We believe that protection of Personal Data is vital so we are committed to complying with your right of receiving information about our measure through this Privacy Policy.
Please take the time to read this Privacy Policy carefully, as it outlines key details about:
- The types of personal data we may collect from you;
- How we use the personal data we gather;
- Whether and with whom we may share your information; and
- The choices and rights you have in relation to the personal data we process.
For clarity, in this Privacy Policy the following terms are defined as follows:
- "Account" means a unique account created for You to access our Service or parts of our Service.
- "Affiliate" means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Top Ads HK Limited, a Hong Kong company whose company registered office is Rm 7B, One Capital Place, 18 Luard Road, Wan Chai, Hong Kong and who is responsible for Personal Data collection and processing;
- "Cookies" are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- "Country" refers to: United Kingdom
- "Device" means any device that can access the Service such as a computer, a cellphone or a digital tablet.
- "Personal Data" is any information that relates to an identified or identifiable individual.
- Service refers to the Website.
- "Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- "Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- "Website" accessible from https://topadshk.co/
- "You" means the individual accessing or using the Service. If you access or use the Service on behalf of a company or other legal entity, "You" refers only to the individual user. If you do not understand or agree to this Privacy Policy, you must leave this Website or service.
If there are any questions regarding this Privacy Policy you may contact us using the information below:
The Data controller responsible for your Personal Data is Top Ads HK Limited.
What Personal Data we collect
We collect Personal Data in two primary ways:
- Directly from you – when you provide the necessary details to create an account, such as your name, email address, phone number and similar information. We might also ask you to provide other Personal Data to us.
- Automatically – through cookies and web server logs that record your online activity and device settings. This may include, but is not limited to, your IP address, device type, device identifiers or serial numbers, browser type and version, language preferences, operating system details, as well as data on the number of visitors and frequency of access to our Website.
Some of this Personal Data may be collected through the use of cookies, similar tracking technologies, and third-party analytics tools, including but not limited to Google Analytics.
Google Analytics collects information such as how often users visit the Website, what pages they visit when they do so, and what other sites they used prior to coming to the Website. We use the information we get from Google Analytics only to improve the Website and Program. Google Analytics collects only the IP address assigned to you on the date you visit the Website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your Personal Data. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Website, the cookie cannot be used by anyone but Google. Google's ability to use and share information collected by Google Analytics about your visits to the Website is restricted by the e Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Website by disabling cookies on your browser.
If you want to find out more about the types of cookies we use, take a look at our Cookies and Tracking Technologies.
In addition to data collected via the Website, we may also receive information from external sources, including publicly available records and trusted third parties such as payment providers and certification authorities.
We would like to draw your attention that we do not have purpose to collect Sensitive Personal Data (SPD) which includes highly private details such as government identifiers (e.g., Social Security Number), account log-in credentials, financial account, precise geolocation, genetic data etc.
In order to avoid fraud, do not tell SPD to anybody if you are unsure of the Data Collector.
Since our services aim for consumers who have reached the age of consent, we do not collect or share Personal Data of anyone under 13.
We do not knowingly collect personally identifiable information from anyone under the age of 13 or the equivalent age as specified by law in your jurisdiction. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
Means of Personal Data Usage
We process personal data for the following legitimate purposes:
- Fulfilling our contractual obligations with you, your employer, or your organization, including steps taken at your request before entering into a contract;
- Providing you with the information, products, and services you request from us;
- Managing and administering your account, including verifying and authenticating your identity;
- Processing and verifying financial transactions, such as payments you make to us or payments we issue to you (depending on whether you act as an Advertiser or Publisher) in connection with the Awin Network;
- Keeping you informed about updates, changes, or improvements to our services and products;
- Offering technical support and related service information;
- Responding to inquiries, resolving issues, and troubleshooting problems;
- Monitoring transactions and communications to ensure security, prevent fraud and crime, and safeguard our staff, property, website visitors, and third parties;
- Meeting compliance, auditing, and reporting obligations across relevant jurisdictions, including for crime prevention and legal enforcement purposes;
- Ensuring that our services are used lawfully, safely, and without disruption, harassment, or fraudulent activity, while also enforcing our rights and complying with legal obligations.
Where we reasonably believe you may be in breach of applicable laws, we may use your personal data to notify appropriate third parties, such as your internet/email provider or relevant law enforcement authorities.
Besides we may use your Personal Data for technical purposes such as website analytics, social media widgets, news updates etc.
Cookies and Tracking Technologies
Cookies are small files that are stored on your device. In conjunction with comparable technologies, cookies facilitate the collection and retention of information regarding your browsing, usage, and download activities on our Site, as well as within the broader ecosystem of websites and applications through which our Services are provided.
On our website cookies are divided into two categories: sessional, which persists only until you end your session, and persistent, which persists even after you end your session.
Information collected through the use of the cookies and similar technologies is used by us for purposes described in our Privacy Policy.
Our use of cookies and similar tracking technologies is classified according to the purposes for which the related information is collected and processed. Please note that certain cookies may be deployed differently by our Clients:
- Strictly Necessary Cookies: These cookies are indispensable for the proper operation of the Site and cannot be deactivated within our systems. They are generally set in response to actions undertaken by you that constitute a request for services, such as configuring your privacy preferences, authenticating your login, or completing electronic forms.
- Performance and Analytics Cookies: These cookies enable us to monitor and analyze Site traffic and usage patterns, thereby facilitating the measurement and enhancement of the performance of the Site and the Services. They provide insights into the relative popularity of pages and the manner in which users navigate the Site.
- Functional Cookies: These cookies allow the Site to recognize you upon your return and to retain your stated preferences (for example, language selection or regional settings), thereby enhancing the personalization of your experience.
- Targeting Cookies: These cookies may be placed by our advertising partners to establish a profile of your interests and to deliver advertising content tailored to those interests. They may also serve to restrict the frequency with which specific advertisements are presented to you and to evaluate the effectiveness of advertising campaigns.
You have the right to decide whether to accept or reject cookies. You can:
- Browser Settings: Most browsers automatically accept cookies, but you may modify your browser settings to refuse cookies or alert you when cookies are being placed.
- Cookie Banner/Consent Tool: Where required by law, we will provide a cookie banner or consent management platform to allow you to manage your preferences.
- Opt-Out Tools: Some third-party providers may offer their own opt-out mechanisms (e.g., Google Analytics opt-out tools).
Please note that disabling certain cookies may affect the functionality of the Site and limit your user experience.
Automated Processing and AI
We may use automated systems, including algorithms and artificial intelligence tools, to analyze usage data and improve our Services. These systems do not make decisions that have legal or similarly significant effects on You. You may request human review of any decision based solely on automated processing.
Share and Disclosure of Personal Data
To fulfill our obligations and provide a high-quality service, we may need to process your Personal Information or, in certain cases, disclose it to our partners or legal authorities. This may occur for the following purposes:
- Contractual and Business Needs – to create and manage affiliate or advertiser accounts; review and approve applications; track commissions; manage campaigns; issue payments; provide customer support; and communicate with you regarding your account or transactions.
- Legal Obligations – to verify your identity and comply with applicable laws, including Anti-Money Laundering (AML) and Know-Your-Customer (KYC) requirements; and to prevent, detect, and report fraud or other unlawful activities.
- Legitimate Interests – to safeguard our platform, affiliates, advertisers, and users from fraud or misuse; to analyze and improve our website, programs, and services; to promote our services and share relevant offers; to collaborate with trusted service providers and partners who support our operations; and to maintain the security and functionality of our systems.
- Consent – where required by law (for example, for certain marketing communications), we will only process your data with your explicit consent. You may withdraw your consent at any time.
- Compliance and Public Interest – in limited cases, we may process data to meet public interest requirements (such as sanctions checks) or to comply with other legal bases as required under local laws.
We take appropriate measures to keep your Personal Information secure and protected against unauthorized access. Access is strictly limited to a select group of parties who may use it only for specific, permitted purposes. This group includes:
- Other entities within our corporate group;
- Third-party service providers and business partners that support the operation, delivery, functionality, marketing, or promotion of the Website, Services, or Programs you use;
- Regulatory authorities, law enforcement agencies, governmental bodies, courts, fraud prevention agencies, licensing authorities, or other third parties, where disclosure is required to comply with applicable law or regulation, or to establish, exercise, or defend legal claims (where legally permissible, we will notify you of such disclosures);
- Advertisers whose offers you choose to engage with;
- Affiliates or other intermediaries who introduce you to us;
- Identity verification and authentication providers;
- Actual or prospective purchasers, and their advisers or representatives, in connection with a proposed or actual merger, acquisition, or sale of any part of our business; and
- Any other individuals or entities, where you have provided your explicit consent.
Security
We implement suitable technical and organizational measures to protect your personal data against loss, misuse, or unauthorized alteration, which include:
- Data encryption. We encrypt all data that goes between you and us using industry-standard TLS (Transport Layer Security), protecting your personal and financial data. Your data is also encrypted when it is stored on our servers, and encrypted when we transfer it between data centres for backup and replication.
- Limited access. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it.
- Network protection. Multiple layers of security controls protect access to and within our environment, including firewalls, intrusion protection systems and network segregation. Our security services are configured, monitored and maintained according to industry best practice. We partner with industry-leading security vendors to leverage their expertise and global threat intelligence to protect our systems.
- Secure data centres. Our servers are located within enterprise-grade hosting facilities that employ robust physical security controls to prevent physical access to the servers they house. These controls include 24/7/365 monitoring and surveillance, on-site security staff and regular ongoing security audits. We maintain geographically separated data replicas to minimize the risk of data loss or outages.
- Security monitoring. Our security team continuously monitors security systems, event logs, notifications and alerts from all systems to identify and manage threats.
- All personnel are subject to full confidentiality. In the event that your data is compromised, we will notify you and competent supervisory authority(ies) within 72 hours.
Data breach notification
We implement automated systems to monitor and log all security incidents, identifying potential vulnerabilities and recording breach details for analysis.
However, if a breach occurs, affected users and the relevant supervisory authority are going to be informed within 72 hours.
Data Retention
We retain your Personal Data for as long as we continue to provide services to you or our business partners, or for as long as it is reasonably necessary to do so. You can manage the amount of Personal Data you share with us at any time by updating your account details or requesting the deletion of your account.
However, even if you close your account, complete a transaction, or stop using our services, we may still retain certain Personal Data in order to:
- Comply with legal and regulatory requirements;
- Support fraud monitoring, detection, and prevention efforts; and
- Fulfill tax, accounting, and financial reporting obligations.
Your Rights regarding Personal Data
According to Chapter 3 of GDPR you can exercise the following rights:
- Right to access. You have the right to access (and obtain a copy of, if required) your Personal Data.
- Right to rectification. You have the right to update your Personal Data or to correct any inaccuracies.
- Right to erasure. You may have the right to request that we delete your Personal Data in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
- Right to restriction of processing. You may have the right to request to restrict the use of your Personal Data in certain circumstances, such as when you have objected to our use of your Personal Data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to data portability. You have the right to transfer your Personal Data to a third party in a structured, commonly used and machine-readable format, in circumstances where the Personal Data is processed with your consent or by automated means.
- Right to object. You may have the right to object to the use of your Personal Data in certain circumstances, such as the use of your Personal Data for direct marketing.
- Right to complain. You may sent your a complaint to us if you believe we breached any rule of Personal Data collection, processing or protection.
Opt-Out Option
According to the Article 6(1)(b) GDPR and CCPA/CPRA (if you are a California Resident) you have the right to opt out of certain uses of your Personal Data, including receiving promotional emails, newsletters, data Sharing with Third Parties or other legitimate interests.
You may exercise this right by contacting us at info.topadshk@gmail.com.
Complaints
If you are not satisfied with how we are processing or using your Personal Data, please contact us through our email info.topadshk@gmail.com. We will review and investigate your complaint, and try to get back to you within a reasonable time frame.
You have the right to complain to your local data protection authority. This right may not be available to you if there is no authority dealing with data protection in your country. You can exercise your rights at any time by making adjustments in your account or by sending an email to info.topadshk@gmail.com.
Modifications
We may update this Privacy Policy from time to time to reflect changes in our practices or services. Whenever updates are made, the "Last Updated" date at the top of this Policy will be revised.
We encourage you to review this page periodically to stay informed about any updates to this Privacy Policy or our related policies. If You continue to use the Service after those changes are in the effect, You agree to the revised Privacy Policy.
