Privacy Policy

Updated: May 2025

Effective Date: May 2025

Welcome to use the Turing Ads Points Wall SDK service (hereinafter referred to as “the Service”) provided by TURING MOBI (HK) TECHNOLOGY CO., LIMITED (hereinafter referred to as “we,” “us,” or “Turing Ads”). We highly value the privacy and personal information protection of our users (hereinafter referred to as “you”). This Privacy Policy explains how we collect, use, store, and share your information, as well as your rights.

Please read and understand this Privacy Policy carefully before using the Service.

I. Global Applicability Statement

The Service is available to users worldwide, especially including Southeast Asia. The collection, storage, and use of your personal information shall comply with the applicable laws and regulations of your location, including but not limited to personal data protection laws of Southeast Asian countries (such as Singapore PDPA, Malaysia PDPA, Indonesia PDP Act, etc.), EU GDPR, US CCPA, China PIPL, and other relevant laws. We particularly respect and comply with Indonesia’s Personal Data Protection Law (PDP Law, effective 2022) to ensure the lawful collection, storage, and processing of user data. We commit to taking reasonable technical and managerial measures to protect your personal information from unauthorized access, disclosure, or alteration.

II. Information We Collect

To achieve product functionality and improve service quality, we may collect the following information:

1. Device Information: including device model, operating system type and version, unique device identifiers (e.g., IMEI, Android ID, IDFA), resolution, device manufacturer, network type, etc.

2. Application Information: including the name, version number, package name, etc. of the host APP integrating this SDK.

3. Log Information: including timestamps of your use of this SDK, click behaviors, task completion status, ad viewing status, points acquisition records, lottery participation, and prize redemption information.

4. Location Information: to improve ad targeting accuracy, we may obtain your IP address and make rough geographical location judgments based on the IP.

5. Redemption Information: when you apply to redeem virtual or physical goods, we collect necessary information you provide, including but not limited to your name, delivery address, contact phone number, email, etc., to complete redemption and delivery services.

III. How We Use Information

We use your information for the following purposes:

1. Provide the core points wall advertising service, including task distribution, points acquisition and display, lottery, and redemption;

2. Analyze user behavior data to optimize product features and interaction design;

3. Conduct anti-cheating checks to ensure platform security and protect advertisers’ rights;

4. Perform statistics and settlement with upstream advertising platforms or advertisers;

5. Use your provided relevant information for order processing, logistics delivery, after-sales service, and necessary identity verification when you redeem virtual or physical goods;

6. Use such information strictly within the necessary scope to fulfill redemption and after-sales services, adhering to privacy protection principles and ensuring information security;

7. Comply with applicable laws, regulations, and supervisory requirements.

IV. Information Sharing and Third-Party Access

To complete ad task display and incentive reward settlement, we may share necessary information with the following types of third parties:

1. Upstream advertising platforms (such as Google AdMob, Unity Ads, Vungle, Applovin, TopOn, etc.) for ad display, incentive callbacks, and settlement;

2. Attribution platforms (such as Adjust) for attribution analysis and traffic quality assessment;

3. Host applications for account authorization, points synchronization, and reward distribution;

4. Compliance and regulatory agencies as required by laws, regulations, supervisory demands, or court rulings.

We promise not to sell or illegally transfer your information to any third party.

V. Information Storage and Security

1. Storage Methods: We process user information through encryption, de-identification, and other means, and store it in legally compliant data centers located domestically and/or overseas.

2. Retention Period: Information is retained only for the period necessary to achieve the service purposes; after expiry, we will actively delete or anonymize it.

3. Cross-border Data Transfer: To ensure normal operation of the Service, your personal information may be transmitted and stored on servers within or outside China. We commit to adopting corresponding security measures in data transmission and storage, complying with applicable laws and regulations.

4. Security Protection: We have implemented various security measures (such as HTTPS transmission, access control, permission verification) to protect your information security.

VI. Your Rights

1. Access and Correction: You may access or modify some of the authorized information through the host APP;

2. Deletion and Account Cancellation: If you wish to stop using the Service and delete related data, you may contact the host APP or reach out to us via feedback channels for processing;

3. Refusal or Withdrawal of Authorization: You may disable permission authorization in device settings, but this may affect the normal use of some functions.

VII. Security Measures for User-Provided Information

1. We adopt multiple technical and managerial security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction, including but not limited to data encryption, access control, and security audits;

2. Only necessary internal staff are authorized to access your information and are subject to strict confidentiality obligations;

3. We regularly evaluate and improve security measures to ensure your information is always effectively protected.

VIII. Handling of Incorrect or Changed User Information

1. If you find that your personal information stored by us is incorrect, you have the right to submit a correction request through official contact methods (such as the email support@turings.mobi);

2. Upon receiving the request, we will verify it promptly and make corrections or updates within a reasonable timeframe;

3. If you need to delete or withdraw personal information, you may also apply according to the “Your Rights” section of this Privacy Policy, and we will handle it in accordance with laws and regulations;

4. To ensure transaction and service security, some information changes may require additional verification or confirmation.

IX. Child Protection

This Service is not provided to children under the age of 14. If it is found that a child has provided personal information without guardian consent, guardians should promptly contact us to delete such information.

X. Policy Updates

We may update this Privacy Policy from time to time. When major changes occur, we will notify you prominently within the host APP. Continued use of the Service shall be deemed acceptance of the updated policy.

XI. Contact Us

If you have any questions, comments, or complaints about this Policy, please contact us as follows:

Company Name: TURING MOBI (HK) TECHNOLOGY CO., LIMITED

Email: support@turings.mobi

Please be advised that this policy takes effect from the date you first use the Service.