Privacy Policy

Last updated: November 10, 2026

Introduction

This Privacy Policy explains how Royal Ridge Trade Limited ("CinubarerSolution", "we", "our", or "us") collects, uses, shares, and protects information when you use the CinubarerSolution platform, websites, and related services (the "Services"). For the purposes of the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"), the data user of your personal data is Royal Ridge Trade Limited. By using the Services, you acknowledge this policy. If you do not agree with it, please do not use the Services.

1. Information we collect

1.1 Information you provide

• Account information: name, company name, work email, country, and password credentials when you register.
• Account verification details: information we ask for to confirm that an account is genuine and used for legitimate advertising, where required.
• Campaign content: campaign settings, budgets, creative assets, audience definitions, and reporting preferences you configure in the platform.
• Communications: the content of support requests, contact form messages, and feedback you send us.

1.2 Information collected automatically

• Usage data: pages viewed, features used, session activity, and timestamps within your workspace.
• Device and connection data: IP address, browser type, device type, operating system, and approximate location derived from IP.
• Cookies and similar technologies: necessary cookies for sign-in and session security, plus analytics, advertising, and functionality cookies where you consent to them.

1.3 Information from advertising activity

• Delivery data: impressions, clicks, and completion events associated with campaigns you run.
• Audience and measurement data: audience segments and conversion events you choose to connect, processed to report on campaign performance.

2. How we use information

• To provide, operate, and maintain the Services.
• To deliver, pace, and measure the campaigns you configure.
• To generate reports, dashboards, and audience insights for your workspace.
• To verify accounts and prevent misuse, fraud, and invalid activity.
• To respond to support requests and communicate about your account.
• To improve the platform, including debugging, testing, and product development.
• To send product updates and marketing communications, where permitted and with consent where required.
• To meet legal, regulatory, and contractual obligations.

3. Legal bases and direct marketing

We process personal data for the purposes described in this policy and in line with the PDPO, including the purpose-limitation and use-limitation principles. Where we rely on consent — for example for non-essential cookies or marketing communications — you can withdraw that consent at any time.

We will not use your personal data for direct marketing without your consent or your indication of no objection, and we provide an opt-out mechanism for marketing communications in line with Part 6A of the PDPO.

4. Sharing information

We do not sell personal data. We share information only as needed to run the Services:

• Service providers: hosting, data storage, analytics, email delivery, and customer support tools that process information on our behalf under contract.
• Delivery and measurement partners: partners involved in serving or measuring campaigns you choose to run.
• Fraud and security providers: partners that help filter invalid traffic and protect the platform.
• Legal and regulatory: where required by law, court order, or a valid governmental request.
• Business transfers: in connection with a merger, acquisition, or transfer of assets, subject to this policy.
• With your direction: where you ask us to share information with a third party.

5. Cookies and your choices

We use necessary cookies to keep you signed in and to secure sessions. With your consent, we also use analytics, advertising, and functionality cookies. You can accept, reject, or customise these categories at any time using the Cookie Settings link in the footer, or through your browser settings.

6. Data security

We apply technical and organisational measures designed to protect personal data against unauthorised access, loss, or misuse. These measures may include, for example:

• encryption of data in transit and at rest where appropriate;
• role-based access controls and least-privilege administration;
• logging of workspace and administrative activity;
• vulnerability management and security testing on a scheduled cadence;
• security and privacy training for team members.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Data retention

We keep personal data for as long as needed to provide the Services and for legitimate business or legal purposes, such as maintaining records, resolving disputes, and meeting legal obligations. When data is no longer needed, we delete or de-identify it.

8. Your rights

Under the PDPO, you have the right to request access to and correction of the personal data we hold about you. To make a data access request or a correction request, contact privacy@cinubarer.com. We will respond within the timeframe required by applicable law.

If you believe your personal data has been mishandled, you may contact the Office of the Privacy Commissioner for Personal Data ("PCPD") in Hong Kong. Where other data protection laws apply — for example the EU GDPR, or US state privacy laws such as the CCPA/CPRA — we handle rights requests in accordance with those laws as well.

9. International transfers

Information may be transferred to and processed in countries other than Hong Kong, including where our service providers operate. Where personal data is transferred outside Hong Kong, we put contractual and organisational safeguards in place and review how the recipient handles the data.

10. Children

The Services are intended for business use and are not directed to children. We do not knowingly collect personal data from children.

11. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be announced through the platform or by email, and the "last updated" date will be revised.