Privacy Policy

1. Introduction

ADPION CO. LTD ("Company", "we", "us") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, share, and safeguard data when you use the Adpion platform ("Service").

By using our Service, you consent to the data practices described in this policy. If you do not agree, please discontinue use of the Service immediately.

2. Information We Collect

2.1 Information You Provide

• Account Information: Name, email address, phone number, and password when you create an account.
• Payment Information: Cryptocurrency wallet addresses, transaction hashes, deposit amounts, and payment proof images.
• Communication Data: Messages, support requests, and correspondence you send to us.
• Identity Verification: Government-issued ID, business registration documents, or other verification materials if required.

2.2 Information Collected Automatically

• Usage Data: Pages visited, features used, timestamps, referral URLs, and interaction patterns.
• Device Information: IP address, browser type, operating system, device identifiers, and screen resolution.
• Cookies: Session cookies for authentication and preference storage. See Section 8 for details.

2.3 Information from Third Parties

• Advertising platform data (Meta, Google, TikTok): ad account status, spending data, and account performance metrics.
• Payment processor data for transaction verification.

3. How We Use Your Information

• Providing, maintaining, and improving the Service.
• Processing deposits, managing ad account balances, and facilitating top-ups.
• Communicating with you about account activity, service updates, and support requests.
• Detecting, preventing, and investigating fraud, abuse, and security threats.
• Complying with legal obligations, regulatory requirements, and law enforcement requests.
• Enforcing our Terms of Service and protecting our rights and property.
• Generating aggregated, anonymized analytics to improve our services.

4. Data Sharing & Disclosure

We do not sell your personal information. We may share your data in the following circumstances:

• Service Providers: Trusted third-party vendors who assist in operating our platform (hosting, analytics, payment processing).
• Upstream Media Partners: Licensed media agencies (e.g., BlueFocus) for ad account provisioning and management, limited to data necessary for service delivery.
• Legal Requirements: When required by law, subpoena, court order, or government regulation.
• Safety & Fraud Prevention: To protect against fraud, abuse, or threats to safety.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity.

5. Data Retention

• Account data is retained for the duration of your account's existence and for 3 years after account closure for legal and compliance purposes.
• Transaction records and financial data are retained for a minimum of 7 years as required by applicable financial regulations.
• Communication logs are retained for up to 2 years after the last interaction.
• Anonymized, aggregated data may be retained indefinitely for analytics and business improvement purposes.

6. Data Security

We implement industry-standard security measures to protect your data, including:

• Encryption in transit (TLS/SSL) and at rest for sensitive data.
• Secure password hashing using bcrypt.
• Access controls and role-based permissions for internal staff.
• Regular security audits and vulnerability assessments.

While we strive to protect your data, no system is 100% secure. You acknowledge that you provide data at your own risk.

7. Your Rights

Subject to applicable laws, you may have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your data, subject to legal retention requirements.
• Portability: Request your data in a machine-readable format.
• Objection: Object to processing of your data for certain purposes.

To exercise these rights, contact us at [email protected]. We will respond within 30 business days. Verification of identity may be required.

8. Cookies & Tracking Technologies

• Essential Cookies: Required for authentication, session management, and platform security. Cannot be disabled.
• Analytics Cookies: Help us understand usage patterns and improve the Service. You may opt out via browser settings.
• We do not use advertising or third-party tracking cookies.

9. International Data Transfers

Your data may be processed and stored in servers located outside your country of residence, including but not limited to Hong Kong, Singapore, and the United States. By using the Service, you consent to such transfers. We ensure appropriate safeguards are in place consistent with applicable data protection laws.

10. Children's Privacy

The Service is not intended for individuals under 18 years of age. We do not knowingly collect data from minors. If we become aware of such collection, we will promptly delete the data.

11. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be posted on this page with a revised "Last updated" date. Material changes may be communicated via email or platform notification. Continued use after changes constitutes acceptance.

12. Contact

For privacy-related inquiries or to exercise your rights:

• 📧 [email protected]
• 📍 Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central, Hong Kong