CB Mobile Ltd., a Hong Kong company located at office at 3/F Jonsim Place 228 Queen's road, East Wanchai, Hong Kong (“CB Mobile“, “we,” “us,” and “our”), provides this privacy policy, because we believe that consumers of our service CleverPay should have clear ways to understand how information about them is collected and used by our services.

Introduction

CB Mobile’s provides SDKs to mobile app developers as a part of service CleverPay. These mobile SDKs permit app developers to manage in-app purchases and payment screens to their users. All of these services (further described in this privacy policy) are referred to collectively as our “Services,” and all of these developers are referred to collectively as our “Clients.”

This privacy policy (the “Privacy Policy”) explains how we may collect, use, store, and disclose information about the end users (“End Users”) of third-party mobile applications that use our Services. We also collect information on our corporate website(s), including any website on which this Privacy Policy is posted. We separately describe how we collect, use and share that website information (“CleverPay Website Information”).

Information We Collect with SDK

We refer to the information we collect from our SDKs as the ‘SDK Information.”

The SDK Information by Our Mobile SDKs includes (or may include) the following:

As noted above, we refer to all of the above collectively as the “SDK Information.”

How We Use the SDK Information

We use the SDK Information to provide a variety of Services to our Clients. This includes:

How we Use and Share Information Collected on the CleverPay Website

Website Information We Collect

We collect the following information from visitors to our websites (the “CleverPay Website Information”, including the website on which this Privacy Policy appears (“CleverPay Website(s)”):

Volunteered: You may share information with us on the CleverPay Websites when you request information from us, fill out a form on our website, or interact with us in other ways. This information may include personal information, such as your name, email address, and other contact information.

Passively Collected (e.g., Cookies and Unique IDs): We use automated mechanisms, such as cookies and other locally stored objects (such as “IndexedDB)”) that we associate with unique identifiers in order to keep track of visitor interactions with the CleverPay Websites. We may use third party-services such as Google Analytics, in which case those third parties gather information such as your IP address, browser type, the webpage from which you came to our website, and the times of your access to the CleverPay Website. In addition, as you browse our website, advertising cookies may be placed on your computer so that we can understand what you are interested in.

How We Use the CleverPay Website Information

In addition to the uses described above, we use the CleverPay Website Information (alone or in combination) to provide, market, and operate the CleverPay Websites and Services. Among other things, by collecting the CleverPay Website Information, we are able to

How We Share the CleverPay Website Information

We may share the CleverPay Website Information as follows:

Data Access and Retention

Generally speaking, we retain the SDK Information and Website Information for as long as necessary to achieve our objectives as detailed in this Privacy Policy, and to comply with our legal obligations, resolve disputes and enforce our agreements.

Data Security

We have administrative, technical, and physical safeguards in place in our physical facilities and in our computer systems, databases, and communications networks that are designed to protect information contained within our systems from loss, misuse, or alteration. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information and Non-Personal Information.

Data Breach Notification

If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on http://cleverpay.io if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us at admin@cleverpay.io.

Third Party Apps

We are not responsible for the privacy practices or disclosures of websites and applications that use our Services. Likewise, when you access the CleverPay Website, you may be directed to other websites that are also beyond our control. We encourage you to read the applicable privacy policies and terms and conditions of such third parties and websites, and the industry tools that we have referenced in this Privacy Policy. This Privacy Policy, however, only applies to the CleverPay Site and the Services.

Contacting Us

CB Mobile Limited (CB Mobile Ltd) Address: 3/F Jonsim Place 228 Queen's road, East Wanchai, Hong Kong

admin@cleverpay.io

Changes to This Privacy Policy

If we make material changes to our privacy policy that may impact you, we will prominently post notice of the change on our website for a period of at least 30 days prior to the change becoming effective. We recommend that you check the Privacy Policy frequently so that you are informed of any changes.

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