Effective Date: Sept. 4th, 2024

OKSPIN Co., Limited ("Company," "we," "us," "our") is an ad network that provides a suite of tools for app developers and businesses to streamline and enhance the marketing and monetization of their platforms, products, and services. We facilitate the placement of various types of advertisements on digital properties, including mobile apps and connected TV devices (collectively, the "Services"). Through the Services, we also provide End Users with gaming opportunities where they can earn Rewards by participating in activities specified by OKSPIN. Advertisers, Publishers/Developers and End Users who use the Services are collectively referred to as "you" , "your" or "yours". To deliver these Services, we collect and utilise certain information related to user activity and preferences. This Privacy Policy outlines our practices for collecting, using, and sharing information through our Services, which encompass our advertising and optimization platform and other interactive products that link to this Privacy Policy (also collectively as the "Services"). We are committed to safeguarding your privacy and ensuring the protection of the personal information we handle.

This Privacy Policy explains how OKSpin Co., Limited ("Company," "we," "us," "our") collects, uses, shares, and stores personal information ("Personal Data") in connection with our Services and website. The practices outlined in this policy govern our handling of all personal information we process and ensure your rights and choices regarding that information are protected.

A. You voluntarily share your information with us. For example, when you create an account and when you fill any online forms on the Website.

B. We use automated data collection technologies to collect your information, such as cookies, HTML5 local storage, tags and pixels, mobile device identifiers, etc. We also collect information from you through these technologies when you integrate our SDK, API into your applications, websites and/or Ads.

C. Information collected from other sources. We may receive your information from third parties with whom we work and from public sources.

We use the information we collect to support and enhance our Services through various means:

Additionally, we may process your information in the following specific ways:

By processing your information in these ways, we aim to provide a secure, personalised, and high-quality experience while adhering to legal standards.

The information we collect through our Services may also be used to deliver ads that we believe you may be interested in. We process Non-Personal Information to identify potential cases of abuse and to generate statistical insights about Website usage. This statistical information is anonymized and not used in a way that could identify specific users. To enhance our service and improve user experience, OKSpin automatically collects and records certain information sent by your browser when you use our Services. Details of the types of personal information can be found at Annex A.

We may use personal information that has been aggregated, deidentified, or otherwise anonymized and thus does not directly or indirectly identify you and that cannot, with reasonable efforts, resources, and technologies, be used to reidentify you. Such aggregated, anonymized, deidentified, or otherwise not re-identifiable information is not personal information within the scope of this Privacy Policy or applicable privacy laws.

We use such information to identify potential cases of abuse and to generate statistical insights about Website usage. This statistical information is anonymized and not used in a way that could identify specific users.

To enhance our service and improve user experience, OKSPIN automatically collects and records certain information sent by your browser when you use our Services. Details of the types of personal information can be found at Annex A.

We process your personal information based on several legal grounds, depending on the context and purpose of the processing. These legal bases include:

We and our partners use cookies and similar technologies to analyse trends, manage our Site, track user activity, monitor user activity across our Site, and collect demographic information about our overall user base. Cookies help retain user preferences, store information such as shopping cart contents, and provide anonymized tracking data for third-party applications, generally enhancing your browsing experience.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. Note that certain parts of the Website may not function properly without cookies. Additionally, even if you limit cookies for interest-based advertising, you may still receive ads, but they may be less relevant to your interests. If you erase your cookies, reset your device identifier, or use different browsers or devices, you may need to make your choices again. If you prefer not to use cookies, you can disable them through your browser settings.

We may also permit certain third-party companies to place cookies and track user behaviour to help us deliver advertising that may be of interest to users. For more guidance on managing cookies, you can consult the Help section of your browser or visit internetcookies.com.

If you would prefer to not receive personalised ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests. To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:

A. Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http:// optout.aboutads.info/) and mobile application-based "AppChoices" download page (https://youradchoices.com/appchoices).

B. European Interactive Digital Advertising Alliiance (EDAA)'s consumer opt-out page (http://youronlinechoices.eu).

C. Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).

In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Android's GAID), visit the device manufacturer's current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: http:// www.networkadvertising.org/mobile-choices.

Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt-out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. Our Website does not track its visitors over time and across third party websites. However, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

We may share the information we collect or derive with third parties under the following circumstances:

A. Service Providers: We transfer information to service providers and other partners who support our business operations. This includes partners that provide technical infrastructure services, help us analyse how our Services are used, measure ad effectiveness, cheating detection, facilitate payments, or offer customer support. These partners are required to adhere to strict confidentiality obligations consistent with this Privacy Policy and our agreements with them. They are authorised to use your personal information only as necessary to perform their functions on our behalf. We partner with anti-cheating platforms such as “CheatBlocker” who provide us with cheating detection services, so as to ensure the integrity and security of our Services.

B. Affiliates: We may share your information with our affiliates for purposes that are consistent with this Privacy Policy. This allows us to streamline operations across our business entities and deliver a cohesive user experience.

C. Advertising Partners: We work with advertising partners, including advertisers, ad networks, exchanges, publishers, and others, to provide advertising services. We may share your information with these partners to help deliver ads that are relevant to you, conduct web analytics, and improve ad experiences. These partners may use the information to measure ad performance, provide interest-based or behavioural advertising, and analyse traffic. Please note that our advertising partners have their own privacy policies, which govern their use of your data.

D. Regulatory or Legal Requirements: We may disclose information to governmental or regulatory authorities as required by law, such as for tax or accounting purposes. We may also disclose information in response to a subpoena, court order, or other legal process, or to assist in investigations. Additionally, we may share information in connection with claims, disputes, or litigation, or to comply with legal obligations.

E. Safety and Terms Enforcement: If we determine that disclosure is necessary to protect the health, safety, or rights of any individual, prevent fraud, or enforce our legal rights (including contractual commitments made to us by third parties), we may share your information. This helps ensure the security and integrity of our Services.

F. Business Transfers: In the event of a business transaction, such as a merger, acquisition, joint venture, financing, or sale of assets, we may disclose personal information to a third party as part of the transaction. This may also include instances of insolvency, bankruptcy, or receivership, where personal information is transferred as part of organisational assets.

G. Consent-Based Sharing: With your consent, we may share your information for specific purposes, such as advertising and marketing. You can contact us to opt out of such sharing at any time. If you do not want us to share your personal information with third parties for marketing purposes, please reach out to us at privacy@okspin.tech.

H. Additionally, we may disclose information when we believe in good faith that it is necessary to protect our rights, ensure your safety or the safety of others, investigate fraud, or respond to a government request.

At OKSpin, safeguarding your personal information is a top priority. We employ robust physical, technical, and administrative security measures to protect the data we collect, process, and store. Our security protocols ensure that the data exchanged between you and our platform is protected during transmission. You can verify that your connection is encrypted by looking for the "https://" in the browser's address bar, along with a padlock symbol.

In addition to encryption, we regularly review and update our security measures to keep pace with technological advancements. Our security practices include:

However, despite our best efforts, no method of data transmission over the internet or electronic storage can be completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security. It is also important to note that data transmitted in an unencrypted form, such as via email, could be intercepted by unauthorised third parties. Users should take precautions to protect their data during transmission, such as using encryption tools or other protective measures.

If you have any concerns about the security of your personal information, please contact us at security@okspin.tech.

5.2 Fraud Prevention and Automated Decision-Making

5.3 Data Breach

5.4 Storage Duration of Your Personal Information

Once personal data is no longer required for the purposes for which it was collected, we will either erase it or anonymize it so that it can no longer be linked back to individuals.

You have specific rights in terms of your personal information. Please send us an email at supportr@okspin.tech at any time if you would like more information about these or to exercise any of them. The following rights are yours:

Our Website contains links to other websites that are not owned or controlled by us. When activating these links, you will be forwarded directly to the websites of the other service providers. Please be aware that we are not responsible for the privacy practices of such other websites or third-parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect Personal Information. We cannot accept any responsibility for the confidential handling of your Personal Data on these websites of third-party companies, as we have no influence on the compliance of these companies with the data protection regulations. Please inform yourself about the use of your Personal Data by these companies directly on these websites. Providing Personal Data to these third-party websites is at your own risk.

We do not knowingly collect personal information from minors. We encourage parents to supervise their children's online activities and ensure they do not provide personal information through our platform. If you are under the age of 18, please do not submit any personal information through our Website or Services. If you suspect that a child under 18 has submitted personal data through our Website or Services, please contact us immediately, and we will promptly delete the information. If you are aware of any such instances, notify us by privacyr@okspin.tech.

As we are based in Hong Kong, if you are located outside Hong Kong and provide personal information to us, or to one of our group companies, your information will be transferred to us in Hong Kong in accordance with this privacy policy. We also would transfer personal data to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.

Please be aware, if you are based in the United Kingdom or the European Economic Area, that we may also transfer any personal information we collect from you to third-party data processors based in other countries (such as the United States) or to other companies in our group.

This Privacy Policy may be modified from time to time at our exclusive discretion to take into account changing industry standards, technological advancements, legal obligations, and other factors. We will update the "Effective Date" at the top of this privacy policy if we make any changes. Before the change takes effect, we may send you an email (sent to the email address you provided when creating your account) or post a notice on the website if we make any significant changes. It is recommended that you frequently review this Privacy Policy to make sure you are aware of the ways in which we gather, utilise, and distribute information.

Any modifications to this privacy statement will take effect as soon as they are published on the website. You consent to accept the amended Privacy Policy's terms by using the Website or Advertising Services after such changes.

If you have any questions or comments about this Privacy Policy, or you have a customer care issue, please send email to privacy@okspin.tech.

Please be sure to include your relevant account information in any correspondence to us. This will help ensure that we can respond to your inquiry in a timely manner.

Annex

Annex A