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Privacy Policy

Privacy Policy of Adextra Media Limited

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Written by Mary
Updated this week

Adextra Media Limited ("Adextra", "we", "us" or "our") is committed to protecting and respecting your privacy and handling your personal data in an open and transparent manner. The personal data that we collect and process may vary depending on the service we provide to you.

This privacy policy:

  • Provides an overview of how Adextra collects and processes your personal data and informs you about your rights under the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO").

  • Contains important information about, among others, the collection and use of personal data, the legal grounds for processing, disclosures to third parties, and the use of cookies on the Website.

For the purposes of this privacy policy:

  • When we refer to "personal data," we mean data which identifies or may identify you, including your name, address, telephone number, date of birth, occupation.

  • When we refer to "processing," we mean the handling of your personal data by us, including collecting, protecting, and storing your personal data.
    When we refer to our "Website" or "Platform," we mean https://www.adextra.io/ and https://partner.adextra.io/ .

1. Who we are

Adextra Media Limited is a company registered in Hong Kong, with its registered office at 7/F, MW Tower, 111 Bonham Strand, Sheung Wan

This Privacy Policy applies to Adextra Media Limited and the services we provide through our Website and Platform.

2. Our Data Protection Principles

We adhere to the principles set out in the PDPO, ensuring that personal data is:

  • Processed lawfully and fairly.

  • Collected only for purposes directly related to our functions or activities.

  • Adequate, relevant, and not excessive.

  • Accurate and kept up to date.

  • Not kept longer than necessary.

  • Secure and protected.

  • Accessible by data subjects, with data subjects able to exercise their rights.

3. Data Controller

3.1 This privacy policy applies where we are acting as a data user (similar to a data controller) with respect to your personal data.

3.2 We will ask you to consent to our use of cookies when you first visit our Website, in accordance with this policy.

4. How We Collect Your Personal Data

4.1 We collect personal data directly from you when:

  • You register on our Platform.

  • You use our Website and services.

  • You contact us for enquiries, complaints, or other reasons.

4.2 We also collect data from other sources, including:

  • Third parties such as partners, contractors, and/or vendors.

  • Tags or tracking scripts on websites you manage or control.

5. Personal Data We Use, Purposes and Legal Grounds

We may collect and process the following data:

Type of Information

Purpose

Data about your use of our Website (e.g., IP address, browser details).

To analyse and improve our services.

Profile data (name, address, email, phone, etc.).

To operate our Platform, communicate, and perform relevant checks.

Publication data (posts, content).

For publication and administration of our Platform.

Inquiry data.

For compliance and payment obligations.

Transaction data (payment details, payment IDs, etc.).

For payments and transaction record-keeping.

Notification data (notifications, newsletters).

To send relevant updates.

Correspondence data (communications metadata).

For proper administration and support.

Any personal data listed above.

To exercise or defend legal claims, manage risks, and obtain professional advice.

6. Disclosures to Third Parties

We may disclose your data to:

  • Group companies for legitimate business purposes.

  • Insurers and professional advisers for risk management and legal claims.

  • Payment service providers to process payments and resolve related issues.

  • Governmental and regulatory bodies in response to investigations or legal obligations.

  • Partners, contractors, and/or vendors to evaluate our contract performance and improve our services (e.g., review platforms).

We require all third parties to implement appropriate security measures.

7. Your Data Protection Rights

You have the following rights under the PDPO:

  • Right to be informed about how your data is processed.

  • Right to access a copy of your personal data.

  • Right to correction of inaccurate or incomplete data.

  • Right to erasure in certain circumstances.
    Right to withdraw consent where processing is based on your consent.

  • Right to complain to the Hong Kong Privacy Commissioner for Personal Data (https://www.pcpd.org.hk/).
    To exercise your rights, contact us at: [email protected].

8. International Transfers

Where personal data is transferred outside Hong Kong, we will ensure appropriate safeguards are in place to protect your data.

9. Retaining and Deleting Personal Data

We retain personal data as long as needed for the purposes for which it was collected, or to comply with legal obligations, after which it will be anonymised or securely deleted.

10. Collection and Processing of End Users’ Data

10.1 We may collect data from your interaction with our advertising services, including IP address, referral URLs, browser and device details.

10.2 We use this data to display relevant ads and to detect fraud.

10.3 We process such data only when lawfully authorized and with appropriate notification by our partners.

11. Confidentiality and Security

We implement security measures to protect your data, including:

  • Access restrictions based on need-to-know.

  • Secure data transfers and storage.

  • Firewalls and intrusion detection.

  • Continuous security monitoring.
    If you have a password for our Website, please keep it confidential.

12. Cookies

Cookies are small text files that are placed on your computer by websites that you visit. Websites use cookies to help users navigate efficiently and perform certain functions. Cookies that are required for the website to operate properly are allowed to be set without your permission. All other cookies need to be approved before they can be set in the browser.

  • Strictly necessary cookies. Strictly necessary cookies allow core website functionality such as user login and account management. The website cannot be used properly without strictly necessary cookies.

  • Targeting cookies. Targeting cookies are used to identify visitors between different websites, eg. content partners, banner networks. Those cookies may be used by companies to build a profile of visitor interests or show relevant ads on other websites.

  • Functionality cookies. Functionality cookies are used to remember visitor information on the website, eg. language, timezone, enhanced content.

  • Performance cookies. Performance cookies are used to see how visitors use the website, eg. analytics cookies. Those cookies cannot be used to directly identify a certain visitor.

You can change your consent to cookie usage below.

13. Changes to This Privacy Policy

We may update this policy from time to time. This may occur without prior notice. The revision date will be updated accordingly.

14. Contact

For questions about this privacy policy or to exercise your rights, contact us at:

Name: Adextra Media Limited

Address: 7/F, MW Tower, 111 Bonham Strand, Sheung Wan, Hong Kong

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