Privacy Policy

Blue X is an IAB Transparency & Consent Framework 2.2 member. Blue X is No. 1487 on the TCF Vendor List.

As the provider of Blue X advertising products/services, Domob Ruida Limited and its affiliates (hereinafter referred to as "we") place high importance on the protection of personal information. Blue X Advertising provides developers with advertising placement and performance optimization services. The Blue X advertising products and/or services referred to in this Privacy Policy are collectively termed "the Service" below. When end users (hereinafter referred to as "you") use websites or application software (including apps, web pages, etc., hereinafter referred to as "Developer Applications") developed and/or operated by developers that have integrated Our Services, we will provide relevant functions and services to you through such Developer Applications. We fully understand the importance of processing your personal information in accordance with this Privacy Policy and applicable laws and regulations, and protecting the security of your personal information and privacy.

Special Notice:

1. This Privacy Policy does not replace the privacy policy of the Developer Application. The developer shall disclose its privacy policy to you regarding the collection and processing of personal information within its application, explaining how it collects, processes, and protects your personal information. If you wish to exercise your rights as a data subject, please contact the relevant developer.

2. The Services you use through a developer application are configured by the developer according to their application's requirements and may vary depending on the version of the developer application you use. If certain features or services are not included in the version of the developer application you use, the provisions of this Privacy Policy concerning such features, services, and the processing of related personal information shall not apply.

3. Developers must carefully review this Privacy Policy before integrating Blue X Ads, paying particular attention to bolded terms. Developers should confirm full understanding of this Privacy Policy and make appropriate choices in accordance with it. Developers must also inform you about the integration of Blue X Ads into their application, including the Blue X Ads name, the entity name, the types and purposes of personal information processing, and a link to this Privacy Policy, to enable you to understand the relevant content and provide your consent. By accepting or using services provided by Blue X Ads, you acknowledge that you have fully understood and agreed to this policy. Unless otherwise stated, if a developer or you disagree with this Privacy Policy or its updates, the developer or you must immediately cease integrating and/or using this service.

4. Data Protection and Ensuring Trust with Business Partners and You are core principles of Blue X's business. Therefore, compliance with applicable data protection regulations is a critical task for us. This Policy has been updated to meet the requirements of applicable data protection laws, including but not limited to the European Union's General Data Protection Regulation ("GDPR"), the United States' Children's Online Privacy Protection Act ("COPPA"), the California Consumer Privacy Act ("CCPA"), Brazil's General Data Protection Law ("LGPD"), the Virginia Consumer Data Protection Act ("VCDPA"), and laws and regulations related to personal information protection in the Mainland Region of the People's Republic of China.

Information We May Collect About You

When you view advertisements delivered by Blue X services or use services provided by Blue X's business partners, we and/or our business partners may collect information about you.

(1) When we collect information, the types of information we may collect include:

① Location Information: IP address;

② Device/Advertising IDs:IDFA, IDFV, GAID, App set ID, Amazon ID. Note: If you restrict your device or application software from accessing your device/advertising IDs in accordance with Section 7 of this Policy, we will not collect such information;

③ Device Information: Device manufacturer, model, operating system details, device type, screen specifications, battery status, volume and font size settings, emulator detection, network connectivity, hardware components, sensor data, Limited Ad Tracking (LAT) status, device boot time, device name summary, storage capacity;

④ Application Information: Blue X partner application package name, application version and features, whether downloaded from the App Store, version;

⑤ Usage Data: When you interact with our promoted ads, we collect information about your engagement with the ad, such as viewing or clicking the ad.

⑥ Other Information: Device event information (e.g., system crashes, system activity), timestamps, the date and time of your request, the referring URL, and user agent.

(2) When you browse or click on an advertisement we promote and subsequently download and use the promoted product (e.g., an application), we collect the following information from the advertiser or the advertiser's designated third-party attribution platform:

① Location Information: IP address;

② Device/Advertising IDs: IDFA, IDFV, GAID, App set ID, Amazon ID

③ Device Information: Device manufacturer, model, operating system, language, type, network details, carrier;

④ App Information: App version;

⑤ Usage Data: The timestamp of the advertising event occurrence;

⑥ Other Information: User agent.

We may also collect the following information from aggregated platforms partnered with advertisers:

① Location Information: IP address;

② Device/Advertising IDs: IDFA, IDFV, GAID, App set ID, Amazon ID

③ Device Information: Device manufacturer, device model, device operating system information, device language, device type, device network information, device carrier;

④ Application information: Application package name;

⑤ Usage data: The timestamp of the advertising event occurrence;

⑥ Other information: User agent.

(3) When providing Blue X services to our business partners, we may collect the following information about the contact person using Blue X on behalf of such partners: name, job title, email address, contact address, as well as the username, password, and IP address used to access the Blue X official website.

Regarding Sensitive Personal Information

Sensitive personal information generally refers to personal information that, if leaked or used unlawfully, could easily lead to infringement of an individual's dignity or harm to their personal or property safety. Its scope may vary according to different applicable laws.

We will not collect your sensitive personal information without your consent. Our business partners will only transmit or authorize us to process your sensitive personal information after fully informing you of the necessity of processing such information and its impact on your personal rights and interests, and obtaining your consent in accordance with the law.

Information Sharing

We may share information we collect or receive with third parties in the following contexts.

· Service Providers. We may transfer information to service providers or other partners who support our business operations, including providing technical infrastructure services, analyzing how our services are used, monitoring the effectiveness of advertisements and services, providing customer service, or facilitating payments. These partners are required to strictly adhere to confidentiality obligations consistent with this Privacy Policy and the agreements we have with them.

· Affiliates. We may share information with our affiliated companies in accordance with the terms of this Privacy Policy.

· Advertising Partners. We share information with our third-party advertising partners, including advertisers, ad networks, exchanges, demand-side platforms, and advertising optimization and monitoring/attribution partners, to deliver advertising services to our customers. These third-party partners may use this information to monitor ad performance, display ads for products and services most likely to interest end users, and analyze traffic and other advertising activities through web analytics to improve ad effectiveness.

Unless otherwise specified in our partner listings, each Blue X advertising partner independently controls your data.

· Regulatory or Legal Requirements. We may disclose information to government regulators as required by law, to assist in investigations, or for tax or accounting purposes. We may also disclose personal information to third parties regarding claims, disputes, or litigation pursuant to legal or court orders.

· Enforcement of Security Terms. We may disclose information if we reasonably believe it is necessary to protect your health, safety, or rights, or the health, safety, or rights of others; to address fraud; or to enforce legal rights, including contractual commitments made to us by third parties.

· Business Transfers. We may disclose personal information in connection with organizational business transactions (such as mergers, acquisitions, joint ventures, financing, or sale of organizational assets), or transfer personal information as a business asset to third parties during such transactions. We may also disclose personal information in the event of bankruptcy, insolvency, or receivership.

Legal Basis for Processing User Personal Information

(1) In accordance with applicable laws, we contractually require our business partners to obtain consent from users or their employees on our behalf for processing activities described in this Privacy Policy. Users or their employees may withdraw consent at any time.

(2) Exceptions to obtaining user consent under laws and regulations include:

① Necessary for entering into or performing a contract with the user;

② Necessary for fulfilling our legal obligations;

③ Necessary to address public health emergencies or protect users' life, health, and property safety in urgent situations;

④ Necessary for public interest activities such as news reporting and public oversight, within reasonable limits;

⑤ Necessary for processing personal information voluntarily disclosed by users or already publicly available within legal boundaries.

(3) If you are located within the European Economic Area (EEA), we may process your personal information based on "legitimate interests" as defined by the GDPR when necessary. Our legitimate interests include: monitoring and preventing fraudulent activities, eliminating technical obstacles to system operation, and ensuring the correct and secure functioning of systems and processes.

Online Privacy Protection for Minors

We protect minors' personal information in accordance with applicable laws and regulations. Unless otherwise required by law, we will only collect, use, store, share, transfer, or publicly disclose minors' personal information when legally permitted, with explicit consent from parents or other guardians, or when necessary to protect the minor. If we discover that we have collected personal information from a minor without verifiable parental consent, we will take steps to delete such information promptly.

If you are the parent or legal guardian of a minor, please contact us via the contact information provided in this Privacy Policy if you have questions regarding the personal information of the minor under your care.

In compliance with applicable legal requirements and regulations, we do not intentionally collect personal information from individuals defined as children. We may collect certain types of information (e.g., IDFA) from applications targeting children, where such collection activities fall under "internal operational support" provisions, excluding the notice and consent requirements under the Children's Online Privacy Protection Act (COPPA).

For users in the United States, we guarantee compliance with COPPA. If our business partners collaborate with us on applications targeting children under 13 years of age, or if they knowingly collect, use, or disclose personal information from children under 13 during our collaboration, they shall obtain verifiable parental or legal guardian consent on our behalf in accordance with COPPA. This enables us to process personal information under this Privacy Policy. Additionally, when using Blue X services, relevant COPPA settings must be configured for the application on the Blue X platform. This ensures Blue X can guarantee compliance with COPPA requirements for processing persistent identifiers collected from users of such applications, including using them for behavioral advertising or user tracking without violating COPPA provisions. Furthermore, we will not collect other personal information (such as precise geolocation data) from applications known to target children under 13.

For users in California, USA, we ensure compliance with the CCPA. We do not sell data or serve targeted ads to consumers under 16 years of age without explicit consent (for minors under 13, we obtain explicit consent from parents or guardians). If a user declines consent, we will not seek it again for 12 months.

If a parent or guardian discovers that their child has provided personal information to us without consent, they should contact us promptly. We will take reasonable steps to ensure such information is deleted from our records.

Data Security and Retention:

We take reasonable measures to ensure the security of information collected through our services. Data collected via our services is retained for no longer than 2 years. If no updates are received for a device within 2 years, information will be automatically purged from our systems. Please note that we may retain information for as long as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

Additional Provisions for EU/UK Individuals

If you are located in the European Union, Switzerland, or the United Kingdom, the following additional provisions apply.

In accordance with the ruling of the Court of Justice of the European Union in Case C-311/18 and similar announcements by the Swiss Federal Data Protection and Information Commissioner, we do not rely on the EU-US or Swiss-US Privacy Shield frameworks as a legal basis for transferring personal data under the General Data Protection Regulation. However, we continue to adhere to these principles and, where appropriate, conduct such transfers in accordance with the EU Standard Contractual Clauses and other safeguards.

Notwithstanding the foregoing, Blue X has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Blue X is committed to processing all personal data received from EU member states, the UK, and Switzerland in accordance with the applicable principles of these frameworks. Blue X is responsible for processing personal data received under the Privacy Shield Frameworks and then transferring it to third parties acting as its agents. For all personal data transfers from the EU, the UK, and Switzerland, Blue X adheres to the Privacy Shield Principles, including those regarding data transfer liability.

For personal data received or transferred under the Privacy Shield Frameworks, Blue X is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain circumstances, Blue X may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under the Privacy Shield Principles, Blue X commits to resolving complaints about our collection or use of your personal information. Individuals in the EU and Switzerland with inquiries or complaints regarding our Privacy Shield policy should first contact Blue X via the email address provided below.

Legal Basis for Processing

In certain circumstances, we process your personal data as necessary to perform a contract with you, such as providing you with services. We may also process your personal data in response to your inquiries about our products and services.

Additionally, we process your personal data where required by law. We may also process your personal data where necessary to protect your interests or those of a third party.

Furthermore, we may process your personal data where necessary for the following purposes: preventing fraud, improving our network and services, and marketing our services to advertisers and publishers. These interests are not overridden by your data protection rights.

Where processing your personal data is necessary and no other legal basis applies, we will generally ensure we have obtained your consent. You have the right to withdraw your consent to the processing of personal data at any time.

For questions regarding data processing, please contact our Data Protection Officer. Visit the "Contact Us" section below for contact details.

Children

We do not knowingly collect personal information from children under the age of 16 through our advertising services or websites.

Your Rights

If you are an individual located in the European Union or the United Kingdom, you may:

Request access to the personal data we hold about you;

Request that we correct or delete your personal data;

Request that we restrict or block the processing of your personal data;

In certain circumstances, receive your personal data stored by us and transmit it to another party without hindrance, including requesting that we provide your personal data directly to another party—this is your right to data portability;

Withdraw your consent, where we have obtained it beforehand, and object to the processing of your personal data.

To exercise these rights, please contact us via the email address provided under "Contact Us" below. This email address also connects to our Data Protection Officer. Please note that in certain circumstances, such as where prohibited by law, we may not be able to allow you to exercise these rights.

Additionally, you have the right to lodge a complaint against us. To file a complaint, please contact the regulatory authority in your country or region.

Additional Provisions for Brazilian Individuals

We have created this notice specifically for Brazilian users. Brazilian users enjoy certain privacy rights under Brazilian law, including the General Personal Data Protection Law (LGPD). Our privacy principles and the privacy controls we provide to all users comply with these laws, and this notice ensures we meet Brazil's specific requirements.

You may exercise the rights to access, delete, correct, and port your information as described in the "Control Your Information" section of our Privacy Policy.

Your country/region only permits us to use your personal information under specific circumstances. These circumstances are referred to as "legal bases" and typically fall under one of the following four legal bases:

Contract. We may use your information because you have entered into an agreement with us.

Legitimate Interests. We or third parties may use your information based on our legitimate interests. For example, we need to use your information to provide and improve our services, including protecting accounts, providing customer support, and helping you find friends and content we believe you'll enjoy. Since most of our services are free, we also use some of your information to try to show you ads we think you'll be interested in. It's important to understand that we prioritize your privacy over our interests. We only rely on legitimate interests when we determine that using your data won't significantly impact your privacy, aligns with your preferences, or we have compelling reasons to do so. For details on our legitimate business grounds for using your information, see here.

Consent. In some cases, we will ask for your consent to use your information for specific purposes. If we do, we ensure you can withdraw consent within our services or through your device's permission settings. Even when consent isn't required, we may request your authorization to access data like contacts or location.

Legal Obligations. We may use your personal information when legally required, such as to comply with valid court orders or take necessary actions to protect our users.

You have the right to object to our use of your information. For many types of data, you can directly delete it if you no longer wish us to process it. For other types of data, we enable you to stop its use by completely disabling the relevant feature.

Accessing and Revising the Privacy Policy

(1) To provide better services, Blue X Advertising and related services may be updated and modified from time to time. We may revise this Privacy Policy as appropriate, and such revisions shall form part of this Privacy Policy. We will not reduce your rights under the currently effective Privacy Policy without your explicit consent.

(2) Upon updating this Privacy Policy, we will publish the revised version on the Privacy Policy notice page and other relevant pages of our website to ensure developers and you can promptly access the latest version. We will notify developers of the updated content, and developers will inform you and obtain your authorization and consent.

Contact Us

If you have any questions, comments, or suggestions regarding personal information protection or the content of this Privacy Policy, you may contact us through the following methods:

a) You may send your inquiry via email to dongguang.jiang@bluefocus.com

We will review your question or suggestion as soon as possible and respond within fifteen business days.

Other

This Privacy Policy applies to Blue X Advertising. It is important to note that this policy does not apply to services provided by other third parties, nor does it apply to products or services we offer that have separate, independently established privacy policies.

Please be aware that Blue X advertising and related services described in this policy may vary depending on factors such as your device model, system version, software application version, and mobile client. The final processing of personal information shall be based on the actual version of Blue X advertising integrated into the developer application you use.