Privacy Policy
Adtech Solutions Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients, customers, business partners and business contacts and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Adtech Solutions Limited
Company registered in Hong Kong under company number 3172523
Registered address: Unit 1603, 16th Floor, The L. Plaza, 367 – 375 Queen’s Road Central, Sheung Wan, Hong Kong
Email address: _____@adtech
Website: ___________
2. What Does This Notice Cover?
This Privacy Policy explains how we collect, process, and use your personal data through our Platform and in the course of providing our services.
It also covers how we use personal data for analytics and marketing, advertising purposes, including behavioral data used for marketing through third-party advertising and analytics platforms.
Finally, it explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identified or identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. For individuals in Hong Kong, ‘personal data’ also has a meaning given to this term in the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”), which governs the collection, use, and handling of personal data in Hong Kong. Together, these instruments (and any other applicable data protection laws) are referred to in this Policy as the “Data Protection Legislation”.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4. Cookies
A cookie is a small text file placed on your computer or device by our Platform when you visit certain parts of our site and/or when you use certain features of our services.
Our website may place and access certain first-party Cookies on your device. These Cookies are placed directly by us and are used solely by us to enhance and personalize your experience and to provide and improve our website. We ensure that your privacy and personal data are protected and respected at all times.
By using our website, you may also receive certain third-party Cookies. These are Cookies placed by websites or parties other than us. Third-party Cookies are typically used for features like analytics, performance monitoring, or additional functionality. These Cookies are not essential to the functioning of our Platform and your experience will not be impaired if you refuse them. These Cookies are described in more detail in Part 11.
Before any non-essential Cookies are placed on your device, you will be shown a clear prompt (e.g., a pop-up) requesting your consent to place them. By giving your consent, you enable us to offer you the best possible experience and service. You may choose to allow only first-party Cookies or block third-party ones. You may also withdraw your consent at any time.
Certain features of our site and services rely on Cookies to function correctly. These are considered “strictly necessary” Cookies for functioning of the website. Your consent is not required for these, but you may disable them in your browser settings. However, if you disable them through your browser settings, some parts of our websitem may not function properly.
4.1 Managing and Deleting Cookies
In addition to the controls we provide, you can manage Cookies through your internet browser settings. Most browsers allow you to block all Cookies, only third-party Cookies, or specific Cookies. You may also delete Cookies already stored on your device.
Please note that deleting or blocking Cookies may remove saved preferences (such as login information) and affect the functionality and performance of our website.
We recommend keeping your browser and operating system up to date and referring to the official help and support resources from your browser or device manufacturer if you need assistance with privacy settings.
5. What Personal Data Do You Collect and How?
We may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table:
|
Personal Data |
Method |
|
Cookies |
|
6. How Do You Use My Personal Data?
We may use your personal data for the following purposes:
|
Personal Data |
Purpose |
|
Cookies |
|
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|
Personal Data |
Term |
|
Cookies |
|
8. How and Where Do You Store or Transfer My Personal Data?
We may store some or all of your personal data in countries outside of the EU. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EU and under the Data Protection Legislation as follows:
We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you where we are legally required to do so.
9. Do You Share My Personal Data?
We do not sell your personal data. However, we may share certain personal data, such as data collected via cookies and online identifiers and usage data, with third-party analytics, advertising service providers and review platforms (e.g. Google) as outlined in Section 11.
If we share any of your personal data with third parties as described herein, we will take all appropriate steps to ensure it is processed securely and in accordance with applicable data protection laws and your rights.
10. Your Rights
Under applicable Data Protection Legislation you may have certain rights in relation to your personal data, depending on your location. These may include the following:
10.1 Right of Access — you have the right to request a copy of the personal data we hold about you (commonly known as a subject access request). All such requests should be made in writing via the contact details in Section 10. There is normally no fee; however, if your request is manifestly unfounded or excessive, a reasonable administrative fee may be charged. We aim to respond within 20 calendar days and in any case no later than one month of receiving your request.
10.2 Right to Rectification — you have the right to request that we correct any inaccurate or incomplete personal data we hold about you without undue delay.
10.3 Right to Erasure (“Right to be Forgotten”) — you have the right to request that we delete your personal data where there is no compelling reason for its continued processing, for example where the data is no longer necessary for the purpose for which it was collected.
10.4 Right to Restriction of Processing — you have the right to request that we restrict the processing of your personal data in certain circumstances, for example while we verify the accuracy of data you have contested.
10.5 Right to Data Portability — you have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
10.6 Right to Object — you have the right to object at any time to the processing of your personal data for direct marketing purposes, or where processing is based on our legitimate interests.
10.7 Rights Related to Automated Decision-Making — you have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects on you.
10.8 To exercise any of the rights listed above, please contact us using the details provided in Section 11. We will respond to all legitimate requests within one month. We may need to verify your identity before processing your request.
10.9 If you are located in Hong Kong, you may contact the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk.
11. Use of Analytics Technologies
We use the following third-party technologies on our website to analyse, improve performance of our website:
11.1 Google Analytics
We use Google Analytics to collect pseudonymised personal data about your interaction with our website (e.g., pages visited, time on page, referral source, device type).
These services may involve the transfer of personal data outside the EU. Where such transfers occur, we implement appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission or other legally recognised mechanisms, and where required additional measures to ensure an adequate level of protection for your personal data.
Google processes personal data in accordance with its own privacy policy.
- You can opt-out of Google Analytics tracking in your browser by installing the Google Analytics Opt-out Browser Add-on at: https://tools.google.com/dlpage/gaoptout.
- Google’s Privacy Policy is available at: https://policies.google.com/privacy
12. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details
Email address: ______________
13. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on https://mobiogroup.com/. This Privacy Notice was last updated on __ June 2026