Privacy policy.

Qianhai Aoyun Information Technology (“we,” “us,” or “our”) collects personal information you provide (e.g. identifiers, contact details), information gathered automatically (e.g. cookies, device identifiers), and data from third parties. We use this information to operate and optimize performance-based marketing campaigns, comply with legal obligations, and pursue our legitimate interests. We share data only with trusted service providers, under confidentiality, or as required by law. You have rights to access, correct, delete, and port your data, and to withdraw consent or opt-out of sales. We retain data only as long as necessary and implement appropriate security measures. This policy is governed by EU GDPR, California’s CCPA, the ePrivacy Directive via the IAB Transparency & Consent Framework, and U.S. FTC privacy/security principles.

1. Scope and Definitions

1.1. Controller

Qianhai Aoyun Information Technology Ltd., headquartered at Haifa, IL, is the data controller for all personal data processed under this policy.

1.2. Key Definitions

  • “Personal Data” means any information relating to an identified or identifiable natural person.

  • “Processing” means any operation performed on personal data, such as collection, storage, use, disclosure, or erasure.

2. Information We Collect

2.1. Information You Provide

  • Identifiers & Contact Data: Names, email addresses, phone numbers.

  • Professional & Demographic Data: Company, job title, country.

2.2. Information Collected Automatically

  • Usage & Device Data: IP address, browser type, device identifiers, operating system.

  • Cookies & Tracking: We use cookies and similar technologies to track campaign performance and optimize ad delivery.

2.3. Third-Party Sources

We may receive data (e.g. demographic or interest data) from advertising platforms, analytics providers, or public databases to enrich campaign targeting.

3. How We Use Your Data

3.1. Performance Marketing & Search Arbitrage

We process data to buy, optimize, and measure search arbitrage traffic, determining bid strategies and revenue attribution.

3.2. Social Media Marketing

We use personal data to create, target, and report on ads across social networks.

3.3. Analytics & Optimization

Data is aggregated and analyzed (e.g. RPC, ROI, CTR) to improve campaign efficiency.

3.4. Legal Bases for Processing

Under the GDPR, we rely on:

  • Consent for optional tracking and marketing communications.

  • Contract performance where processing is necessary to deliver services you request.

  • Legitimate interests in optimizing marketing spend, provided your rights are not overridden.

4. Sharing of Data

4.1. Service Providers

We share data with vendors (e.g. ad networks, analytics platforms) bound by confidentiality and limited-use agreements.

4.2. Legal Requirements

We may disclose data to comply with court orders, legal processes, or governmental requests.

4.3. Business Transfers

In the event of a merger or sale, personal data may be transferred as an asset under confidentiality terms.

5. Cookies & Tracking Technologies

5.1. Cookies

We employ first- and third-party cookies to understand user behavior, measure ad performance, and prevent fraud.

5.2. Online Advertising & IAB TCF

Our implementation follows the IAB Europe Transparency & Consent Framework to ensure compliance with the ePrivacy Directive and GDPR.

6. Data Retention

We retain personal data only as long as necessary for processing purposes and legal compliance. Retention criteria include campaign lifecycle, contractual needs, and statutory obligations.

7. Your Rights

7.1. GDPR Data Subject Rights

  • Access, Rectification, Erasure (Articles 15–17).

  • Restriction & Objection (Articles 18–21).

  • Data Portability (Article 20).

  • Withdraw Consent at any time without affecting prior processing.

7.2. CCPA Consumer Rights

California residents may:

  • Know categories of data collected and purposes.

  • Delete personal information held by us or our service providers.

  • Opt-Out of sale of personal information where applicable.

To exercise these rights, contact us as detailed in Section 12.

8. Children’s Privacy

We do not knowingly solicit or process data of children under 16 without verifiable parental consent, in line with GDPR requirements.

9. Security

We implement administrative, technical, and physical safeguards (encryption, access controls) to protect personal data, per FTC privacy‐security guidance Federal Trade Commission.

10. International Transfers

Where data is transferred outside the EEA, we rely on EU Commission adequacy decisions, Standard Contractual Clauses, or other approved safeguards to ensure lawful transfer.

11. Changes to This Policy

We may update this Privacy Policy; material changes will be posted on our website with the revision date.

12. Contact Us

If you have questions, wish to exercise your rights, or submit complaints, please contact:
Data Protection Officer
Qianhai Aoyun Information Technology Ltd.
Email: services@fagamedia.com

Last updated: May 8, 2025.