This Privacy Policy sets out how Adcom and its affiliated companies within the Adcom Group (“Adcom”, “we”, “our” or “us”) collect, use, disclose, process and protect any information that you give us when you use our products and services located at website and our suite of applications that we offer on our mobile devices. Should we ask you to provide certain information by which you can be identified when using Adcom products and services, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, as well as full confidence that ultimately, you have control of any personal information that you have provided to us.

In this Privacy Policy, “personal information” means information that can be used to identify an individual, either from that information alone or from that information combined with other information Adcom has access about that individual. Such personal information may include your name, address, telephone number, date of birth and email address.

By using Adcom products and services, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time. We are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, including your local data protection legislation. We are equally committed to ensuring that all our employees and agents uphold these obligations.

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarized in this Privacy Policy, please contact us to address your specific concerns. We will be happy to address them directly.

If you have questions or concerns regarding our Privacy Policy or practices, please contact us.

TYPES OF INFORMATION COLLECTED

In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. If you do not provide your personal information, we may not be able to provide you with our products or services.

We may collect the following types of information (which may or may not be personal information):

• Information you provide to us or upload (including your contact details): we may collect any and all personal information you provide to us, like your name, mobile phone number, email address, delivery address (e.g. your security related information, name, birthday, gender), order, invoicing details, materials or data you may sync through apps (e.g. photos, contact lists), information in relation to creating an account and participating in the platforms, phone numbers you insert into your contacts or to send a message, feedback, and any other information you provide us.
  
  
• Device or SIM-related information: information related to your device. For example, IMEI number, IMSI number, MAC address, Android version, device manufacturer details and model name, network operator.
  
  
• Information specific to you that may be assigned by us: we may collect and use this particular information.
  
  
• Location information (only for specific services/functionalities): various types of information on your location. For example, country code, city code, mobile network code, cell identity, longitude and latitude information, language settings.
  
  
• Log information: information related to your use of certain functions, apps and websites. For example, cookies and other anonymous identifier technologies, IP addresses, temporary message history, standard system logs.
  
  
• Other information: environmental characteristics value (ECV) (i.e. value generated from account ID, phone device ID, connected wi-fi ID and location value).
  
  

We may also collect other types of information which are not linked to an individual and which is anonymous. For example, the device model and system version number of the user’s Adcom mobile phone device may be collected when using a particular service. Such information is collected in order to improve the services we provide to you. The type and amount of information collected will depend on how you use, opt-in or participate in our products and/or services.

HOW THE PERSONAL INFORMATION IS USED

Personal information is collected for providing services and / or products to you, and legal compliance on our part under applicable laws. You hereby consent that we may process and disclose personal information to our affiliated companies (which are in the communications, social media, technology and cloud businesses), Third Party Service Providers (defined below) for the purposes stated in this Privacy Policy.

We may use your personal information for the following purposes: 

• Providing, processing, maintaining, improving and developing our goods and/or services to you, including after-sales and customer support and for services on your device or through our websites.
  
  
• Communicating with you about your device, service or any general queries, such as updates, customer inquiry support, information about our events, notices.
  
  
• Conducting marketing related activities, such as providing marketing and promotional materials and updates. For more information on marketing and promotional activities, please refer to the Direct Marketing section below.
  
  
• Allowing you to post comments in public forums.
  
  
• Conducting promotional activities, such as sweepstakes and Facebook events.
  
  
• Analysing and developing statistical information on use of our products and services to better improve our products and services.
  
  
• Storing and maintaining information about you for our business operations or legal obligations.
  
  

Here are more details on how we use your information (which may include personal information) –

• Setting up your account. Personal information collected when creating an account on our web sites or through our mobile devices is used for creating the personal account and profile page for the user.
  
  
• Processing your purchase orders. Information relating to e-commerce orders may be used for processing the purchase order and related after-sales services, including customer support and re-delivery. In addition, the order number is used to cross check the order with the delivery partner as well as the actual delivery of the parcel. The receipt details, including name, address, phone number and postal code are for delivery purposes. The email address is used to send parcel tracking information to the user. The list of purchased item(s) is used for printing the invoice and allowing users to see what is in the parcel.
  
  
• Allowing you to participate in forums. Personal information in relation to the forum or other Adcom Internet platforms may be used for profile page display, interaction with other users, participating in the forum.
  
  
• Providing cloud and other services. Information (device or SIM card-related information including IMEI number, IMSI number, phone number, device ID, device operating system, MAC Address, device type, system and performance information and location information including mobile country code, mobile network code, location area code and cell identity) is collected for activating  services, e.g. cloud, call log sync, SMS sync, Find Device, for the purposes of user authentication and activation of the services.
  
  
• Diagnosing activation failures: Location related information is used for the purpose of assessing SIM card activation failure (i.e. failure of SMS gateway and network) to identify the network operator of that service, and notify the network operator of that failure.
  
  
• Finding your device: Adcom Find Device feature helps you find and secure your phone if it is lost or stolen. You can locate your phone on a map using location information provided by your phone, wipe your phone, or lock your phone. We may collect your location data directly from your mobile device, or in some situations, from cell towers or Wi-Fi hotspots.
  
  
• Recording location information in photos. You have the ability to record your location information while taking a photo. This information will be visible within your photos folder and the location will be put into the header of your photos. If you do not wish to have your location recording while taking a photo, you may turn this off at any time within the camera settings of the device.
  
  
• Providing location based services. In the course of using services, location information may also be used by us or Third Party Service Providers to serve you the correct version of the service and provide accurate details about that location for the best possible user experience, e.g. weather details, location access (as part of the Android platform). You may turn this off at any time by going into the device settings or discontinue use of that application.
  
  
• Improving user experience. Some opt-in features, such as the User Experience Program, allow Adcom to analyse data about how users use the mobile phone and services, so as to improve the user experience, such as sending crash reports.
  
  
• Allowing you to use security centre. Information collected may be used for security and system up-keeping functionalities in the security centre, such as advertising blocker, virus scan, power saver, blocklist, cleaner, etc. Some of these functionalities are operated by Third Party Service Providers. Information (which is not personal information like virus definition lists) is used for virus scan functions.
  
  
• Providing push service.  account ID and IMEI numbers will also be used to provide the Adcom push service to evaluate advertising performance and send notifications from Adcom about software updates or new product announcements, including information about sales and promotion. You may opt out of this at any time through changing your preferences under “Settings”.
  
  
• Verifying user identity. Adcom uses the ECV value to verify the user identity and ensure there is no log-in by hackers or unauthorized persons.
  
  
• Collecting user feedback. The feedback you choose to provide is valuable in helping Adcom make improvements to our services. In order to follow up on the feedback you have chosen to provide, Adcom may correspond with you using the personal information that you have provided and keep records.
  
  
• Sending notices. From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies.
  
  
• Conducting promotional activities. If you enter into contest, or similar promotion, e.g. via Adcom Facebook page or other social media platforms, we may use the personal information you provide to administer those programmes.
  
  

DIRECT MARKETING

We may use your name, phone number, and email address, account ID and IMEI number to provide marketing materials to you relating to goods and services of Adcom companies and our business partners which offer network, mobile applications and cloud products and services. To provide better user experience, we may recommend above-mentioned products, services and activities based on information about your purchase history, website browsing history, birthday, age, gender, and location. We will only so use your personal data after we have obtained your consent or indication of no objection in accordance with local data protection laws, which may require separate explicit consent. You have the right to opt out of our proposed use of your personal data for direct marketing. If you no longer wish to receive certain types of email communications you may opt-out by following the unsubscribe link located at the bottom of each communication. We will not transfer your personal data to our business partners for use by our business partners in direct marketing.

COOKIES AND OTHER TECHNOLOGIES (ONLY WHEN BROWSING OUR WEBSITE)

• What information is collected and how do we use them? Technologies such as cookies, tags, and scripts are used by Adcom and our Third Party Service Providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
  
  
• Log Files: As true of most websites, we gather certain information and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we gather about you.
  
  
• Advertising: We partner with our Third Party Service Providers to either display advertising on our website or to manage our advertising on other sites. Our Third Party Service Provider may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads.
  
  
• Mobile Analytics: Within some of our mobile applications we use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where crashes occur within the application. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
  
  
• Local Storage – HTML5/Flash: We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content and preferences. Third parties with whom we partner to provide certain features on our Sites or to display advertising based upon your web browsing activity also use HTML5 or Flash cookies to collect and store information. Various browsers may offer their own management tool for removing HTML5 LSOs.
  
  

WHO DO WE SHARE YOUR INFORMATION WITH?

 We do not sell any personal information to third parties.

We may disclose your personal information on occasion to third parties (as described below) in order to provide the products or services that you have requested.

Disclosure may be made to Third Party Service Providers and affiliated companies listed in this section below. In each case described in this section, you can be assured that Adcom will only share your personal information in accordance with your consent. You should know that when Adcom shares your personal information with a Third Party Service Provider under any circumstance described in this section, Adcom will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. Adcom will contractually ensure compliance by any Third Party Service Providers with the privacy standards that apply to them in your home jurisdiction.

SHARING WITH OUR GROUP AND THIRD PARTY SERVICE PROVIDERS

From time to time, in order to conduct business operations smoothly in providing you with the full capabilities of our products and services, we may disclose your personal information from time to time to other Adcom affiliated companies (in communications, social media, technology or cloud businesses), or our third party service providers which are our mailing houses, delivery service providers, telecommunications companies, data centres, data storage facilities, customer service providers, advertising and marketing service providers, agents acting on behalf of Adcom, related corporations, and/or other third parties (together “Third Party Service Providers”). Such Third Party Service Providers would be processing your personal information on Adcom behalf or for one or more of the purposes listed above. We may share your IP address with third parties when using certain mobile applications on our device in order to provide you with some of the services you requested.

SHARING WITH OUR GROUP’S ECOSYSTEM COMPANIES

Adcom works together with a cool group of companies, which together form the Ecosystem. The Ecosystem companies are independent entities, invested and incubated by Adcom, and are experts in their fields. Adcom may disclose your personal data to the Ecosystem companies so as to provide you with and improve the exciting products and services (both hardware and software) from the Ecosystem companies. Some of these products and services will still be under the Adcom brand, while others may use their own brand. The  Ecosystem companies may also share data with Adcom from time to time in relation to products and services under the Adcom brand to provide hardware and software services, and to create better functions and user experience. If Adcom is involved in a merger, acquisition or asset sale of all or a portion of our assets, you will be notified via email and/or a prominent notice on our website, of any changes in ownership, uses of your personal information, and choices you may have regarding your personal information.

SHARING WITH OTHERS

Adcom may disclose your personal information without further consent when required under applicable law.

INFORMATION NOT REQUIRING CONSENT

• We may share anonymised information and statistics in aggregate form with third parties for business purposes, for example with advertisers on our website, we may share them trends about the general use of our services, such as the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.
  
  
• For the avoidance of doubt, Adcom may collect, use or disclose your personal information without your consent if it is and only to the extent it is allowed explicitly under local data protection laws, such as to comply with a subpoena, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  
  

SECURITY SAFEGUARDS

ADCOM’S SECURITY MEASURES

We are committed to ensuring that your personal information is secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect on your mobile device and on Adcom websites. We will use all reasonable efforts to safeguard your personal information.

For example, when you access your account, you can choose to use our two-step verification process for better security. When you send or receive data from your Adcom device to our servers, we make sure they are encrypted using Secure Sockets Layer (“SSL”) and other algorithms.

All your personal information is stored on secure servers that are protected in controlled facilities. We classify your data based on importance and sensitivity, and ensure that your personal information has the highest security level. We make sure that our employees and Third Party Service Providers who access the information to help provide you with our products and services are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. We have special access controls for cloud based data storage as well. All in all, we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorised access and use.

We will take all practicable steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

ACCESS, UPDATING OR CORRECTING YOUR PERSONAL INFORMATION

• You have the right to request access to and/or correction of any other personal information that we hold about you. When you update your personal information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your personal information, we shall proceed to respond to your request within any time frame set out under your applicable data protection laws.
  
  
• We normally provide such services for free but reserve the right to charge a reasonable fee for your data access request.
  
  
• If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete.

DATA DELETION POLICY

You may request deletion of your account by emailing us at info@adcomhitech.com. We will delete all of the content contained in your profile; however, please note that some information may remain in our records after your deletion of such information from your account. We may also keep a copy of any such information for legal archival purposes. We may use any aggregated data derived from or incorporating your personal information after you update or delete it, but not in a manner that would identify you personally.

Data which has been deleted or otherwise destroyed can not be recovered at any time. Sufficient warning is given to the account administrator before data are permanently deleted. We undertake to perform the deletion within one month (30 calendar days) and will send you a confirmation once the information has been deleted. Wherever possible, we will aim to complete the request in advance of the deadline.

MISCELLANEOUS 

ORDER OF PRECEDENCE

If you have agreed to our applicable User Agreements, in the event of inconsistency between such User Agreements and this Privacy Policy, such User Agreements shall prevail.

UPDATES TO THE PRIVACY POLICY

We keep our Privacy Policy under regular review and may update this privacy policy to reflect changes to our information practices. If we make material changes to our Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) or post the changes on all the Adcom websites or through our mobile devices, so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of products and services on the websites, mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal information from you or when we wish to use or disclose your personal information for new purposes.

DO I HAVE TO AGREE TO ANY THIRD PARTY TERMS AND CONDITIONS?

Our Privacy Policy does not apply to products and services offered by a third party. Adcom products and services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

Here are third party terms and privacy policies that apply when you use these specific products:

• By using PayPal or other third party check-out services to finalize and pay for your order, you are agreeing to the third party check-out service provider’s privacy policy will apply to the information you provide on their website.

SOCIAL MEDIA (FEATURES) AND WIDGETS

Our websites include social media features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our websites. Your interactions with these Features are governed by the privacy policy of the company providing it.

CONTACT US

If you have any comments or questions about this Privacy Policy or any questions relating to Adcom collection, use or disclosure of your personal information. Thank you for taking the time to understand our Privacy Policy!