Privacy Policy

At EternityX Marketing Technology Limited we are committed to your privacy. To better protect privacy of the information we obtain, we provide this notice explaining our data practices and how information is collected, used and protected. All data we have access to will be collected, processed and protected according to applicable data protection laws, such as the PDPA (Personal Data Protection Act) in Singapore, the GDPR (General Data Protection Regulation) in Europe, or the CCPA (California Consumer Privacy Act) from January 1st 2020 in California. We may change this privacy policy from time to time, in order to conform with evolving laws and regulations or due to changes in our business and technology. You should consult this page from time to time in order to be aware of any updates.

If you reside in the People’s Republic of China, please refer to our Privacy Policy for China (in Chinese).

Who we are

When we say “EternityX”, “us”, “our” or “we”, this is who we are referring to EternityX Marketing Technology Limited and its subsidiaries. In accordance with regulations applicable to the processing of personal data, EternityX is the “data controller”.

“Data controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by relevant law of the Hong Kong Special Administrative Region of the People’s Republic of China.

Our office address is “16/F, CentreHollywood, 151 Hollywood Road, Hong Kong.”

For any data privacy or data protection related issues, we can be contacted at dataprivacy@eternityx.com.

The data we collect

The data we collect about you depends on the services that you use and how you use them, and it also depends on your relationship with us: if you are a user, a business partner, a prospect etc.

We will deploy indiscriminate and anonymous means of statistics, including “cookie” and “pixel tag”, to collect and store the data.

“Cookie” is a small text file, including a single or a string of word character(s), and is used as an anonymous mark to distinguish a unique web browser. Cookie can only be read or changed by the website operator(s) or service providers who deploy(s) it. Most of the browsers allow cookies as default, but you can change your browsers setting, and make your browsers reject any third-party cookies, or accept cookies only if you agree. Please click on the “help” button in your browsers to know more about the cookies setting of your browsers.

“Pixel Tag” is a string of code that is displayed as a 1x1pixel graph on the webpage. Pixel Tag allows service providers or third-party operator to read and change the cookies and transfer other data, including which webpage that the user is currently browsing, about the computer that is used to view the webpage, user’s operation system, browser type and other data such as IP address and time.

Other than for business contacts data as provided below, we do collect any information such as email, address, phone number, credit card information etc. The data we hold about you is not data which allows us to know you. We do not process any data in such a way that it could be used, including through a third party, to establish the identity of a user, unless you voluntarily provide those data to us. If you voluntarily share with us your personal data, we will also collect contact information including but not limited to personal name, company name, telephone or mobile number and email address, in order to contact you.

End-user data

We are a company operating in the field of marketing and advertising technology. We provide advertising and analytics services for the benefit of our business customers, giving them the ability to reach users who are most likely to be interested in the products and services of the clients we work for. We collect data from millions of users and use the data collected and processed to inform audience targeting and generation of insights about consumers.

For Europe-based users:

We do not target users in the EU/EEA and it is not our intention to process the personal data of users located there. In order for us to process your data, you will normally have consented and accepted to data processing and accepting cookies or similar technologies from one of the publishers that we collect data from. So, it is possible that when visiting Chinese language websites you may have consented to data processing or accepted cookies which might lead to us processing your data even if you are located outside of China. On the other hand, we will target Chinese travelers when visiting Europe with advertising campaigns ran on behalf of our clients. You can change your preferences at any time and you can also exercise your rights by writing to dataprivacy@eternityx.com.

We rely upon consent as a legal basis for most data we process. Still we believe we have a legitimate interest to collect and process personal data for the following purposes:

• Understanding whether users have made purchases after having seen ads.
• Counting the number of times users who have seen ads have proceeded to buy a product or service to understand the overall return on investment of that ad.
• Understanding browsing behaviors of aggregated users.
• Ensuring ads are not shown to the same users more than a certain number of times.
• Counting the number of times ads have been seen.
• Counting the number of times ads seen have been clicked on to understand which creative formats generate interest and engagement.
• Understanding if ads are seen by users to optimize advertising investment.
• Checking for fraudulent behavior.

Business contacts data

If you are a business contact, a business partner, a client, an agency, a publisher, a data provider, a prospect etc., we may hold some personal data about you. We will need that data in order to communicate, invoice, manage contracts and products and services we offer to you. That data we have collected may take many forms, ie name, email address, billing address, office address, phone numbers, title, employer etc. We would only hold this information because you have shared that information with us; it may be because you are a client (and we had to invoice you, offer our services to you etc.) or you may be a prospect and we would have obtained that information from exchanging emails or business cards, or during meetings or events etc.

For European users:

Under the current law, we would not have to obtain consent in order to keep that data as we require this data in order to manage our contract with your organization, or the data processing is necessary for our legitimate interests in marketing our services or evaluating new services and supplies. You can exercise your data subjects’ rights of that personal data and contact us at dataprivacy@eternityx.com.

Our retention policy for this data is as follows, i.e. we will delete your data:

• Three years after the last contact.
• Five years after the end of the contractual relationship.

How do we use the data

We will process the above data and analyze your preference and interest, and display the advertisements that match your interest the most. We will also contact you, answer your inquiry, share with you the latest news of EternityX through email or other communication means, according to the contact information that you may have voluntarily provided.

We collect data in order to run our ad platform, run managed service campaigns on behalf of our clients, or generate insights and analytics. We will use the collected data to make decisions or buy, track, or report on ads served via ad exchanges. We may also share performance data with advertisers or/and their agencies. During this process, we may overlay third-party data collected from third-party data providers to enhance our decision making. Data also helps our clients to serve ads more relevant to users, therefore enhancing the return on investment and making ads more meaningful. In compliance with the best industry standards, we also use IP addresses for purposes such as fraud detection to help alert us to situations which could not have been caused by human behavior, such as a massive amount of clicking in a limited period of time.

We do not process any information or combine with information obtained through third parties in order to determine the identity of users. We will also contact you, answer your inquiry, share with you the latest news of EternityX through email or other communication means, according to the contact information that you may have voluntarily provided.

Confidentiality

We collect information in order to provide services to our clients. We will treat all information collected as confidential. Clients’ limited license to us includes but is not limited to the right to collect all information of users visiting our clients’ websites, either directly or through other means, such as the use of redirects and 1-by-1 pixels. We will not disclose any information collected from a client to any third party unless such disclosure is (i) approved by client, who in turn has obtained the approval of their users, or, where this is permitted by applicable laws, who has not opted out of the right to distribute their information, or (ii) is made by us in response to an order by a competent court of law, and provided that we have given client reasonable notice of such order, and an opportunity to object, or (iii) supported by a Non-Disclosure Agreement which enable us to co-operate with third party for data analytics purpose. We may improve and promote its service offerings, aggregate the information collected from clients with other data so that it is non-personally identifiable with respect to both clients and users to clients’ website(s).

For European users:

We provide data to other companies in our corporate group and technical service providers based outside the EU/EEA that require access to data in order to assist us in providing our services. In particular, we work with reputable external organizations (such as ad exchanges, measurement and verification services), to which we provide certain data which may include personal data, in order to provide our technology platform and services, on the basis of detailed written agreements requiring among other things compliance with applicable laws and security standards.

If any governmental body, law enforcement agency, or regulatory authority requested data from us, then we would normally comply with such request without having to notify you or other users.

Data sharing

We will NOT rent, sell or transfer your data to any third party without your active consent. Only trusted third-party can process the data with precautions and limitations under our close monitoring.

For European users:

It is not our intention to collect personal data relating to EU/EEA users. If our services required a data transfer from the EU/EEA to our systems located elsewhere, then this would only be undertaken in accordance with applicable laws and using appropriate safeguards.

Opt-out of cookies (for European users)

If you no longer wish to receive ads served by us, you can manage your choices by using: Youronlinechoices.

Important: when you choose to opt out from receiving cookies, a cookie will still be set in your browser. This is only by maintaining a cookie in your browser that we will be able to recognize you have made the choice of opting out of cookies.

Web: You can configure your web browser to remove cookies by following the directions provided in your browser’s “help” section.

Mobile: You can opt out from receiving targeted advertising based on data collected via applications on mobile devices by following the instructions from the device maker, e.g. (at the time this notice was published):

• Android: Open the Google Settings app > Ads
• iOS 7 or higher: Choose Settings > Privacy > Advertising
• iOS 6: Choose Settings > General > About > Advertising

Data subjects’ rights (for European users)

Applicable data processing laws grant users various rights including in the EU/EEA:

• The right to be informed
• The right of access
• The right of rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• The right not to be subject to automated decision-making

If you are an EU/EEA user and want to exercise your rights, you can contact us at dataprivacy@eternityx.com.

Where we process any data based on your consent, then you are always allowed to withdraw that consent at any time by contacting us (though the processing that took place before withdrawal will still be legal).

We are committed to resolving with you any issues or doubts you may have in relation to processing of your data. If you believe that your rights have not been respected at any time, then you may also have a right to complain to the Supervisory Authority in your country (also known as Data Protection Authorities) to ask them for a resolution.

Changes of policy

From time to time, we may update the Privacy Policy published on our web. These changes may help us to protect and process users’ data better. We will publish the latest date of update on the top of the Privacy Policy page.

Safety

We will make our best effort to ensure the safety of the data stored in our local and remote server, and avoid any unauthorized access or usage, by means of passcode, firewall, data encryption and more. We will regularly assess our strategy to identify any possible threat and improve our services.

We do not process any sensitive or special categories of data such as racial, religious data etc.

For European users:

Under the GDPR, special categories of personal data is any personal data revealing racial or ethnic origin, political opinions, religious and philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation. We do not process any special categories of personal data.

Updated at: 15th March 2022