1. Introduction

Shenzhen Hi-Spark Ad Media Co., Ltd. (hereinafter referred to as "Hi-Spark", "we", "the Company") deeply understands the importance of personal information to you and is committed to protecting the security and reliability of your personal information. This Privacy Policy (hereinafter referred to as "this Policy") is intended to clearly explain how we collect, use, store, transfer, and protect your personal information.

This Policy applies to all websites and services operated by us, including but not limited to: hi-spark.com, as well as all services provided through the AdsPlus aggregation ad SDK.

Before using our products or services, please read and fully understand this Policy carefully. Your use of, or continued use of, our Services signifies your acceptance of all contents of this Policy.

2. Types of Information We Collect

2.1 Information You Actively Provide

• Registration Information: When you register a Hi-Spark account, we collect your email address, username, and encrypted password.
• Contact Information: Name, contact phone, email, company name, job title, and similar information you actively fill in.
• Business Information: Invoice information (company name, tax ID, registered address), bank account information, payment address, etc.
• Communication Records: Content records of your communications with our customer service.

2.2 Information Automatically Collected

• Device Information: Device model, OS version, screen resolution, device language and timezone settings.
• Network Information: IP address, network type (WiFi/4G/5G), carrier information (MCC/MNC).
• Advertising Identifiers: Android advertising ID (GAID), iOS advertising identifier (IDFA), Huawei OAID, anonymous device identifiers.
• Usage Data: Page visit paths, dwell time, click behavior, ad display and interaction data.
• Performance Data: Application launch time, ad loading time, crash logs, network request response time.

2.3 Sensitive Information Notice

We may collect location information (precise or coarse) to deliver region-relevant advertising content. You can disable location permissions in your device settings. We do not collect highly sensitive information such as ID card numbers, bank passwords, or payment passwords.

3. Purposes of Information Use

We only collect and use your personal information within the scope necessary to achieve the following purposes:

1. Service Delivery & Maintenance: Ensure normal operation of the ad aggregation platform; process ad requests and display.
2. Ad Delivery Optimization: Deliver more relevant ad content based on device information and user preferences.
3. Anti-Fraud Monitoring: Identify abnormal traffic and prevent ad fraud and abuse.
4. Revenue Settlement: Compile ad performance data and settle revenue with partners.
5. Product Improvement: Analyze usage data to improve user experience and product features.
6. Compliance Obligations: Comply with applicable laws and regulations; cooperate with regulatory data inquiries.
7. Customer Support: Handle your inquiries, complaints, and technical support requests.

We will not use your personal information for any purposes not stated in this Policy. If information needs to be used for new purposes, we will obtain your explicit consent in advance.

4. Third-Party SDKs & Information Sharing

To deliver ad aggregation services, Hi-Spark integrates the following third-party SDKs. These SDKs may collect necessary device information and ad interaction data:

4.1 Domestic Partner SDKs

4.2 Overseas Partner SDKs

We share only the minimum information necessary to deliver our services with these SDKs. Each SDK's data processing is governed by its own Privacy Policy. We recommend reviewing each platform's Privacy Policy.

5. Cookies & Tracking Technologies

We and our partners use the following types of cookies and similar technologies:

5.1 Essential Cookies

Used to ensure basic website functionality, such as maintaining login state and session management. These cookies cannot be disabled.

5.2 Analytics Cookies

Used to collect information on how visitors use our website, helping us improve site functionality and user experience. We use tools such as Google Analytics.

5.3 Advertising Cookies

Used to display more relevant ads, measure ad performance, and control ad display frequency. Our advertising partners may use cookies to build interest profiles.

You can manage or disable cookies through your browser settings. Disabling cookies may affect the normal use of certain features.

6. Data Storage & Cross-Border Transfers

6.1 Storage Location

Your personal information is primarily stored on servers located within the People's Republic of China. For overseas operations, certain data may be transferred to servers in the United States, Singapore, Germany, and other locations.

6.2 Cross-Border Transfer Safeguards

We take the following measures to ensure the legality of cross-border data transfers:

• Sign Standard Contractual Clauses (SCCs).
• Conduct Data Protection Impact Assessments (DPIA).
• Ensure recipients maintain equivalent levels of data protection capability.
• Comply with the cross-border transfer provisions of the PRC Personal Information Protection Law.

7. Data Security Measures

We have established a comprehensive, full-lifecycle security protection framework:

• Transmission Encryption: All data transmissions are encrypted with TLS 1.3 to prevent eavesdropping or tampering.
• Storage Encryption: Sensitive data is encrypted at rest using the AES-256 algorithm.
• Access Control: Only authorized personnel can access user information; all access activities are logged.
• Regular Audits: Quarterly vulnerability scans and annual penetration tests.
• Staff Training: All employees receive regular data protection training and sign confidentiality agreements.

8. Data Retention Period

We retain your personal information only for the time necessary to achieve the purposes described in this Policy. Specific criteria are as follows:

• Account Information: Retained while your account remains active; deleted or anonymized within 30 days after account closure.
• Advertising Data: Ad display and click data is retained for 6 months for performance analysis and settlement.
• Log Data: Server access logs are retained for 90 days.
• Transaction Data: Settlement and invoice information is retained for 7 years (tax compliance requirement).
• Communication Records: Customer service communication records are retained for 2 years.

Beyond the retention period, your personal information will be deleted or anonymized (rendered unable to identify a specific individual).

9. Your Rights & Choices

Under the PRC Personal Information Protection Law and related regulations, you have the following rights:

1. Right to Know: Learn how your personal information is collected and used.
2. Right of Access: Access personal information we hold about you.
3. Right to Rectification: Request correction of inaccurate information.
4. Right to Erasure: Request deletion of your personal information in specific circumstances.
5. Right to Withdraw Consent: Withdraw consent to our processing of your personal information.
6. Right to Data Portability: Obtain your personal information in a structured, commonly used format.
7. Right to Restrict Processing: Request restriction of information processing in specific circumstances.
8. Right to Lodge Complaints: File complaints with the relevant authorities.

To exercise the above rights, please contact us via the channels in Section 14. We will respond to your request within 15 business days.

10. Children's Privacy Protection

Our products and services primarily target enterprise users and adult developers, and are not directed at children under 13. We do not knowingly collect personal information from children under 13.

If you discover that we have collected personal information from children without verifiable parental consent, please contact us immediately and we will promptly delete the relevant information.

For app developers integrating our SDK, we require you to comply with all applicable children's privacy protection laws and regulations, including but not limited to the Provisions on the Cyber Protection of Children's Personal Information. If your application targets children, please provide a compliant children's Privacy Policy within the application.

11. Data Breach Response

Despite our stringent security measures, security incidents cannot be entirely avoided. In the event of a data breach, we will:

1. Immediately activate the emergency response mechanism and take measures to contain the incident.
2. Notify affected users within 72 hours, disclosing the content of the breach, potential impact, and remediation measures taken.
3. Report the incident to the relevant regulatory authorities.
4. Conduct an internal investigation to identify the root cause and improve security measures.

12. Policy Updates

We may update this Policy from time to time in response to business adjustments or changes in laws and regulations. We will notify you of updates through the following channels:

• Non-Material Changes: Post an update notice on the website home or within the application.
• Material Changes: Notify you by email, in-app message, or popup at least 15 days in advance.

Material changes include but are not limited to: significant changes to the scope of information collected, changes to the purposes of information use, and material changes to data sharing parties. Continued use of our Services signifies your acceptance of the updated Policy. If you do not agree to the updated Policy, you have the right to stop using our Services.

13. Governing Law & Dispute Resolution

The conclusion, execution, and interpretation of this Policy are governed by the laws of the People's Republic of China. Any disputes arising from or in connection with this Policy shall first be resolved through friendly negotiation; if negotiation fails, either party may submit the dispute to the Shenzhen Arbitration Commission for arbitration in accordance with its then-effective arbitration rules.

14. Contact Us

If you have any questions, comments, or suggestions about this Policy, or wish to exercise your rights, please contact us via the following channels:

• Customer Service Email: info@hi-spark.com, chenfei@hi-spark.com (reply within 24 hours)
• Data Protection Officer: tech@hi-spark.com
• Mailing Address: Unit 206-207, Building G1, Yufengyuan, No. 108 Fenghuang Avenue, Pingshu Street, Longgang District, Shenzhen, China (Recipient: Manager Chen)

We will respond to your request within 15 business days of receipt. If you are not satisfied with our response, you may file a complaint with the Shenzhen Cyberspace Administration or the Ministry of Industry and Information Technology.