NextFrame

Privacy Policy

This Privacy Policy describes how Nextframe Ltd. (“Nextframe,” “we,” “us,” or “our”) collects, uses, shares, and otherwise processes personal information through our websites, services, content, and other digital properties that link to this Privacy Policy (collectively, the “Services”).


By using our Services, you acknowledge that your personal information will be handled as described in this Privacy Policy.


Information We Collect


We collect personal information in a variety of ways, including information you provide directly to us, information we collect automatically, and information we receive from third parties.


Information You Provide to Us


We may collect personal information you provide directly to us, such as when you contact us, communicate with us, subscribe to communications, participate in promotions or surveys, or otherwise interact with our Services. Depending on the context, this may include your name, email address, and any other information you choose to provide.


Information Collected Automatically


As is true of many digital properties, we and our third-party partners may automatically collect information you provide to us and information about your device and use of the Services when you visit or interact with them. We, and our third-party partners, use cookies and other tracking technologies, including pixels, SDKs, APIs, scripts, location-identifying technologies, and logging technologies, in connection with our Services to collect and store the information described in this section and elsewhere in this Privacy Policy.


The information automatically collected may include:


Device data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser ID, the URL entered, the referring page, date and time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during a visit. Device data may overlap with the other categories of data listed below.


Analytics and usage data, including the path taken to our Services, through our Services, and when exiting our Services, as well as usage and activity on or in connection with our Services, such as pages visited, links clicked, and videos watched. We may also collect metrics regarding emails we send, such as whether they are opened and whether attachments or links are opened, clicked, or viewed. We may use third-party tools to collect information you provide to us or information about how you use the Services, including mouse movements, scrolling, clicks, keystroke activity, and other browsing, search, or purchasing behavior. These tools may also record information you enter when you interact with our Services or engage in chat or other features.


Location data, including geographic location collected by us or our third-party providers, such as through permissions within your device operating system or browser functionality.


Advertising and advertising measurement data, including data associated with your viewing of, or clicking on, advertisements served on our Services, cookie IDs or other digital or proprietary identifiers assigned to your device, and device metadata, analytics and usage data, and location data, in each case for purposes of serving advertising, whether personalized or otherwise, or facilitating advertising measurement and attribution.


We and our third-party partners may combine information collected automatically with other information about you, including information you choose to provide.


Third-Party Sources


We also obtain personal information from third parties, which we may combine with personal information we collect either automatically or directly from you. For example, we may receive the same categories of personal information described above from the following third parties:


Other users who interact with our Services. We may receive your information from other users who interact with our Services.


Business partners. We may receive your information from our business partners, such as companies that offer products or services through our Services or through other properties, as well as marketing, advertising, and analytics partners, including third-party brands, agencies, or other partners that facilitate the buying and selling of advertising inventory, measure the effectiveness of advertising campaigns, or provide business analytics.


Social media networks. When you interact with our Services through social media networks, such as by logging in through a social network, liking a page, following an account, or sharing our content on services such as Google, Facebook, Instagram, Twitter, LinkedIn, or other social networks, we may receive information from those networks, including profile information and any other information you permit the network to share. We use this information to allow you to log in, communicate or interact on the social network, better understand the demographics of our visitors, and personalize content and advertising. You should review and, if necessary, adjust your privacy settings on third-party websites and social media platforms before sharing information or linking them to other services.


Authentication services. Some parts of our Services may allow you to log in through a third-party social network or authentication service such as Facebook or Google. These services may authenticate your identity and provide the option to share certain personal information with us, such as your name, email address, address book and contacts, or other information. The information we receive depends on that third party’s policies and your privacy settings on that third-party service. We use this information to authenticate your account, provide our Services, communicate with you, and support advertising and marketing activities.


Service providers. Our service providers that perform services on our behalf, such as payment processors, survey providers, and parties who conduct marketing, advertising, and analytics activities on our behalf, may collect personal information and may share some or all of that information with us.


Information providers. We may obtain information from third-party information providers to correct or supplement personal information we collect. For example, we may obtain updated contact information or demographic information, such as interests and preferences.


Other sources. We may also collect personal information from publicly available sources, third-party data providers, brand partnerships, or transactions such as mergers and acquisitions.


How We Use Personal Information


We use personal information we collect or receive for various purposes, including:


For marketing purposes. We may send you communications about new features, updates, products, and special offers. We may also use your information to serve advertisements about our products or other products or services that we, or our advertising partners, believe may interest you. We may also use individual and aggregated information to inform our marketing and advertising campaigns more broadly.


To monitor, improve, and develop our products and services. We may use your information to understand our users and tailor or optimize our Services. For example, we may analyze statistics and trends to improve our Services and to develop or better personalize our Services, features, or new offerings.


To protect the security and integrity of our business, comply with legal obligations, or as otherwise permitted by law. We may use your information to protect our company, our affiliates, our customers, and our Services. We may also use information to comply with laws, regulations, court orders, or other legal obligations; assist in investigations; protect and defend our rights and property, or the rights, property, or safety of others; enforce our Terms of Use, this Privacy Policy, or agreements with third parties; detect and prevent fraud; or for crime-prevention purposes or any other reason permitted by law. We may also use personal information in connection with corporate transactions such as mergers, acquisitions, joint ventures, financing, or sales of company assets, as well as insolvency, bankruptcy, or receivership proceedings.


For any other purposes with your consent, at your direction, or where notice is otherwise provided.


How We Share Personal Information


We may disclose personal information to third parties, including:


Third parties at your request. You may choose to share your activities on the Services with others through email, text, or social media networks.


Promotional partners. We may share information with third parties with whom we partner to provide contests, surveys, sweepstakes, or other joint promotional activities.


Marketing and strategic business partners. We may share information with marketing, advertising, analytics, and other business partners for purposes such as providing you with information, undertaking marketing and advertising activities, informing business analytics, or for other business or commercial purposes as described in this Privacy Policy or their privacy policies.


Online advertising partners. We may share information with third-party online advertising partners or permit them to collect information from you on our Services to facilitate online advertising and related measurement and attribution activities.


The public. When you provide feedback or post user content on our Services, such as comments on an article or on our social media pages, your information, such as your first name, last initial, state or country of residence, and your comments, may be displayed publicly. When you engage with us on social media, we may tag your social media account or the account of others.


With your consent, at your direction, or where notice is provided. In addition to the sharing described in this Privacy Policy, we may share information about you whenever you consent to or direct such sharing or where notice is otherwise provided.


Law enforcement, regulators, and others for legal reasons. Personal information may be disclosed to third parties as required by law, subpoena, or legal process, or if we reasonably believe such action is necessary to comply with the law and reasonable requests of law enforcement, enforce our Terms of Use, protect the security or integrity of our Services, or exercise or protect the rights, property, or personal safety of our organization, our users, or others.


We may also share information in aggregated or otherwise anonymized form that does not reasonably identify you.


Third-Party Data Collection and Online Advertising Practices

General


We and our third-party partners use information that we receive about you, including information you provide to us, information about your use of the Services, and information received from third parties, to serve advertisements more relevant to your interests, the content on which the ads will appear, or audiences similar to you, to optimize marketing and advertising campaigns more broadly, and to generate analytics and provide advertising-related services such as reporting, market research, and measurement or attribution.


These third-party partners may include advertising networks or exchanges, measurement and attribution companies, ad fraud verification companies, social media companies, and other advertising technology services.


How We Collect This Information


The information used for these advertising practices is typically collected through tracking technologies such as cookies, web beacons, pixels, SDKs, APIs, embedded scripts, location-identifying technologies, logging technologies, and similar tools. These technologies may recognize the device you are using and collect information including clickstream data, browser type, time and date of visit, mobile advertising ID or other digital identifier, geolocation, and other information described in this Privacy Policy. These tools may also collect information you provide to us or information about how you use the Services, such as mouse movements, scrolling, clicks, keystroke activity, browsing, search, or purchasing behavior. They may also record information you enter when you interact with our Services or engage in chat or other features.


We may share a common account identifier, such as a hashed or encrypted email address or user ID, or other information such as a hashed or encrypted phone number, with our third-party advertising partners to help identify you across devices. We may share this information using methods such as APIs, direct file uploads, server-to-server transfers, or integrated tracking technologies such as pixels.


How to Exercise Your Choices Regarding Online Ads


Please see the section titled “What Controls Do I Have Over My Information?” below to learn how you can opt out of interest-based advertising.


Social Media Platforms and Advertising


Our Services may include social media features such as Facebook “Like” buttons, Pinterest, Instagram, Twitter, LinkedIn, and similar widgets. These social media companies may recognize you and collect information about your visit to our Services and may set a cookie or use other tracking technologies. Your interactions with those features are governed by the privacy policies of the companies providing them.


We may also display targeted advertising to you through social media platforms. For example, these companies may offer interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Services or to groups of users who share similar characteristics. We may share a unique identifier, such as a hashed or encrypted email address, phone number, or user ID, with these platform providers, or they may collect information from our website visitors through a pixel, API, direct file upload, or server-to-server integration, in order to direct targeted advertising to you or to custom or lookalike audiences on those platforms. These advertisements are governed by the privacy policies of the respective social media companies. If you do not want to receive targeted advertising on social networks, you may be able to adjust your advertising preferences in your account settings on those platforms.


What Controls Do I Have Over My Information?


You may control your information in the following ways:


Access, Modification, or Deletion of Your Information


You may have the right to request access to your personal information, correction of inaccurate or incomplete personal information, or deletion of your personal information. To better protect the security of your personal information, we may seek to verify your identity before processing your request.


Under certain circumstances, we may not fulfill your request, such as where we are unable to verify your identity or where the information is subject to legal, regulatory, audit, record-keeping, or other obligations or exceptions. In any event, we will respond within a reasonable timeframe and in accordance with applicable law.


To make such a request, please contact us at support@nextframehq.com

.


Marketing Email Preferences


You can manage your preferences for marketing emails by:


using the unsubscribe link at the bottom of those messages; or

updating your preferences through any email preferences page we may provide.


If you no longer want to receive third-party marketing emails that you requested through our Services, you should follow the unsubscribe or opt-out instructions included in those emails from the relevant third party.


Cookies and Other Tracking Technologies


To manage cookies, you may be able to change your browser settings to:


notify you when you receive a cookie, so you can choose whether to accept it;

disable existing cookies; or

automatically reject cookies, including some third-party cookies.


Similar controls may exist for other tracking technologies such as pixels, SDKs, and local storage. Please check your device or browser settings and related documentation for more information.


Restricting the use of these technologies may negatively impact your experience using our Services, as some features may be less personalized or may not function properly. Depending on your device and operating system, you may not be able to delete or block all cookies or other tracking technologies described in this Privacy Policy. If you wish to reject cookies across browsers and devices, you must do so on each browser and device you use.


Online Ads


To learn more about interest-based advertising and how you may be able to opt out of some of it, you may wish to visit the following resources, where available in your region:


the Digital Advertising Alliance at aboutads.info/choices;

the European Interactive Digital Advertising Alliance at youronlinechoices.eu; or

the Network Advertising Initiative at networkadvertising.org/choices.


You may also be able to opt out of some interest-based advertisements in mobile applications through aboutads.info/appchoices.


How We Protect Personal Information


We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. However, no security system is impenetrable, and we cannot guarantee the security of our systems at all times. You therefore assume some risk when providing information through any digital property, including our Services.


Links to Third-Party Websites or Services


Our Services may contain links to websites or other digital properties controlled by third parties. Those third-party properties may have their own privacy notices or policies, which we encourage you to review. We are not responsible for the content, terms of use, or privacy practices of third-party properties that we do not own or control.


Children’s Privacy


Our Services are not designed or intended for use by children, and we do not knowingly collect or solicit personal information from children under the age of 16, or the equivalent minimum age in the relevant jurisdiction. If we become aware that we have inadvertently collected personal information from a child under that age, we will take steps to delete such information promptly. If you believe that we may have collected information from a child under 16, please contact us at support@nextframehq.com

.


International Users


Your personal information may be stored in, transferred to, and processed in Hong Kong, the United States, and any other country in which Nextframe Ltd., its affiliates, or its service providers maintain facilities. Data protection laws in these countries may differ from those in your country of residence. Where required by applicable law, we take appropriate steps to provide safeguards for cross-border transfers of personal information.


If you have questions or would like more information about international transfers of your personal information and the safeguards used, please contact us at support@nextframehq.com

.


Changes to This Privacy Policy


We may update this Privacy Policy from time to time to reflect changes in our privacy practices. If we make material changes, we will update the “Last updated” date at the top of this Privacy Policy and may provide additional notice where required or appropriate. We encourage you to review this page periodically for the latest information about our privacy practices.


How to Contact Us


If you have any questions about this Privacy Policy or our privacy practices, you may contact us at:


Nextframe Ltd.

RM D07, 8/F, Kai Tak Factory Building, No. 99 King Fuk Street, San Po Kong

Hong Kong


Email: support@nextframehq.com


If you are a California, Colorado, Connecticut, Utah, or Virginia resident making an inquiry regarding your privacy rights under applicable U.S. state privacy laws, please include “U.S. Privacy Rights Request” in the subject line of your email.


If you are located in the European Economic Area, the United Kingdom, or Switzerland and are inquiring about your rights under the GDPR or other applicable privacy laws, please include “GDPR Privacy Rights Request” in the subject line of your email.


U.S. State Privacy Notice


This U.S. State Privacy Notice supplements the information contained in this Privacy Policy for residents of U.S. states with applicable privacy laws, and for Nevada residents as described in the section titled “Notice to Nevada Residents.” The term “State Privacy Laws” includes, where applicable, the California Consumer Privacy Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act.


Your Privacy Rights


Depending on your state of residence, you may have the following rights, subject to limitations and exceptions under applicable law:


Right to Access


You may have the right to confirm whether we are processing your personal information and to access that personal information. You may also have the right to access your personal information in a portable and readily usable format where technically feasible.


For California residents, this may include the right to request:


the specific pieces of personal information we have collected about you;

the categories of personal information collected;

the categories of sources from which personal information is collected;

the business or commercial purposes for collecting, selling, or sharing personal information; and

the categories of third parties to whom personal information is disclosed.

Right to Deletion


You may have the right to request deletion of personal information we have collected from you, subject to certain exceptions.


Right to Correction


You may have the right to request correction of inaccurate personal information, taking into account the nature of the information and the purposes of the processing.


Opt-Out Rights


Depending on applicable law, you may have the right to opt out of the sale or sharing of personal information, targeted advertising, or certain uses or disclosures of sensitive personal information.


As described in this Privacy Policy, we may disclose the following categories of personal information to advertising, marketing, and analytics partners for advertising and marketing purposes:


identifiers;

commercial information;

geolocation data;

internet or network information; and

information that may be considered sensitive personal information under certain laws.


To exercise applicable opt-out rights, please contact us at support@nextframehq.com

.


Non-Discrimination and Appeals


You have the right not to receive discriminatory treatment for exercising applicable privacy rights. However, if exercising those rights limits our ability to process personal information, we may no longer be able to provide you with certain products, services, or features in the same manner.


Residents of certain states, including Colorado, Connecticut, and Virginia, may have the right to appeal a decision we make regarding a rights request. Appeals may be submitted by email to support@nextframehq.com

 together with a copy of the decision being appealed.


Authorized Agents


Where permitted by applicable law, you may use an authorized agent to submit privacy requests on your behalf, provided we can verify the agent’s authority to act for you.


Where required, we may request documentation such as:


a valid power of attorney under applicable law; or

sufficient evidence showing that you provided the authorized agent signed permission to act on your behalf and that you verified your identity directly with us.


For opt-out requests submitted by an authorized agent, we may require signed permission demonstrating that the agent has been authorized to act on your behalf.


Deidentified Information


Where we process deidentified information and are required to maintain it in deidentified form, we will maintain and use that information in deidentified form and will not attempt to reidentify it, except as permitted or required by applicable law.


Notice at Collection for California Residents


For California residents, in the preceding 12 months we may have collected the following categories of personal information:


Identifiers, such as name, email address, online identifiers, or similar identifiers.

California customer records information, such as contact details and payment information.

Protected classification characteristics, such as age or gender where provided.

Commercial information, such as purchase history.

Internet or network information, such as device information, logs, and analytics data.

Geolocation data, such as approximate location derived from IP address or device signals.

Professional or employment information, where relevant.

Other personal information, such as content you post on social media pages or otherwise provide to us.

Inferences, such as predictions about interests and preferences.

Sensitive personal information, where applicable under law.

Sales and Shares


In the previous 12 months, we may have sold or shared the following categories of personal information with advertising, marketing, and analytics partners for advertising and analytics purposes, subject to your right to opt out:


identifiers;

commercial information;

geolocation data;

internet or network information; and

information that may be considered sensitive personal information.

Data Retention


We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. In many situations, we must retain all or part of your personal information to comply with legal obligations, resolve disputes, enforce agreements, protect against fraudulent, deceptive, or illegal activity, or for other business purposes.


Notice of Financial Incentives


We may offer financial incentives related to the collection, sale, retention, or use of personal information as permitted by applicable law. These incentives may result in different prices, rates, or quality levels. Any material terms of such financial incentive programs will be provided at the time you are offered the program.


Participation in such programs is optional. You must affirmatively opt in, and you may opt out at any time by following the instructions provided in the applicable program terms.


Notice to Nevada Residents


Nevada law may permit residents to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To exercise any applicable Nevada opt-out rights, please contact us at support@nextframehq.com

.


European Privacy Notice


This European Privacy Notice supplements the information contained in this Privacy Policy and applies solely to individuals located in the European Economic Area, the United Kingdom, or Switzerland, and to the Services made available to them.


Controller of Your Personal Data


The controller of your personal data under this European Privacy Notice is:


Nextframe Ltd.

RM D07, 8/F, Kai Tak Factory Building, No. 99 King Fuk Street, San Po Kong

Hong Kong


For privacy-related questions, you may contact us at support@nextframehq.com

.


Legal Bases for Using Personal Data


We process your personal data only where we have a valid legal basis to do so, including:


to comply with legal and regulatory obligations;

where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract;

for our legitimate interests or those of a third party, where those interests are not overridden by your rights and freedoms; and

where you have provided consent.

Purposes for Processing and Legal Bases


We may process personal data for the following purposes and on the following legal bases:


To provide products and services you request. Processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.


To respond to requests, questions, comments, and provide support. Processing is necessary to take steps at your request or to perform a contract with you.


To send marketing communications or direct you to portions of our Services or other websites that may interest you. Where required by law, we rely on your consent for electronic marketing communications. In other cases, we rely on our legitimate interests in marketing our products and services.


To communicate with you about and administer events, programs, contests, promotions, or similar activities. Where required, we rely on consent; otherwise, we rely on our legitimate interests.


To carry out, evaluate, and improve our business. This may include developing new features, analyzing and enhancing user experience, optimizing and assessing the effectiveness of marketing and advertising, and managing communications. We rely on our legitimate interests for this processing.


To perform data analytics regarding use of the Services. This may include market and customer research, trend analysis, financial analysis, and pseudonymization or anonymization of personal data. We rely on our legitimate interests.


To serve advertising, content, and offers based on your interests and online activities. Where required by law, we rely on your consent.


To enable our affiliates or service providers to perform activities on our behalf. We rely on contractual necessity and, where applicable, our legitimate interests in operating our business efficiently.


To notify you of changes to the Services that may affect you. Processing may be necessary to perform a contract with you or to comply with legal obligations.


To comply with law, legal process, or regulatory requests; protect against harm, fraud, and illegal activity; and in connection with corporate transactions. We rely on our legal obligations, legitimate interests, and, where applicable, the public interest.


International Transfers


Some processing of your personal data may involve transferring your data outside the EEA, the UK, or Switzerland, including to Hong Kong and the United States. Where personal data is transferred to a country that has not been recognized as providing an adequate level of protection, we take steps to provide appropriate safeguards in accordance with applicable law, which may include entering into standard contractual clauses or relying on other lawful transfer mechanisms.


Retention of Personal Data


We will retain your personal data only for as long as necessary for the purposes for which it was collected, including to enable you to use the Services, comply with legal obligations, resolve disputes, and enforce our agreements.


Data Subject Rights


If you are located in the EEA, the UK, or Switzerland, you may have the following rights in relation to your personal data, subject to applicable law:


the right of access;

the right to rectification;

the right to erasure;

the right to withdraw consent;

the right to lodge a complaint with a supervisory authority;

the right to restriction of processing;

the right to data portability; and

the right to object to processing.

How to Exercise These Rights


To exercise any of these rights, please contact us at support@nextframehq.com

.


Please note that these rights are not absolute, and we may refuse a request in whole or in part where an exception under applicable law applies.


You also have the right to lodge a complaint with your local data protection authority.

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