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User Privacy Policy

Last updated February 2026.
This Privacy Policy is effective as of February 2026 for all users.

We are committed to respecting and protecting each individual’s privacy rights. This Privacy Policy explains how the website and its wholly-owned subsidiaries and holding subsidiaries (collectively referred to as “Company,” “we,” “our,” or “us,” meaning GROW ENGINE LIMITED and its affiliates; where “holding” refers to direct or indirect ownership of 50% or more) collect, use, disclose, or share end-user information (“you” or “your”) through our advertising platform (“Advertising Service”), our website (“Website”), our mobile applications (“App”), and any other products or services we provide (collectively, the “Services”). This Policy applies whether you access the Services directly or through a third party.

Except as specifically described below, this Privacy Policy does not apply to information collected by third parties—for example, other companies, websites, or mobile applications—even if they are linked to or accessible through our Services.

We collect information for users:

(i) visit our Website;

(ii) view ads served by our Advertising Service;

(iii) interact with our Advertising Service; or

(iv) interact with platforms, applications, websites, or other products or services provided by our business partners (e.g., app publishers, advertisers).

When you use the Services, and where applicable under relevant laws, you consent to our collection, use, and disclosure of information as described in this Privacy Policy. Under other legal frameworks, we may collect, use, or disclose your information based on appropriate legal bases.

Please review this Privacy Policy before using the Services. We may amend this Privacy Policy from time to time. Any updates will be displayed on our Website. Please check regularly for the most recent version. Where required under applicable law, your continued use of the Services after the effective date constitutes your acknowledgment and acceptance of the revised Privacy Policy.

If you have any questions or concerns about our information practices, please contact us

1. What Information We Collect and How We Collect It

We may collect, transmit, store, and otherwise process information about you in connection with your use of the Services, including information you send to or through the Services. We use this information to provide and improve the Services, fulfill requests, conduct analysis, personalize experiences, track usage, display relevant advertising, assist our partners, provide customer, back up our systems, ensure security, and comply with legal obligations.

Even when information is not retained, it must be transmitted to our servers and temporarily stored for processing.

Information we may collect:

Information you provide

May include:

  • name
  • gender
  • date of birth
  • personal ID numbers
  • address
  • phone number
  • email address
  • occupation
  • education
  • work experience
  • other information you choose to provide

Passive information collected automatically

Examples include:

  • browser information (user agent)
  • browser type
  • IP address
  • device type
  • Identifier for Advertising (IDFA)
  • Google Advertising ID (GAID)
  • interaction with ads (views, clicks, engagement)
  • device identifiers
  • domain name
  • pages visited
  • session duration
  • log data collected via IP addresses, cookies, tags, SDKs, or similar technologies

Cookies

We use cookies to collect device and network information such as:

  • access time and date
  • device characteristics
  • domain access data

This information is used internally to analyze and optimize performance. Cookie-based data does not personally identify you.

Information from third-party partners

We may receive information from partners such as:

  • companies providing services to us
  • publishers
  • advertisers
  • analytics or attribution partners

2. How We Use Your Information

We use personal and non-personal information to:

  • Provide, operate, maintain, and improve our Services
  • Internal business operations
  • Assist customers or partners in improving their offerings
  • Compile aggregate analytics for internal/external use
  • Prevent illegal or fraudulent activities
  • Customer service requests and user accounts
  • Comply with legal and regulatory requirements
  • Enforce our Terms and Conditions

We may also use device-level information to:

  • Display advertisements, including interest-based ads
  • Conduct real-time ad bidding
  • Measure ad effectiveness across devices
  • Provide advertisers with reporting and analytics
  • Build custom audience segments

Legal Basis for Processing Personal Information

We only process personal data where we have a valid legal basis. These include:

2.1 Legitimate Interests

For example:

  • Tracking and reducing fraudulent traffic
  • Verifying advertisement performance
  • Preventing and detecting crime
  • Analyzing device data to optimize ad performance
  • Conducting ongoing business analysis
  • Optimizing our in-house Apps

We conduct a balancing test to ensure our legitimate interests are not overridden by your rights and freedoms.

2.2 Compliance with Legal Obligations

We may process personal information where required to comply with applicable laws.

Legal entity:Dovi Creative Limited

Legal entity address:Rm 701, Unit 108B, 7/F,Twr B New Mandarin Plaza 14 Science Museum Rd Tsim Sha Tsui Hong Kong