Adsspark – Master Privacy Policy (Global Baseline)

Effective Date: 2025/09/10

At Adsspark (“Adsspark,” “we,” “our,” or “us”), protecting your privacy and personal information is one of our highest priorities. This Privacy Policy explains how we collect, use, store, disclose, and safeguard your personal information when you interact with our website (adsspark.co) or use our services.

This global policy applies to all visitors, clients, affiliates, and partners, regardless of where they are located. Depending on your country of residence, supplements may apply (e.g., GDPR for the EU/UK, CCPA for California, LGPD for Brazil, DPDP for India, etc.), which we will set out in separate sections.

1. Who We Are

• Company: Adsspark Limited
• Headquarters: Hong Kong
• What We Do: We provide performance-based digital marketing services, including sweepstakes campaigns, pay-per-call advertising, lead generation, and affiliate marketing.
• Contact: You can reach us at contact@adsspark.co

2. Information We Collect

We collect different categories of information to provide our services, maintain compliance, and improve our website.

a) Information You Provide Directly

• Identity Data: Your name, job title, and organization name.
• Contact Data: Email address, phone number, business address.
• Account Information: Login details if you create an account on our platform.
• Business Information: Details you share when inquiring about partnerships, advertising campaigns, or affiliate programs.
• Payment Information: Billing address, bank details, or PayPal/Payoneer details (for payouts or invoices).

b) Information We Collect Automatically

When you visit our Site, we automatically collect:

• Technical Data: IP address, device identifiers, browser type, operating system, and network provider.
• Usage Data: Pages visited, time spent on the Site, referral URLs, clicks, and navigation patterns.
• Tracking Data: Cookies, web beacons, tracking pixels, and similar technologies. (See our Cookie Policy for more details.)

c) Information from Third Parties

We may receive information from:

• Business partners: Advertisers or affiliates who share data with us in accordance with law.
• Service providers: Payment processors, analytics platforms, fraud-detection vendors.
• Public sources: Open databases, social media profiles, or publicly available websites.

d) Sensitive Personal Data

We do not intentionally collect sensitive personal data (e.g., race, religion, political views, health data). If such data is ever processed (e.g., in a legal dispute), it will be handled in strict accordance with applicable laws.

3. How We Use Your Information

We use your personal information for legitimate business purposes, including:

Service Delivery

• Operating our website and digital marketing platform.
• Managing affiliate and advertiser relationships.
• Processing payments and commissions.

Communication

• Responding to inquiries, support requests, or partnership discussions.
• Sending important updates about policies, terms, or services.
• Marketing communications (with your consent where required).

Business Operations

• Analyzing performance metrics and campaign effectiveness.
• Detecting and preventing fraud, spam, or misuse of our platform.
• Internal training, audits, and compliance reporting.

Legal Compliance

• Meeting obligations under Hong Kong law (PDPO), contracts, tax regulations, and international laws (e.g., GDPR, CCPA, DPDP).
• Responding to lawful requests from regulators or law enforcement.

4. Legal Bases for Processing

Our processing of personal data is based on:

• Consent – When you opt in to marketing, cookies, or voluntarily share your data.
• Contractual Necessity – When we process data to deliver services or fulfill agreements (e.g., affiliate payouts).
• Legitimate Interests – For fraud prevention, analytics, service improvement, and business efficiency, provided these interests are not overridden by your rights.
• Legal Obligations – When we must retain or share data to comply with laws or respond to lawful authorities.

5. Sharing & Disclosure of Information

We may share personal data with:

• Internal Teams: Employees and contractors with a need-to-know basis.
• Service Providers: Hosting providers, payment processors, analytics platforms, fraud-monitoring vendors, IT support.
• Business Partners: Advertisers, affiliates, or agencies involved in campaign delivery (only in compliance with privacy laws).
• Legal/Regulatory Authorities: When required by law or in response to subpoenas, court orders, or investigations.
• Corporate Transactions: If Adsspark is merged, acquired, or undergoes restructuring, your data may be transferred as part of the transaction.

We do not sell your personal data to third parties.

6. International Data Transfers

Because Adsspark operates globally, your personal data may be transferred across borders (e.g., from Hong Kong to the US, EU, or India).

• We use contractual safeguards (e.g., Standard Contractual Clauses for GDPR countries) to ensure equivalent protection.
• Transfers are limited to partners or vendors who meet adequate data protection standards.

7. Data Retention

• We retain personal data only for as long as it is necessary for the purposes outlined in this Privacy Policy.
• The retention period may vary:
  • Business data: Retained for the duration of the business relationship plus any legal retention period (e.g., accounting/tax).
  • Marketing data: Retained until you withdraw consent.
  • Cookies/logs: Retention periods vary (see Cookie Policy).
• Once data is no longer required, we will securely delete, anonymize, or aggregate it.

8. Data Security

We take security seriously and apply industry-standard measures to protect personal information, including:

• Encryption of sensitive data during transmission and storage.
• Access controls and role-based permissions for employees.
• Firewalls, intrusion detection, and malware scanning.
• Regular security audits and vendor assessments.
• Employee confidentiality agreements and training.

However, no system is completely secure. We cannot guarantee absolute security but commit to notifying affected parties if a breach occurs, as required by law.

9. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

• Access: Obtain a copy of your personal data we hold.
• Correction: Rectify inaccurate or incomplete information.
• Deletion: Request erasure of your personal data (“right to be forgotten”).
• Restriction: Limit how we process your data.
• Portability: Receive data in a machine-readable format and transfer it to another provider.
• Objection: Object to certain processing (e.g., direct marketing).
• Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.

Specific details for GDPR, CCPA/CPRA, DPDP, LGPD, PIPEDA, Singapore PDPA, and Australia APPs will be provided in supplements.

10. Children’s Privacy

• Our Site and services are intended for business professionals and not directed to children.
• We do not knowingly collect personal data from anyone under 16 years of age (or the minimum legal age in their jurisdiction).
• If we become aware of such collection, we will delete the data promptly.

11. Third-Party Websites & Services

• Our Site may link to third-party websites or services (e.g., advertiser landing pages, affiliate platforms).
• We are not responsible for their privacy practices, and this policy does not apply to them.
• We recommend reviewing the privacy policies of all third-party sites you visit.

12. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be posted on this page with a revised Effective Date.

• If changes are material (e.g., new data uses), we will provide prominent notice (e.g., website banner, email).
• Continued use of our Site or services after changes means you accept the updated policy.

13. Contact Us

If you have any questions or requests regarding this Privacy Policy, or if you wish to exercise your privacy rights, please contact us at: contact@adsspark.co

Adsspark Limited, Hong Kong