardian should contact us in a timely manner. We will take reasonable measures to ensure that such information is deleted from our files.

10. Marketing

If you are our business partner, we may periodically send you information about our products and services and content that may be of interest to you via email. If the relevant law requires 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 can unsubscribe at any time by following the instructions provided in the marketing information or by sending an email to privacy@toponad.com to request not to receive such information.

TopOn Website Privacy Policy

1. Introduction

This TopOn Website Privacy Policy applies to the website's information collection and use, including information collected and used by TopOn when you browse and use the TopOn website. If the provisions of European data protection law should apply here, TopOn is the data controller of your personal information under European data protection law. If you have any questions, comments or suggestions, please contact us at the following contact information: Email: privacy@toponad.com

2. Information we collect

When you visit the TopOn website, the personal information you actively provide (such as name, date of birth, personal identification number, address, telephone number, email address, occupation, education background, work experience and other relevant information) will be collected, and some information you do not actively provide, such as browser type, domain name, IP address, web pages visited, and the length of time you browse the web using different technologies and methods, including the collection of IP addresses, Cookies, Internet tags and browsing data. In order to improve the quality of our services, we need your personal information to meet your personal needs and provide better services. TopOn has the right to take measures to verify the accuracy of the information you provide. If the information you provide is the personal information of others, we will assume that you have obtained the permission of others. The information transmission of the TopOn website may be non-confidential, so the information you transmit may be read or intercepted by others.

3. How we use your personal information

Based on our legitimate interests, you may need to provide us with your personal information for the following purposes: (i) to provide you with TopOn products, services or related information; (ii) to register you for related events or training; (iii) to contact and respond to your requests and inquiries; (iv) business management, including data analysis; (v) to provide you with personalized access services and assistance when using the website; or (vi) to help us understand our users and improve our website.

We will periodically provide you with information about our products and services and content that may be of interest to you via email. If applicable law requires 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 want to receive such marketing information, you can unsubscribe at any time by following the instructions provided in the marketing information or send an email to privacy@toponad.com to request not to receive such promotional information.

4. Disclosure of your personal information

We will share your personal information with third parties other than TopOn affiliates in accordance with applicable laws.

We may hire third parties to provide services for us, including companies that assist in the development and operation of the TopOn website at the program and technical level, service providers that provide technical services to assist in analyzing website usage, and email service providers, and such third parties may obtain your personal information. Our affiliates may also obtain your personal information through the TopOn website or in connection with the TopOn website for the purposes set forth in this Privacy Policy.

We may also share aggregated or anonymous information with other third parties in accordance with the terms of this Privacy Policy.

For the purposes of this Privacy Policy, our affiliates may also obtain users' personal information.

The network servers used in the operation of the TopOn website automatically identify (your) computer based on the IP address. However, once you leave the TopOn website, we will not be able to identify (your) computer based on the IP address. If we believe that you are attempting to or have abused or damaged the website, we will investigate and cooperate with relevant law enforcement agencies to safeguard our legitimate rights and interests.

At the same time, we will provide your personal information as required or permitted by law in accordance with court subpoenas, other similar legal proceedings or government requests; or we believe that such disclosure is necessary in accordance with legal requirements or to safeguard the legitimate rights and interests and security of us and/or other third parties (including consultants, law enforcement agencies, and judicial supervision agencies). We may also transfer your personal information to a third party that acquires some or all of our assets, shares, or that succeeds to some or all of our business by merger, acquisition, reorganization or otherwise.

5. International transfers

If you are located in the European Economic Area, personal information collected from you, including information collected from the TopOn website, will be transferred to countries located outside the European Economic Area, including Singapore, where the TopOn website servers are located, and other countries that have not been determined by the European Commission to provide an adequate level of protection for personal information. You hereby expressly consent to the transfer of your personal information to recipients located outside the European Economic Area as described in this Privacy Policy, including to TopOn, TopOn's affiliates and other recipients specified in this Privacy Policy.

6. Your information rights

You have the right to access, modify, amend or delete your personal information that we may have collected. To exercise these rights, please contact privacy@toponad.com.

If you are located in the European Economic Area, you will have the following rights (subject to limited exceptions): (i) request access to, modification or deletion of your personal information; (ii) restrict or object to the processing of your personal information; and (iii) request an electronic copy of your personal information to be provided to another person or third party. You also have the right to lodge a complaint with your local data protection authority in the European Economic Area regarding the processing of your personal information.

If you are a resident of California, United States, as of January 1, 2020, you have the following rights:

(i) exercise relevant consumer rights, such as requesting to know, disclose, access, and delete data collected in the last 12 months by emailing privacy@toponad.com; and (ii) requesting an opt-out from the sale of your data: Do Not Sell My Data.

If you are a resident of Virginia, United States (effective January 1, 2023), or if you are a resident of Colorado or Connecticut, United States (effective July 1, 2023), you may exercise the following personal information rights with us:

Confirmation whether we are processing your personal information and access to it;

Correct inaccuracies in your personal information;

Delete your personal information;

Obtain a copy of the personal information you have provided to us; and

Request that we object to processing your personal information for the following purposes: (i) personalized advertising, (ii) selling your personal information, or (iii) user profiling that has a significant legal or similar impact on you.

As provided by the VCDPA, CPA and CDPA, you have the right to exercise the above rights without discrimination.

You can exercise your personal information rights above by (i) sending a written request to privacy@toponad.com; and (ii) clicking on this link to request to prohibit personalized advertising, prohibit the sale of your personal information, and prohibit user profiling that has a significant legal or similar impact on you. If you fail to provide effective information for us to provide effective feedback when exercising the above rights, we may deny your exercise of your rights. If you disagree, you can further send a written complaint to privacy@toponad.com.

If you are a resident of Utah, starting December 31, 2023, you can exercise the following personal information rights with us:

Confirm whether we are processing your personal information and access that personal information;

Delete your personal information;

Obtain a copy of the personal information you provided to us; and

Request to refuse us to process your personal information for the following purposes: (i) personalized advertising, or (ii) sale of your personal information.

As provided by the UCPA, you have the right to exercise the above rights without discrimination.

7. Security of your personal information

We are committed to protecting the security of your personal information. We use a variety of protection technologies and procedures to protect your personal information and prevent your personal information from being obtained, used or disclosed without authorization. We will only retain your personal information as long as necessary, and we will only retain your personal information collected on the website for one year regardless of the method.

8. Protection of Minors

This website does not intentionally collect personal information from minors. Any personal information of minors you provide must be approved by the minor's parents or guardians in advance. The definition of minors is defined by the law applicable to this Privacy Policy.

9. Use of Cookies and Other Tracking Technologies

When you visit the TopOn website, TopOn may use cookies or other technologies (collectively referred to as "Cookies") to collect your personal information.

10. External Websites and Links

This website may contain links and instructions to websites owned or operated by third-party vendors and other third parties ("External Websites"). TopOn is not responsible for the effectiveness of External Websites and the content of External Websites (including any webcasting or any other form of transmission and reception of content on any External Website). If you have any questions about the relevant links or the content on the External Website, please contact the administrator of the External Website. If a third party has informed TopOn that it will link TopOn's homepage to the third party's website and TopOn has not refused, TopOn allows the third party to link to TopOn's homepage. TopOn reserves the right to unilaterally revoke the above consent at any time, including links to its homepage. Any external website provided on this website is only for your convenience. Any link or indication contained in this website does not mean approval of the external website.

11. Copyright

All website content, design, text, graphics, images, logos, buttons, icons, interfaces, audio and video, and all permutations and combinations of the above are the exclusive property of TopOn or its respective content providers and are protected by Hong Kong Special Administrative Region and international copyright laws. All software used on the website is the property of TopOn or its respective software providers and is protected by Hong Kong Special Administrative Region and international copyright laws and other relevant laws and treaties. Website users shall not send/upload any content that infringes on the copyright or other intellectual property rights of others to this website.

12. Trademarks

All trademarks, service marks and trade names (collectively referred to as "marks") used on the website are exclusive to TopOn. Such logos shall not be used on any non-TopOn product or service, or any other product or service that may cause consumer confusion or in any way discredit or discredit TopOn.

13. Online Behavior

If TopOn believes that any individual restricts or prohibits others from using this website, TopOn has the right to prohibit such behavior. You agree to use this website only for lawful purposes and agree not to carry out the above prohibited behavior. You agree not to upload or forward any illegal, damaging, threatening, insulting, harassing, defamatory, vulgar, obscene, sexually suggestive, blasphemous, hateful, racially discriminatory, regionally discriminatory or any other type of negative information to this website, including but not limited to any information that incites illegal behavior, such as any behavior that constitutes a criminal offense, civil liability or other violation of applicable local, state, domestic or international laws.

14. Termination of Use

Based on any violation of relevant laws, this Privacy Policy, or any violation of the interests of other users, third parties, retailers, sponsors, licensors, service providers or the website, TopOn may, at its sole discretion, terminate or suspend your access to all or part of the website without further notice or liability.

In view of the rapid development of network technology and the update of privacy data-related regulations, we will update this Privacy Policy from time to time. All revisions will be posted on the website www.toponad.com.