Shine Dragon Group Limited Privacy Policy


The purpose of our Privacy Policy (hereinafter identified as "Privacy Policy") is to safeguard users’ information containing personal data from illegal and unapproved access and disclosures. We recognize and respect the rights of web site visitors and we are strongly committed to keep their privacy and acknowledge the importance personal data protection. Our Privacy Policy explains how we treat personal information about you that we obtain when you visit our site: (hereinafter named as "Site"). This Regulation encompasses the following issues: which information we collect, why we collect it and how precisely we use information about our visitors. Along with our Privacy Policy, this Site is subject to the terms of the contract that determine the regulation of any conflict with this Privacy Policy.

All the relations concerning collection, storage, disclosure and protection of the information about visitors of the Site are specified and determined by these Rules and other legal instrument of the Site Administration and the applicable legislation of Hong Kong. Navigating the Site implies that the user fully agrees to each and all of the provisions and points contained in this Privacy Policy. We have made our best efforts to make it as simple as possible, but if you are not familiar with some terms such as cookies , IP- addresses, pixel tags and browsers, you can find the key terms at the end of the document.

Submission and Processing of Information

When you subscribe or sign up to the Website, may ask you to provide certain personally attributable information. This personally identifiable information may encompass data that can be used to identify or contact you, such as your name and email address. You must consent to the Terms and Conditions of this website before making any comments or leaving any reviews on any posting.

User Postings

Except as otherwise expressly stipulated in this Privacy Policy, this policy only addresses the use and disclosure of Personal Information and other information we gather from you. In the course of your use of the Website, including when you generate a profile on the Website, you may choose to post or otherwise reveal information about yourself and others, which may include Personal Information or other personally identifiable information. You may also choose to communicate with others or upload content such as photographs. Such postings are governed by our Terms and Conditions. Whenever you , at your own free will, disclose personal information on publicly-viewable web pages, that information will be publicly accessible and can be gathered or used by others. Such postings may also appear on other websites or when searches are performed on the subject of your posting. Furthermore, although imposes limitations on access to sections and parts of the Website to members of the Service, since the Service is offered via and accessible through a number of other websites in addition to the Website, any information that you post to the Website for access by members of the Website may be searchable and reachable to users of the Service who access it via different websites from the Website. You may also receive uninviated and unwelcome messages from other parties by reason of such disclosure. Such activities are beyond the control of and this Privacy Policy. You should therefore exercise and practice discretion and caution when revealing any Personal Information or other information when using the Website or the Service.

Countries with limited services

In accordance with certification of obligation to abide by national and international sanctions Shine Dragon Group Limited is not integrating publishers registered in Afghanistan, Algeria, Bahrain, Bosnia and Herzegovina, Crimea, DPRK North Korea, Ethiopia, Iraq, Iran, Kuwait, Lebanon, Lybia, Myanmar (Burma), Nigeria, Oman, Pakistan, Palestine, Qatar, Saudi Arabia, South Sudan, Sudan, Syria, Uganda, Vanuatu, Yemen. Traffic and offers from/targeted to those states and territories will be banned, not paid and viewed as not allowed. There are also no payouts or incomes that can be processed from these countries.

Children’s Online Privacy

It is of importance to that parents and guardians have control over what information is gathered from their children online and how such information is used or may be used. In this respect, we ensure that we follow, respect, and comply with applicable and relevant national and international legislation. Thus, we do not knowingly gather, solicit, and collect personal information and data about or from Internet users below the age of 13. If we find out that we have received personal data from such users, this information is deleted immediately.

In addition tho this, we require that natural persons shall be at least 18 years old or older to register as a member of the Service. Accordingly, our policy is not to solicit or collect information about or from anyone below 18 years old.

However, we inform you that if an online communication has been submitted by a person under age 18 absent a clear indication, the collection of Personal data submitted to the Website will be processed and treated as though it was submitted by an adult, and may, unless excluded or exempted from access by federal or state law, be subject to public access.

In the event that receives an online communication clearly stating and indicating that it has been submitted by an individual below the age of 18, under no circumstances will any Personal Information be published on the Website, be used for a purpose not intended by its sender or shared with third parties.

Compliance with children’s online privacy protection act comprehends and realizes that Google, together with all other web browsers, must abide by any and all laws, of any and all States with the United States and abroad when anyone under the age of 18 years old is involved. confirms that it is law compliant. does not employ children to do any work on this web property or for the company itself. Children, i.e. natural persons below the age of 18, no matter whether they are emancipated or not, are not allowed to peruse, join, read, write or co-join this website. They are not allowed to contract, therefore, they are not allowed to purchase services and/or products from

Information Collection

Our company adheres to the privacy principles elaborated by the Interactive Advertising Bureau (IAB) and Direct Marketing Association (DMA). We do not collect any personally identifiable information (PII) from visitors. The Site Administration processes information about users, including their personal data, in order to carry out obligations to the users of the Site Administration for the use of the Site and its services offered. This Site is an advertising platform. Websites you are visiting has commissioned our company to act as an agent to deliver ads and report about advertising activity. The website you are visiting may be our customer or a website who is selling ad space to one of our customers. We receive information in two ways: information that you give us and information that we collect. The last one is information about the services that you use and how you use them. This information includes:

Internet protocol address

It is device event information, such as crashes, system activity, hardware settings, browser type, language of an Internet browser, the date and time of your request and referral URL. The Site can automatically identify the IP address and the domain name used by the User. All this information is duly recorded in a file server activity which allows subsequent processing of the data to obtain measurements only, statistics revealing the number of page impressions, amount of visits to web services, the order of visits, the access point, etc.

Cookies and anonymous identifiers

Like most internet sites, the Site may use cookies to improve user’s browsing experience and prevent them from seeing the same ads over and over again. This way we collect anonymous usage statistics via cookies and pixel tags. It is an industry standard technology used by numerous prominent websites. No personally attributable information is gathered or utilized in this process. Information collected may include: session data, geography, browser information, IP address, operating system type. Cookies are not used to personally identify you in any manner, nor will they harm your system or files. Cookies can also be used for Pixel tracking explained below.

Pixel Tracking

We use pixel tracking tags to measure usage statistics to secure correct delivery and efficiency of our customer’s advertising campaigns. Our customers can place pixel tags on their partner websites. These tags make it possible for our software to measure non-personal behavioral models to assess the effectiveness of advertising. No personally identifiable information is gathered during this process.

Audience Pixels

We use audience pixels in order to ensure that ads meet the interests of our users. Audience pixels information also helps our advertisers, ad networks, carriers and publisher web sites deliver ads and offers to the users within a certain segment. Audience pixels do not store any personally identifiable information.

Non-personal identification information

We may gether non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may embrace the browser name, the computer type, and tech-related information about Users means of connection to our Site, such as the OS and the Internet service provider’s used and other similar information.


The information presented in this Privacy Policy should not be interpreted as offering business, legal or other advice, or warranting as fail proof the integrity and security of information submitted via this Website. While all reasonable efforts are made to provide accurate, current and trustworthy information, admits the possibility of human and/or mechanical error and the probability that Users of the Site and other third parties may submit and/or publish information, graphics and images on the Site that are erroneous, misleading, or inaccurate.

Thus, makes no representations as to the accuracy, completeness, timeliness or suitability of the information provided on this Website, and rebuffs any expressed or implied warranty as to the same. For further disclaimers and limitations of liability of regarding your use of the Website and Service, see its Terms and Conditions.

Opting Out

To avoid storing information in your browser, you can easily deny, or opt out of cookies either by deleting them by you own hand or choosing to permanently opt out by clicking here from seeing advertisements matching your interests. In order to opt out, you should have cookies enabled. If you use a different computer, change web browsers or delete cookies, you will need to repeat the process. If you want to see ads tailored for you, please opt in again.

Information security

The Site uses security information schemes generally accepted by the industry, such as firewalls, access control procedures and cryptographic mechanisms, to block unauthorized access to personal data. As this, the User agrees that we recieve data for purposes of authentication of the identity for access control. All processes requiring the introduction of high personal protected data will be transmitted via safe communication protocol (https:// ...) and in no event the third party can obtain an access to this information transmitted electronically. We make our best efforts to protect our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information that we hold. We review our information collection, storage and processing practices, including physical security measures, to safeguard against unapproved access to systems.

While the Company has taken measures to protect your information, please be informed that (i) no computer system is immune from intrusion; and (ii) information transmitted to the Site may need to pass through multiple systems in order to process such information. Thus, we cannot guarantee the absolute safety or confidentiality of information transmitted to the Site and you hereby admit and assume the risks related to any such communication.

Sharing your personal information

We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic data not linked to any personal identification information concerning visitors and users with our business partners, trusted affiliates and advertisers for the purposes mentioned above.

We may use third party service providers to assist us in operating our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your data with such third parties for those restricted purposes, given that you have given us your permission.

Third party websites

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We exert no control over the content or links that appear on these sites and are not answerable for the practices used by websites linked to or from our Site. More than that, these sites or services, including their content and links, may be constantly changing.

These sites and services may offer their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

Use of Location Based-Services

Shine Dragon Group Limited and its partners and licensors may provide certain features or services through the Service that rely upon device-based location information. To provide such features or services, where available, Shine Dragon Group Limited and its partners and licensors may gather, use, transmit, process and maintain your location data, including the real-time geographic location of your device, and you hereby agree and consent to Shine Dragon Group Limited and its partners’ and licensors’ collection, use, transmission, processing and maintenance of such location data to provide such services.

In addition, by enabling and/or using any location-based services or features within the Service, you agree and consent to Shine Dragon Group Limited collecting, using, processing and maintaining information related to your account, and any devices registered thereunder, for purposes of providing such location-based service or feature to you. Such information may include, but is not limited to, your device ID and name, device type and real-time geographic location of your device at time of your request. You may withdraw this consent at any time by not using the location-based features on your device. When using third party services that use or provide location data as part of the Service, you are subject to and should review such third party’s terms and privacy policy on use of location data by such third party services. Any location data provided by the Service is not intended to be relied upon in situations where precise location information is needed or where erroneous, inaccurate, time-delayed or incomplete location data may lead to death, personal injury, property or environmental damage. Neither Shine Dragon Group Limited nor any of its content providers guarantees the availability, accuracy, completeness, reliability, or timeliness of location data or any other data displayed by the Service.


Ads appearing on our site may be served to Users by advertising partners, who may set cookies. These cookies make it possible for the ad server to recognize your computer each time they send you an online ad to compile non personal identification information about you or others who use your computer.

This information makes it possible for ad networks to, along with other things, serve targeted ads that they believe will be most interesting to you. This privacy policy does not encompass the use of cookies by any advertisers. Please contact our support team for more information.


If we ever send you information by e-mail regrding new products, services or information that you did not explicitly ask for, we will provide you with an email address by which you may request no further notices.


The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent, and stipulates tough penalties for violations. We collect your email address in order to:

  • Send information; respond to inquiries, and/or other requests or questions.
  • Process orders and to send information and updates pertaining to orders.
  • We may also send you additional information related to your product and/or service.
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM we agree to the following:

  • NOT use false or misleading subjects or email addresses
  • Identify the message as an advertisement in some reasonable way
  • Include the physical address of our business or site headquarters
  • Monitor third party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly
  • Allow users to unsubscribe by using the link at the bottom of each email

Fair Information Practices

The Fair Information Practices Principles form the spinal column of privacy law in the US and the principles they encompass have played an important part in the development of data protection laws globally. In order to be in line with Fair Information Practices, we will take the following responsive actions if a data breach occur:

We will notify the users via email

  • Within 7 business days

We will inform the users via in site notification

  • Within 7 business days

We also agree to the individual redress principle, which demands that individuals have a right to pursue legally enforcible rights against data collectors and processors who fail to abide by the law. This principle requires not only those individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

Changes to this Privacy Policy reserves the right to update this privacy policy at any time at its own discretion. When we do so, we will alter the updated date at the bottom of this page. We urge Users to check this page for any modifications to remain informed about how we protect the personal information we gather. You admit and agree that it is your responsibility to review this privacy policy from time to time and learn about modifications.

Changes to this Privacy Policy Regarding Transfer(s) of Ownership

You agree that if we transfer ownership or management of the Website or to a third party we may also transfer your Personal Information and any other data or information you have given to us to such third party, provided such third party agrees to observe and follow this Privacy Policy. may modify this Privacy Policy occasionally to correctly communicate how we gather and treat User information. We will publish any modifications made to this Privacy Policy on the Website and, where pertinent and practicable, inform you via e-mail. All modifications to the Privacy Policy will be effective upon posting to the Website. Please, make sure to regularly read our Privacy Policy carefully before using the Website. Continued use of the Website shall indicate your acceptance of any modifications made to this Privacy Policy.

Your acceptance of these terms

By using this Site, you express your acceptance of this policy and Terms and Conditions. If you do not agree to this policy, please do not use our Site. Your continued use of it following the posting of modifications to this policy will be viewed your acceptance of them.

Contact us

Shine Dragon Group Limited appreciates your comments and questions concerning this Statement of Privacy. If you believe that Shine Dragon Group Limited has not adhered to this Statement, please contact us at:


Key terms

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie makes it possible for that site to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function correctly without cookies.

IP address
Each computer connected to the Internet is assigned a unique number known as an Internet protocol (IP) address. In view of the fact that these numbers are usually designated and given in country-based blocks, an IP address can frequently be used to detect the country from which a computer is connecting to the Internet.

Non-personally identifiable information
This is information that is recorded about users so that it no longer indicates or makes references to an individually identifiable user.

Personal information
This is information provided by you to us, which personally identifies you, such as your name, e-mail address or billing information, or other data which can be linked to such information in a reasonable manner.

Pixel tag
A pixel tag is a type of technology placed on a website or within the body of an email to tack activity on websites, or when e-mails are opened or accessed, and is often used jointly with cookies.

Sensitive personal information
It is a special category of personal information related to private matters that include confidential medical facts, ethnic or racial origin, political convictions, religious beliefs or sexuality.

Unique device identifier
A unique device identifier is a string of characters that is incorporated into a device by its manufacturer and can be used to uniquely identify it. Different device identifiers differ from each other in how permanent they are, whether they can be reset by users and how they can be accessed. A given device may have several different and unique identifiers. Unique device identifiers can be used for various purposes, including security and fraud detection, syncing services such as a user’s e-mail inbox, remembering the user’s preferences and providing relevant advertising.

Effective as of September 27, 2018