Privacy Protection and User Agreement

Version：202203

ComRatings is a cloud-based digital audience analytics company that helps companies and brands improve their marketing based on insights from the online behaviors and overall profiles of many consumers like you who have joined our panels. Leading advertisers, agencies and publishers rely on ComRatings’s analytics services to create engaging online experiences and effective advertising campaigns. For more information, please visit http://www.comratings.com/.

This agreement describes our data collection and use practices for consumers who download ComTracker software – the data collection application (the “Software”) that includes differing specific APPs, such as Quick APP, iReward APP, Huijifen APP, etc. The Software may have been installed through the partner website, or through a partner’s software product with which the Software was bundled. This privacy policy applies only to the operation of the Software and not to any other application, website or service. While we encourage our partners to comply with best practices regarding consumer privacy, we are not responsible for the privacy practices of any third party product with which the Software may be bundled.

This privacy policy is divided into the following sub-topics. If you have any additional questions, you may reach us at info@comratings.com

Information Collection

We only collect the non-personally identifiable information from you as described below.

Our Software primarily collects ‘clickstream data’. Clickstream data is information generated by you and your computer while surfing the Internet and interacting with various sites and services.

In greater detail, the Software collects the following types of information:

1. Online browsing: This includes the sites you visit, including news sites or social networks, and your interactions with those sites.
2. Online activities: This includes the search terms you enter and the results of such searches, the videos you view, the products you shop for online, information you enter into forms, the materials you download or upload, the advertisements you see, information and content on web pages you visit and with which you.
3. 3. System information: This includes information about the computer and browser that you are running on, including the IP address of the computer, how the Software is operating, and which other applications are installed or running.

Protecting Personal & Sensitive Information; Information Filtering

The Software and our internal systems are outfitted with technical privacy rules designed to avoid the collection of certain types of personally identifiable and sensitive information that can be identified by the Software and systems, such as credit card numbers, email addresses and information from most web-based email accounts.

As part of our security program, we conduct regular checks to update and refresh these rules that filter personally identifiable and sensitive information.

When your information is sent over the public Internet by the Software, it is transmitted through a secure means of encryption. This is to protect against the information we collect from of our panelists being improperly accessed by third parties during such transmission.

Information Use and Sharing

This section describes how your data – which includes web use, demographic information, and information we have obtained from third parties – contributes to the kinds of services our clients buy from us.

Our typical process is to combine panel members’ data into consumer segments and report on the aggregated (or grouped) results. Consumer segments are pools of users who have common interests or characteristics, for example, “women between the ages of 28-34 interested in travel websites.” Once aggregated, the results and consumer segments are shared with our clients and other parties. On some occasions, we may share non-aggregated results for limited purposes. The following are examples of the kinds of services we provide, and how your data is used in these services:

Consumer Analysis – We may use your data, including personally identifiable information you have provided or we obtained directly or through a trusted third party vendor, to enhance our or our customer’s consumer segments explained above.

Advertising Research – Your data is combined with data from other users into a pool that is then analyzed for exposure to certain advertising. Information about the combined pool, which does not identify any particular user, is shared with clients so they can understand if and how their advertising spending impacts the consumer journey and consumer decisions. For example, by comparing the behaviors of a group of users who saw a particular online advertisement with another group of users who did not see that advertisement, ComRatings can help advertisers understand the effectiveness of their ads.

Media Use Analysis – Your data is combined with data from other users to form consumer segments that are shared with clients without identifying any particular user. These segments are typically analyzed on behalf of clients to understand where consumers go online and how consumers interact with digital media, which includes website content and advertising that they see. For example, we help companies understand the effectiveness of their websites by comparing how users are interacting with their websites versus how users are interacting with their competitors’ websites.

Targeted Surveys – If you join one of our partners’ survey panels, we may send you invitations to participate in surveys on the basis of your online behaviors collected by the Software. For example, if you visit sites that suggest you enjoy travel, we may send you a survey regarding travel services.

Children’s Privacy

For the majority of our recruitment, the ComRatings research panel consists of users who are of the legal age of majority within their geography. On occasion, we may recruit children for a non-adult panel for custom research. In these cases of non-adult recruitment, we will obtain parental consent and adhere to the appropriate data laws and regulation.

Additional Disclosures for your Information

In the event ComRatings goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your information may be among the assets transferred.

We also reserve the right to disclose your information as required by law, court order, or legal process served on us, when we believe that disclosure is necessary to protect our rights, or to combat suspected fraudulent activities.

The 3^rd Party Certification

ComRatings has been certified by third party organization of VeriSign for the data process.

Data Security

We have put in place reasonable administrative, technical, and physical safeguards to protect against unauthorized access to the information we collect. However, no security measures are 100% impenetrable and we cannot guarantee against all potential security breaches. Moreover, the transmission of information over the Internet is not inherently secure, and we are not responsible for the transmission of information over networks that we do not control. Your use of our Software demonstrates your assumption of these risks.

Data Retention

We will retain the information described above for as long as the information has value as part of the services we offer to our clients , or as long as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, whichever is longer. If you cancel your account by following the directions to remove the Software, we no longer will collect data from you but we will retain and continue to use your data collected prior to your removal of the Software.

Data Storage for China Market and Other Markets

Our servers are maintained in differing countries. By using the Software, you freely and specifically give us your consent to export your information to the servers in your country, and to store and use it in your residential country as specified in this privacy policy.

Data from EU residents

ComRatings complies with the European Union regulations regarding the collection, use, and retention of personal data from EU member countries and Switzerland.

How to Uninstall the Software

For users who have downloaded the Software directly from ComRatings, you can opt-out of the ComRatings research panel at any time by removing the Software from your device.