Algogear Privacy Policy

Updated on July 7, 2026

1. Introduction

The Algogear entities that provide the Algogear Services and are responsible for making the disclosures required under applicable data protection laws are Fengine Intelligent North America Limited and Fengine Intelligent Technology Limited. These entities are referred to in this Privacy Policy as “Algogear”, “we”, “us” or “our”. This Policy explains how we collect, use, disclose and otherwise process personal data. This Policy applies to the following categories of data subjects:

a) if you are a U.S. citizen or an entity duly organized under the laws of the United States, the Algogear entity responsible for processing your personal data is Fengine Intelligent North America Limited; and

b) if you do not fall within the circumstances described in paragraph (a), the Algogear entity responsible for processing your personal data is Fengine Intelligent Technology Limited.

In this Policy, unless otherwise stated, Fengine Intelligent North America Limited and Fengine Intelligent Technology Limited are collectively referred to as “Algogear”. For ease of reference, “personal data” includes “personal information” and any similar term used under applicable data protection or privacy laws.

This Policy covers Algogear’s processing of the following categories of personal data:

(1) Personal data that we receive in connection with our programmatic advertising services, including: (i) device-related personal data about end users that we receive through application programming interfaces (“APIs”), our platforms, services or other technologies from traffic supply partners, such as mobile app developers, ad exchanges, supply-side platforms and other traffic supply platforms; (ii) personal data relating to end users’ interactions with ads, collected through APIs or other technologies, or collected and transferred to us by our Business Partners (including mobile app developers, publishers, advertisers and other advertising partners, “Business Partners”) or by third parties designated by them; (iii) device-related personal data generated when end users use the mobile apps, websites, platforms or services of our Business Partners, and personal data collected and transferred to us by our Business Partners or by third parties designated by them; and (iv) personal data provided by Business Partners when they use Algogear’s platforms, technologies or services. In this Policy, the end users described in this section are referred to as “Users”, “you” or “your”, and the APIs, technologies, platforms and services provided by Algogear are referred to as the “Algogear Services”.

(2) Personal data that we receive from visitors to https://www.algogear.com/ or to any other website on which this Policy is posted, and from visitors to any website that we provide to Business Partners or potential clients in connection with our services (collectively, “Visitors”, “you” or “your”).

This Policy is subject to any applicable service agreement between Algogear and you. By using the Algogear Services or the Algogear Site, you acknowledge that you have read and understood this Policy. Please review this Policy before using the Algogear Services or the Algogear Site.

We review this Policy and our related procedures from time to time and may update them to reflect changes in our practices or applicable legal requirements. If we make material changes to this Policy, we will publish an announcement on the Algogear website before the updated Policy takes effect.

Data protection and maintaining the trust of our Business Partners and users are core to Algogear’s business principles. Accordingly, compliance with applicable data protection laws is a priority for us. This Policy is intended to address applicable privacy and data protection requirements, including the EU General Data Protection Regulation (“GDPR”), the U.S. Children’s Online Privacy Protection Act (“COPPA”), the California Consumer Privacy Act (“CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Utah Consumer Privacy Act (“UCPA”), the Connecticut Data Privacy Act (“CDPA”), and the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais) (“LGPD”). Where our processing is subject to European data protection laws, Algogear acts as the controller of your personal data unless otherwise stated.

For the purposes of this Policy, “processor” means a “processor” under the GDPR, VCDPA, CPA, CDPA and UCPA, and a “service provider” under the CCPA; and “controller” means a “controller” under the GDPR, VCDPA, CPA, CDPA and UCPA, and a “business” under the CCPA.

2. How and why we collect users’ personal data

This Policy describes the circumstances in which Algogear collects and uses personal data.

Depending on how you use the Algogear Services, or services provided by Algogear’s Business Partners, we may collect personal data directly or receive it from our Business Partners, such as mobile app developers, publishers, ad exchanges, demand-side platforms, advertisers, advertising agencies, attribution partners and traffic supply platforms. For example:

(1) when we work with an ad exchange or traffic supply platform and that platform sends advertising requests to our demand-side platform, it may transmit users’ personal data to us;

(2) advertisers, demand-side platforms, ad exchanges or third-party attribution platforms used by them may share users’ personal data with us.

When providing the Algogear Services, we generally do not have a direct relationship with end users. Where required by applicable law, we rely on our Business Partners, such as mobile app developers, publishers, ad exchanges, demand-side platforms, supply-side platforms, advertisers and other partners, to provide appropriate notices and obtain any required consents or other lawful bases for the collection and use of users’ personal data. In our agreements with Business Partners, we require them to represent and warrant that the personal data they provide to us is lawfully obtained, that users are informed of the relevant processing activities in accordance with applicable law, that valid consent or another lawful basis is obtained where required, and that users are able to withdraw consent where applicable.

The Algogear Services may contain links to third-party websites, applications or other content. We do not control the privacy practices of those third parties, and their privacy practices may differ from those described in this Policy.

When we collect personal data such as the names and email addresses of representatives of Business Partners, we do so for business communication purposes, including communications necessary to perform our contracts with those Business Partners.

3. Personal data we may collect

When you view advertisements served through the Algogear Services or use services provided by Algogear’s Business Partners, we and/or our Business Partners may collect your personal data. To learn how the relevant app developer, publisher, advertiser or other Business Partner collects, uses and shares your personal data, and how you may exercise choices in relation to that processing, please review the privacy policy of the relevant Business Partner. Where required by applicable law, we require our Business Partners to provide appropriate notice and obtain any required consent before collecting or sharing personal data about you in connection with the services.

(1) When you view or click on advertisements that we promote, and then download or use the products promoted by those advertisements, such as mobile applications, we may receive the following personal data from advertisers, demand-side platforms, ad exchanges or third-party attribution platforms used by them:

Category of personal data	Data elements
Location data	[Required data] IP address [Optional data] Country, city;
Device / advertising identifiers	[Required data] IMEI, OAID, IDFV, mobile advertising identifier (such as Apple IDFA, Google Advertising ID and Amazon ID), MAC address;
Device data	[Required data] Device manufacturer, device model, device operating system information, device language, device type, device network information, device operator;
Application data	[Optional data] Algogear Business Partner’s application package name and application version;
Purposes of use data	[Required data] The timestamp of the installation event or other events;
Other data	[Optional data] User agent;

(2) When Algogear acts as a demand-side platform (“DSP”), ad exchanges and supply-side platforms may transmit personal data to us through APIs and other technologies, including:

Category of personal data	Data elements
Location data	[Required data] IP address [Optional data] Country, time zone and regional settings (country and preferred language);
Device / advertising identifiers	[Required data] International Mobile Equipment Identity (IMEI), Android ID, OAID, IDFV, mobile advertising identifier (such as Apple IDFA, Google Advertising ID and Amazon ID), MAC address;
Device data	[Required data] Device screen information, device manufacturer, device model, device operating system information, device type, device network information, limited advertising tracking (LAT) status;
Application data	[Required data] Algogear Business Partner’s application package name, application version and features;
Purposes of use data	[Required data] When you interact with the advertisements we promote, we will collect information about your interaction with the advertisements we promote, such as information about browsing and clicking on the advertisements;
Other data	[Optional data] Information transmitted by other advertising information exchange platforms or media platforms, user agents.

(3) When we provide the Algogear Services to Business Partners, we may collect the names, job titles, email addresses, business contact details, account usernames and passwords used to access Algogear websites, and IP addresses of individuals who use the Algogear Services on behalf of those Business Partners.

We work with reputable ad exchanges, demand-side platforms, supply-side platforms and other partners. Where permitted by applicable law, after an ad exchange or media platform receives an advertising request that contains your personal data, that personal data may be transmitted to Algogear so that advertisements can be delivered to you online.

Circumstances where consent is not required

Where required by applicable law, we contractually require our Business Partners, including mobile app developers, publishers, advertisers and advertising platforms, to obtain consent from users or their employees on our behalf for the processing described in this Policy. Users or their employees may withdraw consent at any time where consent is the applicable lawful basis. In certain circumstances, applicable laws may permit us to process personal data without consent, including where the processing is:

(1) necessary to enter into or perform a contract at your request;

(2) necessary to comply with legal obligations or to perform statutory duties, including obligations relating to national security, public security, criminal investigations, prosecutions, trials or enforcement of judgments;

(3) necessary to respond to public health emergencies, or to protect the life, health or property safety of natural persons in emergency situations;

(4) necessary for news reporting, public-interest supervision or other activities carried out in the public interest, within a reasonable scope;

(5) related to personal data that you have voluntarily made public, or other personal data that has been lawfully made public, within a reasonable scope; or

(6) otherwise permitted or required by applicable laws and regulations.

Where data does not identify, and cannot reasonably be linked to, an identified or identifiable individual, it is not treated as personal data. Where data can identify you, either alone or in combination with other data, or where we combine non-identifying data with your personal data, we will treat the combined data as personal data in accordance with this Policy.

If you are located in the European Economic Area, we may, where appropriate, process your personal data on the basis of our legitimate interests under the GDPR. Our legitimate interests may include monitoring and preventing fraud, resolving technical issues, ensuring the security and proper operation of our systems and services, and maintaining the integrity of our advertising services.

About sensitive personal data

Sensitive personal data may include, depending on applicable law, data that reveals or concerns racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic or biometric data, health data, sex life or sexual orientation, precise location data, financial account data, government identification numbers, or other categories of data treated as sensitive under applicable law.

We do not knowingly collect sensitive personal data unless permitted by applicable law and, where required, with your explicit consent. Our Business Partners may transfer sensitive personal data to us, or authorize us to process it, only after providing any required notice to you, explaining the necessity and potential impact of the processing, and obtaining your explicit consent or another lawful basis where required by applicable law.

4. How we use users’ personal data

We use your personal data in the following manner:

Categories of personal data	Purposes of use
Including all types of personal data described in paragraphs (1) to (2) of Article 3 of this Policy	Core business functions: Your device may be distinguished from other devices based on information it automatically sends. We use personal data to deliver ads to your device through automated processes. Ads may be shown based on information that we lawfully collect or receive, such as the content you are viewing, the app or website you are using, your approximate location, device type and device status. Where required by applicable law, we will obtain your explicit consent before conducting automated decision-making or profiling that produces legal or similarly significant effects concerning you. Technical and security functions: We may use device data and interaction data to monitor traffic quality, detect and prevent fraud, troubleshoot technical issues, and ensure the security and proper operation of our systems and services.
Including all types of personal data described in paragraph (3) of Article 3 of this Policy	We may collect and use personal data of individuals who represent our Business Partners when they use the Algogear Services, such as employees of publishers, advertisers or advertising partners, for business contact and direct marketing purposes where permitted by applicable law.
Sensitive personal data	We will not knowingly collect sensitive personal data unless permitted by applicable law and, where required, with your explicit consent. Our Business Partners may transmit sensitive personal data to us, or authorize us to process it, only after providing any required notice and obtaining explicit consent or another lawful basis where required by applicable law.

Subject to applicable law, we may disclose or share personal data with third parties for the purposes and in the circumstances described below.

(1) Sharing with third parties

When we act as an ad exchange, demand-side platform or traffic supply platform, we may, in order to perform our contractual obligations to Business Partners and provide our services, report on the performance and effectiveness of ads that users interact with, provide traffic quality statistics, and share users’ personal data with Business Partners for advertising attribution, settlement, ad delivery, traffic quality monitoring and anti-fraud purposes. The personal data we share is limited to data relating to advertising performance and effectiveness, such as device information, clicks, impressions, installations or activations. These Business Partners may use the personal data to measure users’ interactions with advertisements or websites, evaluate ad performance and effectiveness, understand areas of user interest, and better understand traffic usage or user behavior on websites and applications to improve their services. The use of such data by our Business Partners is governed by their own privacy policies.

We may also engage third-party technical service providers, such as cloud service providers, to process personal data on our behalf in order to support the secure and proper operation of our systems and services and to store data.

In accordance with applicable data protection laws, we will not share users’ personal data with third parties other than Algogear affiliates unless authorized by the user or otherwise permitted or required by applicable law. This restriction does not apply to data that has been anonymized in a manner that prevents identification of an individual and cannot reasonably be re-identified. Users may request information about the names, contact details and other relevant information of our Business Partners and third-party technical service providers by contacting legal@fengine.com.

We may also share aggregated or anonymized information with other third parties in accordance with the terms of this Privacy Policy.

Categories of recipients	Categories of personal data	Purposes of processing and disclosure
Advertisers, advertising agencies, attribution service providers, demand-side platforms, ad exchanges, supply-side platforms and Algogear affiliates	1. Location data: IP address, country, time zone and locale settings, including country information and preferred language. 2. Device / advertising identifiers: Android ID, OAID, IDFV, IDFA, GAID, Amazon ID and other advertising identifiers. We will not collect or use such identifiers where you have restricted your device, browser or app from allowing access to device or advertising identifiers in accordance with Article 7 of this Policy. 3. Device data: device make, device model, operating system information, device type, screen information, battery information, device volume and font size, emulator status, network information, hardware information, device sensor information, Limited Ad Tracking (LAT) status, system boot time, device username and storage capacity information. 4. Application / site data: package name, site URL, version and characteristics of the app or website of Algogear Business Partners that is used when you interact with the Algogear Services. 5. Interaction data: information about your interaction with ads served by us, such as whether you viewed or clicked an ad. 6. Other data: user agent, TCF string and other data transmitted by ad exchanges, media platforms or attribution partners.	1. Advertising attribution and settlement with advertisers or advertising agencies. In relation to these processing activities, Algogear may act as a processor under the GDPR on behalf of advertisers or advertising agencies. 2. Monitoring advertising delivery quality and preventing fraud. 3. Placing, measuring and optimizing advertisements.

Except as expressly stated in this Policy, we will not disclose users’ personal data to third parties without user consent or another lawful basis where required by applicable law.

We contractually require partners that have a direct relationship with users to provide users with notice of the third-party sharing described above and to obtain consent or rely on another lawful basis where required by applicable law.

We may also share aggregate or anonymous information with other third parties in accordance with the terms of this Policy.

(2) Corporate transactions

If it becomes necessary to transfer users’ personal data in connection with a merger, demerger, dissolution, bankruptcy, sale of assets or business transfer, we will provide users with information about the recipient in accordance with applicable law and will require the recipient to continue to comply with applicable controller or processor obligations. If the recipient changes the original purposes or means of processing, we will require the recipient to obtain user consent again, or to establish another lawful basis, where required by applicable law.

(3) Legal disclosures

We may disclose your personal data to third parties for legal, regulatory, judicial or administrative purposes where we consider such disclosure necessary or appropriate, including:

(i) to comply with applicable privacy and data protection laws;

(ii) to respond to subpoenas, search warrants or other legal process;

(iii) in response to a request from a public authority or governmental body;

(iv) to enforce our terms and conditions;

(v) where we believe in good faith that disclosure is necessary to protect the rights, property or safety of Algogear, our affiliates, subsidiaries, users or others; and

(vi) to establish or exercise our legal rights, or to defend against legal claims.

6. International Transfers

The primary locations where we process personal data are Singapore and the United States. However, we may transfer personal data to other countries where Algogear, its affiliates, service providers or partners conduct business. We implement such transfers in accordance with applicable law, including by entering into data transfer agreements or implementing other appropriate safeguards where required.

If you are located in the European Economic Area (“EEA”), the personal data we collect about you may be transferred to, or accessed remotely from, countries outside the EEA, including the United States, Singapore or other countries that have not been recognized by the European Commission as providing an adequate level of data protection. We will implement appropriate safeguards for such personal data as required by applicable law. Where required by law, our Business Partners will obtain your consent to transfer your personal data outside the EEA, including to Algogear or other recipients described in this Policy. You may withdraw consent at any time where consent is the applicable transfer mechanism.

If you are a U.S. person, we will comply with applicable U.S. laws and regulations, including the U.S. Department of Justice Data Security Program (“DSP”), and will not unlawfully transfer, share or otherwise make available your personal data.

7. Your data rights

(1) If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or another country or region whose applicable data protection laws grant you comparable rights, you may, to the extent permitted by applicable law, have one or more of the following data subject rights:

Right of access. You have the right to request access to the personal data we process relating to you and to obtain information about how we process such personal data.
Right to rectification. You have the right to request that we correct inaccurate or incomplete personal data.
Right to erasure. You have the right to request that we delete your personal data in the circumstances provided by applicable law.
Right to restriction of processing. You have the right to request that we restrict the processing of your personal data in the circumstances provided by applicable law.
Right to object. You have the right to object to our processing of your personal data in the circumstances provided by applicable law, including objecting to processing based on legitimate interests or processing for direct-marketing purposes.
Right to data portability. You have the right, in the circumstances provided by applicable law, to request that we provide you, or a third party of your choosing, with a copy of your personal data in a structured, commonly used and machine-readable format.
Right to withdraw consent. Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Rights relating to automated decision-making. In the circumstances provided by applicable law, you have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you, or to request that we provide human intervention, allow you to express your point of view, or contest the decision.
Right to lodge a complaint. You have the right to lodge a complaint regarding our processing of your personal data with the data protection supervisory authority in your location or having jurisdiction.

Priority of local law. Although we seek to provide users with a broad set of data rights globally, the rights available to you may vary by jurisdiction. Where the rights described in this Policy are inconsistent with mandatory provisions of the data protection laws applicable in your jurisdiction, the mandatory provisions of the applicable local law will prevail.

（2）Privacy Rights of U.S. Residents

If you are a U.S. resident, you may have one or more of the following privacy rights under applicable U.S. federal or state privacy laws, including the privacy laws of California, Virginia, Colorado, Connecticut, Utah and other applicable states:

To confirm whether we process your personal data and to access that personal data.
To correct inaccuracies in your personal data.
To delete your personal data.
To obtain a copy of personal data that you have provided to us.
To opt out of the processing of your personal data for purposes of: (i) targeted or personalized advertising; (ii) the sale of personal data; (iii) the sharing of personal data; or (iv) profiling or analysis in furtherance of decisions that produce legal or similarly significant effects concerning you.
Right to opt out of sale or sharing. You have the right to opt out of the sale or sharing of your personal data.
Right to limit the use and disclosure of sensitive personal data. You have the right, to the extent provided by applicable law, to request that we limit the use and disclosure of your sensitive personal data, except for uses permitted by applicable law.
Right to non-discrimination. You have the right to exercise the rights granted to you under applicable privacy laws free from discrimination.
Right to appeal. If we decline your privacy rights request and the applicable state privacy law grants you a right to appeal, you may appeal in the manner provided in our response, or by sending an email to legal@fengine.com.

California residents (CCPA)

If you are a California resident, you may also request that we disclose how we have collected, used, sold, shared or disclosed your personal data during the period prescribed by applicable law, which generally covers the preceding 12 months. Where permitted by applicable law, you may request that we disclose such information for a period longer than 12 months, provided that this right applies only to personal data collected by us on or after January 1, 2022 and still retained by us, and is subject to applicable exceptions. This does not require us to retain personal data for longer than necessary in order to respond to such a request.

The information California residents may request includes:

the categories of personal data we have collected;
the categories of sources from which the personal data was collected;
the business or commercial purposes for collecting or sharing personal data;
the categories of third parties to whom we disclose personal data;
the categories of personal data that we have sold, shared or disclosed for a business purpose;
the categories of third parties to whom the personal data was sold or shared, or disclosed for a business purpose; and
a copy of the personal data we have collected about you during the period prescribed by applicable law.

The rights described above are not exhaustive and do not limit any other privacy rights you may have under applicable U.S. federal or state law. If the laws of your state of residence grant additional privacy rights not expressly described in this section, this Policy does not limit or prevent you from exercising those rights in accordance with applicable law. We will comply with applicable U.S. state privacy laws to protect your personal data.

(3) How to exercise your rights

Regardless of your location, you may submit a data subject request to us by sending an email to legal@fengine.com. This mailbox is also available for users in the EEA, the UK, the United States and other applicable regions to submit requests to access, correct, delete, restrict or object to the processing of personal data, withdraw consent, request data portability, opt out of certain processing activities, or exercise other privacy rights granted by applicable law.

If you wish to opt out of the sale or sharing of your personal data, you may do so by sending “Do Not Sell or Share My Data” to legal@fengine.com.

If you wish to limit our use and disclosure of your sensitive personal data, or to opt out of the processing of your personal data for targeted or personalized advertising, the sale or sharing of personal data, or profiling or analysis in furtherance of decisions that produce legal or similarly significant effects concerning you, you may submit a request by sending an email to legal@fengine.com.

To the extent required by applicable law, we will also recognize and honour opt-out preferences expressed by users through browsers, device settings, platform permission settings or other applicable preference signals.

When you submit a request, we will verify it in accordance with our internal procedures and the information you provide, such as a device ID, company email address or other necessary information. If you fail to provide information necessary for us to verify your identity or locate the relevant personal data, we may be unable to process your request or may decline it as permitted by law.

You may designate an authorized agent to submit an applicable privacy rights request on your behalf by providing the agent with written authorization and verifying your identity directly with us where required. We may deny a request from an agent that does not provide valid proof of authorization.

(4) Response timeframes

We will process your request without undue delay and respond within the period required by applicable law. Specifically:

If you are located in the EEA or the UK, we will generally respond within one month of receiving your request. For complex or multiple requests, where permitted by applicable law, we may extend the response period by up to a further two months, and will inform you of the extension and the reasons for it within one month of receiving the request.
If you are a U.S. resident, we will generally respond within 45 days of receiving a verifiable consumer request. For complex or multiple requests, where permitted by applicable law, we may extend the response period by a further 45 days, and will inform you of the extension and the reasons for it within the initial 45-day period.
If you are located in another country or region, we will respond to your request within the period prescribed by the applicable data protection laws of your location; where local law does not prescribe a specific period, we will generally respond within 30 days of receiving a verifiable request.
If we decline to act on your request as permitted by law, we will explain the reasons for the refusal within the period required by applicable law and, where required by applicable law, inform you of the appeal, complaint or other remedies available to you.

Unless otherwise provided by applicable law, we will generally respond by electronic means to requests submitted electronically; where you request a response by other means, and where permitted by applicable law and technically feasible, we will give reasonable consideration to your request.

(5) Personalized advertising choices

Regardless of your location, you may opt out of personalized advertising as described below.

Opt-out guidance

You may opt out of receiving interest-based, targeted or behavioral advertising from Algogear on supported devices by following the guidance below.

On an iOS device, if you are using iOS 14.5 or above, you may select “Ask App Not to Track” in the app tracking prompt or manage your tracking settings under Settings > Privacy & Security > Tracking. If you ask the app not to track, Algogear will not access your advertising identifiers and will not use advertising identifiers to infer your interests or serve advertisements to your device based on inferred interests.

On Android devices, your settings may allow you to opt out of interest-based advertising or reset/delete your advertising ID. When you opt out through your device settings, Algogear will not use information collected from that device to infer your interests or serve interest-based ads to that device based on inferred interests.

You may also manage personalized advertising settings in the privacy-related settings of the mobile app you have downloaded, where available. If you choose not to allow personalized advertising, Algogear will not use information collected from your device to infer your interests or serve ads to your device based on inferred interests.

Your mobile web browser may provide a “Do Not Track” or similar browser setting. Where required by applicable law or where we are technically able to honor such preference signals, Algogear will not use mobile web browsing information from that browser to infer your interests or serve interest-based ads to that device based on inferred interests.

8. Security of users’ personal data

The security of users’ personal data is a priority for us. We implement appropriate technical, organizational and administrative measures designed to protect personal data against unauthorized access, use, disclosure, alteration or destruction. For example, we use firewalls, encryption technologies and other automated tools designed to protect against fraud and identity theft; store data in secure data centers; and apply physical access controls, including perimeter controls, building access controls, video surveillance and other electronic measures. We also maintain data security processes and access controls designed to ensure that only authorized personnel can access personal data where necessary, and we conduct data and technology security audits where appropriate. We maintain incident response procedures and will notify affected users and/or competent authorities of personal data breaches where required by applicable law.

We also seek to protect users’ privacy by minimizing the personal data we collect and retain where practicable, and by requiring appropriate contractual commitments from our partners regarding their handling of user data.

how long the personal data is needed to provide the services and operate the business;
the categories and sensitivity of the personal data collected; and
whether we are subject to a legal, contractual or similar obligation to retain the data (for example, mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or dispute resolution).

9. Protection of children and minors

The Algogear Services are intended primarily for adults. We do not knowingly or intentionally collect personal data from children or minors, and we do not knowingly profile or make personalized recommendations to children or minors. In the processing activities described in this Policy, we generally distinguish devices or browsers based on device or technical identifiers rather than age. Where our partners transfer or share data with us, we require them to comply with applicable laws relating to the protection of children’s and minors’ personal data, and to implement appropriate safeguards, including stricter de-identification and encryption measures where appropriate.

If an end user is a child or minor under applicable law, the end user should read the privacy policy of the relevant developer, publisher or advertiser application and this Policy under the supervision of a parent or guardian, and should use the relevant application or provide personal data only with the consent of a parent or guardian where required by applicable law.

We protect children’s and minors’ personal data in accordance with applicable laws and regulations. We will collect, use, store, share, transfer or otherwise process such personal data only where permitted by law, with consent from a parent or guardian where required, or where necessary to protect the child or minor. If we become aware that we have collected personal data from a child or minor without any required verifiable parental consent, we will take steps to delete such data as soon as reasonably practicable.

If you are a parent or guardian and have questions about our processing of personal data relating to a child or minor under your guardianship, please contact us using the contact information provided in this Policy.

If a parent or guardian becomes aware that their child has provided us with personal data without the required consent, the parent or guardian should contact us promptly. We will take reasonable steps to ensure that such data is deleted from our files.

10. Marketing

If you are a Business Partner, we or our affiliates may contact you periodically by email to provide information about our products, services and content that may be of interest to you. If applicable law requires your consent before we send certain types of marketing communications, we will send those communications only after receiving your consent.

If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in the relevant communication or request to opt out by emailing legal@fengine.com.

11. Contact us

You may contact our data protection contact by sending a written request to legal@fengine.com.

Privacy Policy of Algogear Website

1. INTRODUCTION

This Privacy Policy of the Algogear Website applies to the collection and use of personal data when you visit or use the Algogear Site. For the purposes of the GDPR, Algogear is the controller of your personal data unless otherwise stated.

2. WHAT PERSONAL DATA WE COLLECT

When you use the Algogear Site, we may collect the following personal data:

Information collected automatically, such as browser type, domain name, IP address, pages visited and session duration, using technologies such as IP addresses, cookies, internet tags and navigational data collection tools.

Algogear may take reasonable steps to verify the accuracy and authenticity of personal data that you provide.

If you provide us with personal data about another individual, you represent and warrant that you have the authority or consent required to do so.

3. HOW WE USE YOUR INFORMATION

Depending on the context and the applicable legal basis, including your consent or our legitimate interests, we may use your personal data for the following purposes: (i) to provide you with Algogear products, services or information; (ii) to register you for an event or training; (iii) to contact you and respond to your requests and enquiries; (iv) for business administration, including statistical analysis; (v) to personalize your visit to the Algogear Site and assist you while you use the Site; (vi) to improve the Algogear Site and better understand how it is used; and (vii) to provide you periodically by email with information about our products, services and content that may be of interest to you, where permitted by applicable law.

If you no longer wish to receive marketing communications from us, you may follow the unsubscribe instructions provided in the relevant email or request to opt out by emailing legal@fengine.com.

4. DISCLOSURE OF YOUR PERSONAL DATA

Subject to applicable laws and regulations, we may disclose your personal data to Algogear affiliates and other third parties as described in this Policy.

We may engage third-party technology service providers that may have access to your personal data, including companies that assist with programming, hosting and operating the Algogear Site, analytics providers such as Google Analytics that help analyze website usage, and email service providers.

We may also share aggregated or anonymized data with third parties in accordance with this Policy.

We may disclose users’ personal data to our affiliates for the purposes described in this Policy or to promote the products or services of our affiliates, where permitted by applicable law.

The servers used to operate the Algogear Site may automatically identify a device or browser by its IP address. We generally will not be able to identify a specific device or individual using the IP address after you leave the Algogear Site. If we determine in good faith that you have misused or attempted to misuse or harm the Site, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property.

We may share your personal data as required or permitted by law to comply with subpoenas, legal process or government requests, or where we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights or property, or the rights, property or safety of others, including advisers, law enforcement agencies, courts and regulatory authorities. We may also transfer your personal data to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or part of our business, whether by merger, acquisition, reorganization or otherwise.

5. INTERNATIONAL TRANSFERS

6. YOUR DATA RIGHTS

Right of access. You have the right to request access to the personal data we process relating to you and to obtain information about how we process such personal data.
Right to rectification. You have the right to request that we correct inaccurate or incomplete personal data.
Right to erasure. You have the right to request that we delete your personal data in the circumstances provided by applicable law.
Right to restriction of processing. You have the right to request that we restrict the processing of your personal data in the circumstances provided by applicable law.
Right to object. You have the right to object to our processing of your personal data in the circumstances provided by applicable law, including objecting to processing based on legitimate interests or processing for direct-marketing purposes.
Right to data portability. You have the right, in the circumstances provided by applicable law, to request that we provide you, or a third party of your choosing, with a copy of your personal data in a structured, commonly used and machine-readable format.
Right to withdraw consent. Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Rights relating to automated decision-making. In the circumstances provided by applicable law, you have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you, or to request that we provide human intervention, allow you to express your point of view, or contest the decision.
Right to lodge a complaint. You have the right to lodge a complaint regarding our processing of your personal data with the data protection supervisory authority in your location or having jurisdiction.

（2）Privacy Rights of U.S. Residents

To confirm whether we process your personal data and to access that personal data.
To correct inaccuracies in your personal data.
To delete your personal data.
To obtain a copy of personal data that you have provided to us.
To opt out of the processing of your personal data for purposes of: (i) targeted or personalized advertising; (ii) the sale of personal data; (iii) the sharing of personal data; or (iv) profiling or analysis in furtherance of decisions that produce legal or similarly significant effects concerning you.
Right to opt out of sale or sharing. You have the right to opt out of the sale or sharing of your personal data.
Right to limit the use and disclosure of sensitive personal data. You have the right, to the extent provided by applicable law, to request that we limit the use and disclosure of your sensitive personal data, except for uses permitted by applicable law.
Right to non-discrimination. You have the right to exercise the rights granted to you under applicable privacy laws free from discrimination.
Right to appeal. If we decline your privacy rights request and the applicable state privacy law grants you a right to appeal, you may appeal in the manner provided in our response, or by sending an email to legal@fengine.com.

California residents (CCPA)

The information California residents may request includes:

the categories of personal data we have collected;
the categories of sources from which the personal data was collected;
the business or commercial purposes for collecting or sharing personal data;
the categories of third parties to whom we disclose personal data;
the categories of personal data that we have sold, shared or disclosed for a business purpose;
the categories of third parties to whom the personal data was sold or shared, or disclosed for a business purpose; and
a copy of the personal data we have collected about you during the period prescribed by applicable law.

(3) How to exercise your rights

If you wish to opt out of the sale or sharing of your personal data, you may do so by sending “Do Not Sell or Share My Data” to legal@fengine.com.

(4) Response timeframes

We will process your request without undue delay and respond within the period required by applicable law. Specifically:

If you are located in the EEA or the UK, we will generally respond within one month of receiving your request. For complex or multiple requests, where permitted by applicable law, we may extend the response period by up to a further two months, and will inform you of the extension and the reasons for it within one month of receiving the request.
If you are a U.S. resident, we will generally respond within 45 days of receiving a verifiable consumer request. For complex or multiple requests, where permitted by applicable law, we may extend the response period by a further 45 days, and will inform you of the extension and the reasons for it within the initial 45-day period.
If you are located in another country or region, we will respond to your request within the period prescribed by the applicable data protection laws of your location; where local law does not prescribe a specific period, we will generally respond within 30 days of receiving a verifiable request.
If we decline to act on your request as permitted by law, we will explain the reasons for the refusal within the period required by applicable law and, where required by applicable law, inform you of the appeal, complaint or other remedies available to you.

7. SECURITY OF YOUR PERSONAL DATA

We retain personal data for as long as necessary to achieve the purposes described in this Policy, unless a longer retention period is required or permitted by applicable law. Generally, personal data will be retained in our systems for no more than two (2) years from the date of collection. The criteria we use to determine retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the categories and sensitivity of the personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data, such as mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for litigation or dispute resolution purposes.

8. PROTECTION OF CHILDREN AND MINORS

The Site does not knowingly collect personal data from children or minors. If you provide personal data relating to a child or minor, you must have obtained the consent of the child’s or minor’s parent or guardian where required by applicable law. “Child” and “minor” are defined in accordance with the laws applicable to this Privacy Policy of the Algogear Website.

We process children’s and minors’ personal data in accordance with applicable laws and regulations. Except as otherwise provided by law, we collect, use, store, disclose or make available such personal data only where permitted by law, with consent from a parent or guardian where required, or where necessary to protect the child or minor. If we become aware that we have collected personal data from a child or minor without required verifiable parental consent, we will take steps to delete the relevant data as soon as reasonably practicable.

If you are a parent or guardian and have questions about our protection of children’s or minors’ personal data, please contact us using the email address provided in this Policy.

If you are located in the United States, we will comply with COPPA. If our Business Partners, such as publishers, operate apps directed to children under the age of thirteen (13) or knowingly collect, use or disclose personal data of children under the age of thirteen (13) during our cooperation, they must obtain verifiable parental consent for Algogear to collect, use or disclose such personal data in accordance with this Policy. We require such Business Partners to notify us when their services are child-directed or when COPPA applies, so that persistent identifiers collected from users of services flagged as “child-directed” are processed in accordance with COPPA, including by not using such identifiers to serve behaviorally targeted ads or track users for such purposes in violation of COPPA. In addition, we will not knowingly collect other personal data, such as precise geolocation data, from users of apps that we know are directed to children under the age of thirteen (13).

If you are located in California, we will comply with the CCPA. We will not sell or share personal data of consumers under the age of 16, or use such data for targeted advertising, unless we have obtained the required opt-in consent. If the request for consent is declined, we will not request consent again for 12 months. Consumers under the age of 13 must obtain consent from a parent or guardian to opt in.

9. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Algogear may use cookies or other technology (collectively “Cookies”) to collect certain information about you when you are visiting the Site. Please read our Cookies Policy for more details.

10. OUTSIDE SITES AND LINKING

The Site may contain links or references to websites or resources owned or operated by third parties (“Outside Sites”). Algogear is not responsible for the availability of, or the content located on or through, any Outside Site, including any webcasting or other transmission received from an Outside Site. Please contact the relevant site administrator or webmaster if you have concerns about such links or content. Algogear permits certain third-party links to the home page of the Site, provided that Algogear is notified of such links and does not object. Algogear reserves the right to revoke any linking permission at any time, including permission to link to the home page. Outside Sites are provided for convenience only, and any link or reference on the Site does not imply endorsement of the relevant Outside Site.

11. COPYRIGHT

All Site content, designs, text, graphics, images, logos, buttons, icons, interfaces, audio and video clips, and the selection and arrangement thereof are the exclusive property of Algogear or its respective content providers, and are protected by Singapore and international copyright laws. All software used on the Site is the property of Algogear or its respective software suppliers, and is protected by Hong Kong SAR and international copyright laws and other applicable laws and treaties. Users of this Site must not transmit or post any information to this Site that infringes the copyright or other intellectual property rights of any third party.

12. TRADEMARKS

All trademarks, service marks and trade names used on the Site (collectively, the “Marks”) are owned by Algogear. The Marks may not be used in connection with any product or service that is not a product or service of Algogear, or in any manner that is likely to cause confusion among customers or that disparages or discredits Algogear.

13. ONLINE CONDUCT

Any conduct that, in Algogear’s sole discretion, restricts or inhibits any other person from using or enjoying the Site is prohibited. You agree to use the Site only for lawful purposes. You agree not to post on the Site or transmit any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, sexually explicit, profane, hateful, racially, ethnically or otherwise objectionable material of any kind, including any material that encourages conduct that would constitute a criminal offense, give rise to civil liability or otherwise violate any applicable local, state, national or international law.

14. TERMINATION OF USAGE

Algogear may, without incurring liability to you, terminate or suspend your access to all or part of the Site, without notice, for any conduct that Algogear, in its sole discretion, believes violates applicable law or this Policy, or is harmful to the interests of another user, a third party, a merchant, a sponsor, a licensor, a service provider or the Site.

Due to the rapid development of internet technologies, we may update this Policy from time to time. All revisions will be posted on https://www.algogear.com/.

15. CONTACT US

You may contact our data protection contact by sending a written request to legal@fengine.com.

Algogear Privacy Policy ​

1. Introduction ​

2. How and why we collect users’ personal data ​

3. Personal data we may collect ​

4. How we use users’ personal data ​

5. How we share and disclose users’ personal data ​

6. International Transfers ​

7. Your data rights ​

8. Security of users’ personal data ​

9. Protection of children and minors ​

10. Marketing ​

11. Contact us ​

Privacy Policy of Algogear Website ​

1. INTRODUCTION ​

2. WHAT PERSONAL DATA WE COLLECT ​

3. HOW WE USE YOUR INFORMATION ​

4. DISCLOSURE OF YOUR PERSONAL DATA ​

5. INTERNATIONAL TRANSFERS ​

6. YOUR DATA RIGHTS ​

7. SECURITY OF YOUR PERSONAL DATA ​

8. PROTECTION OF CHILDREN AND MINORS ​

9. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES ​

10. OUTSIDE SITES AND LINKING ​

11. COPYRIGHT ​

12. TRADEMARKS ​

13. ONLINE CONDUCT ​

14. TERMINATION OF USAGE ​

15. CONTACT US ​