1. Introduction

Shenzhen Hi-Spark Ad Media Co., Ltd. (hereinafter "Hi-Spark", "we", or "the Company") recognizes the importance of your personal information and is committed to protecting its security and reliability. This Privacy Policy (hereinafter "this Policy") is designed to clearly explain to you 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 and all services provided through the AdsPlus ad aggregation SDK.

Before using our products or services, please carefully read and fully understand this Policy. By using or continuing to use Our Services, you agree to all of this Policy's contents.

2. Information We Collect

2.1 Information You Provide Directly

• Registration Information: When you register a Hi-Spark account, we collect your email address, username, and encrypted password.
• Contact Information: Your name, phone number, email address, company name, job title, and other information you voluntarily provide.
• Business Information: Invoice details (company name, tax ID, registered address), bank account information, payment address, etc.
• Communication Records: Records of your communications with our customer service team.

2.2 Automatically Collected Information

• Device Information: Device model, OS version, screen resolution, device language, and time zone 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 impressions, and interaction data.
• Performance Data: App launch time, ad load time, crash logs, and network request response times.

2.3 Sensitive Information Notice

We may collect location information (precise or approximate) to deliver regionally relevant ad content. You may disable location permissions in your device settings. We do not collect highly sensitive information such as national ID numbers, bank passwords, or payment passwords.

3. How We Use Your Information

We collect and use your personal information only to the extent necessary for the following purposes:

1. Service Provision & Maintenance: Ensuring the normal operation of the ad aggregation platform, processing ad requests and impressions.
2. Ad Optimization: Delivering more relevant ad content based on device information and user preferences.
3. Anti-Fraud Monitoring: Identifying abnormal traffic and preventing ad fraud and abuse.
4. Revenue Settlement: Compiling ad performance data and settling revenue with partners.
5. Product Improvement: Analyzing usage data to improve user experience and product features.
6. Legal Compliance: Complying with applicable laws and regulations and cooperating with regulatory data requests.
7. Customer Support: Handling your inquiries, complaints, and technical support requests.

We will not use your personal information for any purpose not described in this Policy. If we intend to use information for a new purpose, 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 International Partner SDKs

We only share the minimum information necessary to deliver our services with these SDKs. Each SDK's data processing activities are 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 the normal operation of basic website functions such as login state maintenance 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 website functionality and user experience. We use tools such as Google Analytics for analysis.

5.3 Advertising Cookies

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

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

6. Data Storage & Cross-Border Transfer

6.1 Storage Location

Your personal information is primarily stored on servers located within the People's Republic of China. For overseas operations, some 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:

• Signing Standard Contractual Clauses (SCCs)
• Conducting Data Protection Impact Assessments (DPIA)
• Ensuring recipients maintain an adequate level of data protection
• Complying with PRC Personal Information Protection Law (PIPL) regulations on cross-border transfer

7. Data Security Measures

We have established a full-chain security protection system:

• Transmission Encryption: All data in transit is encrypted using TLS 1.3, ensuring data cannot be eavesdropped or tampered with during transmission.
• Storage Encryption: Sensitive data is stored using AES-256 encryption.
• Access Control: Only authorized personnel may access user information, and all access is logged.
• Regular Audits: Quarterly security vulnerability scans and annual penetration tests.
• Employee Training: All employees receive regular data protection training and sign confidentiality agreements.

8. Data Retention Period

We retain your personal information only for the period necessary to fulfill the purposes described in this Policy. The specific criteria are as follows:

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

After the retention period expires, your personal information will be deleted or anonymized (so that it cannot be identified to 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 the personal information we hold about you.
3. Right to Correction: Request correction when information is inaccurate.
4. Right to Deletion: Request deletion of your personal information under specific circumstances.
5. Right to Withdraw Consent: Withdraw your consent for 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 processing under specific circumstances.
8. Right to Lodge a Complaint: Lodge a complaint with the relevant authorities.

To exercise any of the above rights, please contact us using the details in Section 13. We will respond to your request within 15 business days.

10. Children's Privacy Protection

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

If we discover that we have collected personal information from a child 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 app targets children, please provide a compliant Children's Privacy Policy within your app.

11. Data Breach Response

Although we have implemented strict security measures, we cannot completely eliminate the possibility of security incidents. In the event of a data breach, we will:

1. Immediately activate our emergency response mechanism and take measures to control the situation.
2. Notify affected users within 72 hours, informing them of the content of the leaked information, potential impacts, and remedial measures taken.
3. Report the incident to relevant regulatory authorities.
4. Conduct an internal investigation to identify the cause and improve security measures.

12. Policy Updates

We may update this Policy from time to time based on business adjustments or changes in laws and regulations. You will be notified of updates in the following ways:

• Non-material Changes: Update notices posted on the website homepage or within the app.
• Material Changes: Notified 15 days in advance via email, in-app message, or pop-up.

Material changes include but are not limited to: significant changes in the scope of information collection, changes in the purpose of information use, and significant changes in data sharing recipients. Continuing to use Our Services constitutes your agreement to the updated Policy. If you disagree with the updated Policy, you have the right to stop using Our Services.

13. Applicable Law & Dispute Resolution

The formation, execution, and interpretation of this Policy are governed by the laws of the People's Republic of China. Any dispute arising out of or in connection with this Policy shall first be resolved through friendly negotiations between the parties. If negotiation fails, either party may submit the dispute to the Shenzhen Arbitration Commission for arbitration in accordance with its arbitration rules in effect at that time.

14. Contact Us

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

• Customer Service Email: info@hi-spark.com, chenfei@hi-spark.com (reply within 24 hours)
• Data Protection Officer: tech@hi-spark.com
• Mailing Address: Room 206-207, Building G1, Yufeng Garden, No.108 Fenghuang Avenue, Pinghu Street, Longgang District, Shenzhen, China (Attn: Mr. Chen)

We will respond to your request within 15 business days of receiving it. 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.