Mobile Marketing Agency

Last updated on January, 2020.

This Privacy Policy is effective January 1, 2020 for all users.


We are committed to respecting and protecting each individual’s privacy rights. This Privacy Policy explains how Click Tech Limited, its subsidiaries and affiliated companies (collectively, “we”, “us”, “our”) collect, use, disclose or share end user (“you” or “your”) information through our advertising platform (“Advertising Service”), our website at (“Website”), our mobile applications (“App”), and any of our products and/or services (collectively, the “Services”), and whether you access the Services directly or through a third party. 


Please understand that, except as specifically described below, this Privacy Policy does not apply to information collected by third parties, such as other companies, or third-party websites or mobile applications, even if any are linked to or accessible through the Services.


We collect information from users when users (i) visit our Website; (ii) view ads served by our Advertising Service; (iii) interact with our Advertising Service; or (iv) interact with the platforms, applications, websites or any other products and/or services provided by our business partners (e.g. app publisher, advertiser).


When you use the Services, you consent to our collection, use, and disclosure of information about you as described in this Privacy Policy. Please review this Privacy Policy before using our Services or visiting our Website. We may amend this Privacy Policy from time to time. The amended Privacy Policy will be displayed on our Website. Please check our Privacy Policy regularly to ensure you have read the latest version. Continued use of the Services after the effective date will be your acknowledgement that have accepted the revised Privacy Policy.


If you have any questions or concerns about our information practices, please contact us at


1.    What Information Is Collected?

We may collect, transmit, and store information about you in connection with your use of the Services, including any information you send to or through the Services. We use that information to provide the Services’ functionality, fulfill your requests, improve the Services’ quality, engage in research and analysis relating to the Services, personalize your experience, track usage of the Services, provide feedback to third party businesses that are listed on the Services, display relevant advertising, market the Services, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Services, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our servers initially and stored long enough to process.

l   We may collect the following information from or about our users when they access our Services:

l   Information which users provide to us, including names, gender, birth dates, personal ID card numbers, addresses, telephone numbers, email addresses, occupations, education, work experience and related information.

l   Passive information collected when users use the Services, such as a user’s browser information (user agent), browser type, IP host address, mobile device type, the Identifier for Advertising (IDFA), Google Advertising ID (GAID), whether user viewed, clicked or otherwise interacted with the advertisement, and other device identifiers, domain name, pages visited, and the length of your user sessions using various technologies and means, such as IP address, cookies, internet tags and navigational data collection.

l   We also use cookies to collect certain information about our users. Cookies collect information on the device and network used to access the domain, and the date and time that users access the domain. This information is for internal use only, such as optimizing performance of the Services. The information cannot identify the individual user.

l   Information from other third party partners of us, such as companies that provide services to us and our business partners.

2.    How Do We Use Your Information?

We use the information, including any personal information, provided by users to provide our Services and for internal business purposes, such as improving our services and assist our customers and partners in improving their products and services; compiling aggregate data for internal and external business purposes; preventing potentially illegal activities; in support of user accounts or customer service requests; in relation with any required governmental or legal action ; and other uses in accordance with our respective Terms and Conditions. 

We may also use the information that we collect about your device to display advertisements on your device, which may include interest-based advertising customized to your interests, preferences, locations, for bidding to serve advertisements and to determine which ads are most effective, to analyze and provide our demand partners or advertisers reports on the effectiveness of advertisements and campaigns, including across different types of devices based on our determination of devices that are related to the same person, and to build custom audience segments to enable our customers and partners better target their advertisements and offers.


3.    How Do We Share Your Information? 

We may share your personal information with our business partners, including publishers, supply partners, demand partners, advertisers, marketing partners, data tracking companies, service providers (which may include IT and related services; fraud detection, information and services; payment processors; customer service providers; and vendors to support the provision of the Services) and with our subsidiaries and affiliates so that we can better provide our Services.


When users are located in the European Economic Area (“EEA”), personal information collected from users, will be transferred to recipients in countries located outside the EEA (including US, Brazil, Singapore), which may not provide a similar or adequate level of protection to that provided by countries in the EEA. We will take reasonable measures to protect user information in accordance with this Privacy Policy. Where required by law, the publisher and/or advertiser will obtain user consent to the transfer of user personal information to recipients, as described in this Privacy Policy, which are located outside the EEA. You may withdraw your consent at any time by contacting us at


Except as otherwise described in our Privacy Policy, we will not disclose personal information to any third party unless we believe that disclosure is necessary: (1) to comply with applicable law or to respond to a subpoena, court order, search warrant, or other legal process received by us , whether or not a response is required by applicable law; (2) to protect or enforce our rights or the rights of a third party; (3) to protect the safety of members of the public and our users; or (4) to respond to an emergency. We reserve the right to transfer personal information to a successor in interest that acquires rights to that information as a result of a sale of us or substantially all of our assets to that successor in interest or of a merger between us and such successor in interest. We also reserve the right to disclose personal information as necessary to enable third-party service providers to support and maintain the operation of our Services, or to disclose personal information to other third parties performing services in connection with the operation of our business.


4.     How Do We Protect the Information?

We use various safeguards to protect the personal information submitted to us, both during transmission and after we receive it. For example, we use appropriate technical and organizational security measures to protect the information we collect. We use multiple electronic, procedural, and physical security measures to protect against unauthorized or unlawful use or alteration of information, and against any accidental loss, destruction, or damage to information. We also have a Data Protection Officer (“DPO”) according to GDPR. The DPO is responsible for monitoring our compliance with GDPR and cooperating with supervisory authority. His contact is


However, no method of transmission over the internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.


5.    How Long Do We Keep the Information For?

We may retain the information relating to a user device collected from partnering mobile publishers or app developers for as long as a user uses the Services and for the purposes as stated in this Privacy Policy, unless otherwise required by law or applicable contract. Notwithstanding the foregoing, we may retain and use such information in a non-identifiable, aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, to resolve disputes and enforce agreements. We will make efforts to guarantee that personal information is kept for no longer than is necessary for the purposes for which the personal information is processed.


6.    User Rights to Their Information

Users have certain rights available to them when it comes to their information.


EU Residents

For residents of the EU, we collect and process information about the users who live in the EEA only on where we have legal bases under applicable EU laws. For EU users, you have the rights to request a copy of their information, to object to our use of their information, to request the deletion or restriction of their information unless subject to a legal hold, or to request their information in a structured, electronic format. Furthermore, they may withdraw their consent to our processing of their information at any time by contacting as, but that will mean we can no longer provide the Services to the user.


California Residents

Under the California Consumer Protection Act of 2018 (“CCPA“), California residents have certain rights around our collection, use, and sharing of their personal information. 


In accordance with CCPA, please see the following summary of personal information that we have collected in the past twelve (12) months, as well as the purposes of collection, and third parties with who we have shared such personal information in the past twelve (12) months.  


Categories   of Personal Information

Purposes   of Collecting Personal Information

Third   Parties with Whom We Share Personal Information

Identifiers   (such as names, gender, birth dates, personal ID card numbers, addresses,   telephone numbers, email addresses, occupations, education, work experience   and related information, Google Advertising ID (GAID))

Provide   the Services

Internal   research, including to maintain and develop the Services

Marketing,   security and detection of unauthorized activities

Service   providers

Subsidiaries   & Affiliates


Commercial   information (such as purchases and transaction history)

Provide the   Services

Internal   research, including to maintain and develop the Services


Security   and detection of unauthorized activities

Service   providers

Subsidiaries   & Affiliates


Internet   and network activity information (or usage data, such as browsing or search   history or interaction with websites)

Provide   the Services

Internal   research, including to maintain and develop the Services


Security   and detection of unauthorized activities

Service   providers

Geolocation   data

Provide   the Services

Internal   research, including to maintain and develop the Services


Service   providers

Inferences   drawn from any personal information collected

Provide   the Services

Internal   research, including to maintain and develop the Services

Service providers

Subsidiaries   & Affiliates



In addition to those purposes described above, we may use or disclose any personal information that we collect as necessary to comply with applicable law or legal obligations as described in this Privacy Policy.


Sale of Personal Information. You may exercise your right to opt out of the sale of your information as defined under the CCPA by clicking on the following link: DO NOT SELL MY DATA, and you can contact to exercise this right.


California Residents’ Rights under the CCPA. Under the CCPA, California residents have certain rights regarding their personal information.  Subject to certain exceptions, California residents have or may exercise the following rights:


Right to Know about Personal Information Collected, Disclosed or Sold. A California resident has the right to be informed about the information practices of a business, and the specific pieces of personal information that a business holds about that resident.


Right to Request Deletion of Personal Information. A California resident may request that a business delete their personal information. 


Right to Opt-Out of the Sale of Personal Information. A California resident has the right to opt-out of the sale of their personal information by a business.


Right to Non-Discrimination for Exercise of Consumer Privacy Rights. A California resident has the right not to receive discriminatory treatment by a business for the exercise of privacy rights provided by the CCPA.


To submit requests to us to exercise these rights, California residents may use the following methods:


l  Contact us through our Website at

l  Contact us by email at


We will not discriminate against you for exercising your rights under the CCPA.  An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.  Please understand that, before responding to your request, we may ask you for additional information in order to verify your identity, or take other actions that we believe are appropriate in order to verify your identity.


Separate from the CCPA, California’s Shine the Light law gives California residents the right to request information regarding the disclosure of your personal information by us to a third party for the third party's direct marketing purposes. To make such a request, you may contact us through our Website at or by email at


7.    Use of Cookies & Other Tracking Technologies

We may use cookies or other similar tracking technology (collectively “Cookies”) to collect certain information about you when you are visiting the Website. Cookies are small text files that are stored automatically on your browser by a website during your visit. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies may contain unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Services, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have interacted with, and the date and time of your use. Cookies may be persistent or stored only during an individual session.


We use Cookies in the Services including the following purposes:





To make   the Services work in the way you expect.

Authentication,   Security, and Compliance

To prevent   fraud, protect your data from unauthorized parties, and comply with legal   requirements.


To   remember information about how you prefer the Services to behave and look.


To allow   or prevent notices of information or options that we think could improve your   use of the Services.


To make   advertising more relevant to users and more valuable to advertisers.


To help   us understand how visitors use the Services.


By using the Website, you consent to the use of the Cookies. If you do not accept these Cookies, you can change your browser’s settings to delete cookies that have already been set and to not accept new Cookies. Please note, however, if you delete Cookies or do not accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly. Please note that changing any of these settings does not prevent the display of certain advertisements to you.


8.    Our Policy Towards Children

We comply with the age-gating requirements under applicable privacy laws such as Children's Online Privacy Protection Act (COPPA), California Consumer Privacy Act (CCPA) in the U.S. and GDPR in EEA and do not knowingly collect personal information or personal data about users of sites or apps directed to children.


If you become aware that a child has provided us with personal information without parental consent, please contact us at If we become aware that a child has provided us with personal information without parental consent, we take immediate steps to remove such information and terminate such account.


9.    Right to Opt Out of Devices

We respects your privacy as a user, and you can opt-out from receiving interest-based advertising from us on supported devices:

You can opt out of having your Mobile IDs used for certain types of interest-based mobile advertising (also called “cross-app advertising”), including those performed by us, by accessing the settings on your Apple or Android mobile device, as follows:

Apple Devices: If you have an Apple device, you can opt out of most cross-app advertising by updating to iOS 6.0 or higher and enabling “Limit Ad Tracking.”
iOS 7 and Higher: Go to Settings → Privacy → Advertising, and toggle “Limit Ad Tracking” to ‘ON.’
iOS 6: Go to Settings → General → About → Advertising, and toggle “Limit Ad Tracking” to ‘ON.’
More information about the iOS setting can be found here:

Android Devices: If you have an Android device, you can opt out of most cross-app advertising by going to Google Settings → Ads, and selecting the option to opt out of interest-based ads.
When you have opted out using this setting on a device, we will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests.

These platforms control how these settings work, so the above instructions may change, and the precise language may be different on certain (particularly, on older) devices. Likewise, if your device uses other platforms not described above, please check the settings for those devices.  Please note that while opting out limits our collection of information to serve you ads based on your inferred interests, it does not prevent you from receiving ads from us, Facebook, Google, or third parties.”

10.  Send “Do Not Track” Signals

Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites a user visits indicating user does not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Services do not currently respond to browser DNT signals.


11.  Third Party Websites

In the event that we provide links to other websites that we do not control, whether or not those other websites refer to our branding, this Privacy Policy does not apply to those other websites. Visitors to those websites are advised to carefully read the policies on those individual websites. Furthermore, the following partners may receive data from users and their interactions with our Services: Unity Technologies (Privacy Policy located at: .However, our agreements with these service providers limit the types of information these companies collect, how they may collect it, and how they may use it.


12.  Contact us

If you have any question or comment about this Policy, please contact our Data Protection Officer at



If you are interested in learning more,we are glad to hear from you.

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