User privacy and data security are our top priorities. At Ocean Gem Link, we fully recognize the trust you place in us when accessing and using our mobile application, and we commit to protecting your personal data in strict compliance with global data protection regulations. This Privacy Policy clearly defines what data we collect, how we utilize, process and share your information, as well as your legitimate rights regarding your personal data. This policy applies to all users of our Ocean Gem Link mobile application (hereinafter referred to as the “App”). For any inquiries regarding our privacy practices, you may reach out to us via the official contact email provided below.
1. Data We Collect
We only collect necessary user and device data to maintain App operation, optimize user experience, analyze service performance and deliver standardized advertising services. All collected data is processed strictly within the scope permitted by relevant laws and user authorization. The specific data categories are as follows:
1.1 Behavioral & Statistical Data
During your use of the App, we automatically collect anonymous usage statistics, including but not limited to in-app click behaviors, access pages and browsing tracks, App startup records, functional operation status, device permission activation status, local application installation data, App package names, device network status, and system operation logs. Such data is only transmitted to our certified third-party statistical platforms (Max, Adjust) and our internal data analysis system. We solely use this data to optimize product functions, fix operational defects and improve advertising delivery accuracy, and will not disclose or sell it for unauthorized commercial purposes.
1.2 Device & Network Information
To stabilize App operation and adapt to different device environments, we collect basic device and network information based on your interactive behaviors and personal privacy settings. The collected information covers SDK and API version information, device operating platform, operation timestamp, App identification and version number, unique device identifiers, device brand and model, system version, system language, time zone, Wi-Fi network status, Google Play release information, ad delivery strategies and advertising platform IDs. We reserve partial device data associated with Android IDs to record standardized in-app advertising behaviors, which are uniformly categorized as user personal information and protected in accordance with privacy regulations.
1.3 Third-Party SDK Data
Our App integrates authorized third-party functional and advertising SDKs to realize service monetization, data statistics and anti-fraud monitoring. These third-party service providers may access and process your relevant data within the scope of authorization, including Google advertising IDs, IP-based regional demographic information, ad click anti-fraud data, device type and technical parameter information, and data for advertising delivery, market analysis and user behavior statistics. Third-party partners include but are not limited to Google Admob, Meta Audience Network, IronSource, AppLovin, Vungle, Unity, Amazon Ads, Pangle, Mintegral, Yandex, Kwai, Bigo, Inmobi and Moloco, as well as data analysis platforms Adjust and Max. All data processing behaviors of third-party SDKs are governed by their independent privacy policies, and we do not possess control over their data operations.
1.4 Advertising Identifier Data
We use your Android Advertising ID to deliver personalized, targeted advertising content and conduct standardized data analysis. This advertising identifier does not carry any sensitive user information, cannot independently identify individual users or specific devices, and is not associated with permanent device identifiers such as SSAID, MAC address and IMEI. It is only used for advertising matching and operational statistics, without any other unauthorized usage.
1.5 Payment & Transaction Data
If you initiate withdrawal or other financial transaction behaviors within the App, we will collect the relevant information you voluntarily submit. Meanwhile, our official cooperative payment service providers will obtain necessary financial account information and transaction details to complete fund settlement and transaction verification. All payment data is protected by encrypted technology and only used for completing user-initiated financial services.
1.6 Voluntarily Submitted Information
We may collect non-mandatory information you actively provide during App usage, including but not limited to custom nicknames, user feedback, suggestion content and other interactive information. Such data is completely provided on a voluntary basis, and you may choose not to submit relevant content.
2. Purpose of Data Processing
All personal data we collect is processed for legitimate, specific and necessary purposes only. We may share authorized user data with third-party partners such as advertising service providers, traffic publishers and data statistical institutions. Authorized third parties may use the data to deliver targeted advertisements, count ad interaction effects, analyze App traffic and user operation habits, and optimize their own service systems. The data usage behaviors of all cooperative third parties are subject to their respective privacy policies, and we will bear no responsibility for their non-compliant operations.
3. Legal Basis for Data Processing
Our processing of your personal data complies with global mainstream data protection laws and regulations, and is based on the following legitimate legal bases: (1) Contract performance: necessary for providing you with complete App services, verifying user identity and ensuring normal functional operation; (2) Legal compliance: necessary for fulfilling legal obligations, retaining transaction records and responding to official legal inquiries; (3) Legitimate interests: based on reasonable operational needs, including ensuring App security, preventing fraudulent behaviors, optimizing product experience and conducting normal business communication; (4) User consent: based on your explicit authorization for cookie deployment, personalized advertising push and third-party data sharing. You may withdraw your consent at any time without affecting the legality of prior data processing behaviors.
4. User Privacy Rights
In accordance with GDPR, CCPA and other global data protection regulations, you enjoy complete personal data rights. To exercise your rights, please submit a verified application via our official email: bangsawancyberindoindonesia@gmail.com. We will verify your identity after receiving the request and respond within the time limit stipulated by law. We reserve the right to reasonably restrict excessive, repetitive or invalid requests, as well as requests that may infringe on others’ privacy or violate legal regulations.
4.1 Right to Withdraw Consent
Where data processing relies on your explicit consent, you have the right to withdraw such authorization at any time. The withdrawal of consent will not invalidate any legitimate data processing conducted before the revocation.
4.2 Right to Access & Rectification
You may apply to obtain a copy of your personal data stored by us free of charge (except for statutory special circumstances). If your personal information is inaccurate or incomplete, you have the right to request correction and update of relevant data.
4.3 Right to Erasure (Right to be Forgotten)
You may request us to delete your personal data if the data is no longer required for the original collection purpose, if you withdraw your processing consent, or if you object to data processing and we have no legitimate overriding processing grounds.
4.4 Right to Processing Restriction
You are entitled to apply for restricting our data processing behaviors in the following scenarios: you dispute the accuracy of your personal data pending verification; data processing is illegal and you refuse data deletion; we no longer need the data but you require it for legal rights defense; you object to data processing pending legitimacy verification. We will only process restricted data with your consent or for legal defense, public interest and other legitimate purposes, and will notify you promptly when the restriction is lifted.
4.5 Right to Object
You may object to our data processing behaviors based on consent, contract performance or legitimate interests at any time. We may continue processing only for legal defense or other statutory exceptions.
4.6 Right to Data Portability
For data processed automatically based on your consent or service contract, you may request to obtain your personal data in a standardized, machine-readable format, or ask us to transfer the data to other data controllers (subject to technical feasibility and no infringement of third-party rights).
4.7 Third-Party Notification Right
If your personal data is shared with third-party partners, we will notify relevant third parties of your data correction, deletion or restriction requests (unless impossible or requiring excessive cost). You may also inquire about the list of relevant third parties through our official email.
4.8 Right to Refuse Automated Decision-Making
You have the right not to be subject to sole automated data processing (including user profiling) that produces legal or significant personal impact, except for statutory exceptions.
4.9 Right to Complaint
If you believe our data processing behaviors violate privacy regulations, you may contact us via the official email to resolve the issue. You also have the right to file a complaint with the local data protection authority in your residence, workplace or alleged infringement location.
5. Third-Party Partner Privacy Policies
The third-party SDKs integrated in our App independently formulate and enforce their privacy policies. We have no control over their data processing rules. You can view the detailed privacy terms of each partner via the official links below:
•Max/Applovin: https://www.applovin.com/privacy/
•Adjust: https://www.adjust.com/terms/privacy-policy/
•Vungle: https://vungle.com/privacy/
•Unity: https://unity3d.com/legal/privacy-policy
•Mintegral: https://www.mintegral.com/en/privacy
•ironSource: https://www.is.com/privacy-policy/
•Pangle: https://www.pangleglobal.com/privacy
•Google Play Services: https://policies.google.com/privacy
•Payermax: https://www.payermax.com/about/terms/TermsofUse
6. Special Provisions for EU & UK Users
Users residing in the European Union member states or the United Kingdom enjoy exclusive data rights under local data protection laws. You have the right to confirm our data processing scope, correct inaccurate data, delete redundant personal data, apply for processing suspension, and obtain machine-readable personal data copies. We will complete the processing of your legitimate rights application within one month free of charge. If you are dissatisfied with our processing results, you may file a complaint with the local data supervision authority. To verify your identity when submitting a request, you need to complete email verification, and we will match your information with our internal system records.
7. CCPA Compliance Provisions for California Residents
This clause applies exclusively to users residing in California, USA, complying with the California Consumer Privacy Act (CCPA). Non-California users are not applicable to this part of the terms.
7.1 Right to Data Disclosure Inquiry
You (or your authorized agent) may request us to disclose the categories of personal data we have collected, data sources, commercial processing purposes and shared third-party categories within the past 12 months.
7.2 Right to Data Deletion & Opt-Out
You have the right to opt out of personal data sales and sharing behaviors, and request us to delete your stored personal data. We may retain partial data only for security risk prevention, App error repair, legal right protection and other statutory legitimate purposes.
7.3 Application & Response Rules
You may submit verifiable consumer requests via our official email, with a maximum of two valid applications within 12 months. We will complete the review and response within 45 days (extendable to 90 days for special circumstances). We do not charge fees for normal requests, and will only charge reasonable fees for repetitive, excessive or invalid applications.
7.4 Non-Discrimination Provision
We will not implement differential treatment or discriminatory behaviors against any user who exercises CCPA rights, including refusing services, charging different fees and providing differentiated service quality.
7.5 Minor Data Protection
Our App is not oriented to users under the age of 13, and we do not actively collect personal information of minors under 13. Once we discover unintentional collection of minor personal data, we will delete it immediately. Users aged 13–16 need parental consent to participate in personalized data authorization. Parents or guardians may contact us at any time to handle minor data-related issues.
8. Minor Protection Policy
We strictly abide by global minor privacy protection regulations, and do not actively contact or collect personal information from children under 13. If you find that we have mistakenly collected minor data, please contact us in a timely manner, and we will promptly delete the relevant information or complete parental authorization verification as required by law.
9. Policy Updates & Revisions
We reserve the right to update this Privacy Policy irregularly to adapt to service upgrades, technical iterations and legal requirement changes. All revised terms will be updated on this page with a revised effective date. For major policy changes that expand data usage and sharing scope, we will obtain your explicit consent again. Your continued use of the App after policy updates will be deemed as recognition of the revised terms.
10. Contact Us
If you have any questions, suggestions or rights exercise needs regarding this Privacy Policy and data processing behaviors, please contact us via email: hongt19891120@gmail.com
Last Updated: August 15, 2026