Menta Platform Privacy Policy

Updated on June 28, 2024

You (including developers and terminal users who use developer applications, the same below) are welcome to use the Menta platform services!

Menta platform is a technical service platform that provides promotion or information content display for Developers (hereinafter referred to as "developers"). Developers in their applications (including but not limited to mobile applications, mobile websites, application platforms, PC websites, sites, applets and other terminals that can provide services confirmed by the Menta platform,After the products or services of the Menta platform are integrated in), relevant content can be provided to its application end users (hereinafter referred to as "terminal user") through the Menta platform. Developers integrate the service tools provided by the Menta platform into their applications, and entrust the Menta platform to process relevant data information in the developer's applications,This may include personal information of the end user of the developer's application (the "terminal user"). We attach great importance to personal information and privacy protection. We will adopt security protection measures in accordance with laws and regulations to protect the personal information and privacy of terminal users.

In view of this, Menta Platform (hereinafter referred to as "we" or "Company") has formulated this Privacy Policy (hereinafter referred to as "this Policy/this Privacy Policy"). This Privacy Policy is intended to help developers and end users understand how we collect, use, store, share, process and protect personal information that end users provide to us,And the manner in which we provide end users with access to, delete, correct, withdraw authorized consent, and protect such information.

Before using the products or services of the Menta platform, please be sure to carefully read and thoroughly understand this policy. Among them, we have indicated the important contents such as the terms and conditions of the personal information rights and interests of the end users in bold form, so please pay special attention to them. Please be sure to read this privacy policy carefully, and integrate the service tools provided by the Menta platform and/or use the products and services of the Menta platform after confirming full understanding and consent.Once you start to use the service tools and/or products or services provided by the Menta platform, you have fully understood and agreed to this policy.

In order to further improve our privacy policy and services, we will revise this privacy policy from time to time. In the event of a material change to this Privacy Policy, we will make an announcement via the Menta website before the new Privacy Policy takes effect.

Data protection and guaranteeing the trust of business partners and you are at the heart of Menta's business principles. As a result, compliance with applicable data protection regulations is an important task for us and this policy has been updated to meet the requirements of applicable data protection laws, including the European Union General Data Protection Regulation ("GDPR"), the United States Children's Online Privacy Protection Act ("COPPA"), the California Consumer Privacy Act ("CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), the Utah Consumer Privacy Act ("UCPA"), the Connecticut Data Protection Act ("CDPA"), the Brazilian General Data Protection Act ("LGPD"), and other laws and regulations related to the protection of personal information.To the extent that our cooperation with you is subject to European data protection law, Menta is the data controller of your personal information under European data protection law. For the purposes of this Privacy Policy, processors under GDPR, VCDPA, CPA, CDPA and UCPA ("processors"),Service providers under the CCPA ("Service providers"), and "personal information processors" refer to controllers under the GPR, VCDPA, CPA, CDPA and UCPA ("controllers"), companies under the CCPA ("businesses").

In order to facilitate your reading and understanding, we have defined the specific terms. Please refer to the "Appendix 1: Definitions" of this privacy policy for the specific content of these definitions.

Special Notes:

If developers integrate the services provided by the Menta Platform into their applications or use the products or services provided by the Menta Platform in any form, the developers shall commit:
- The Developer shall comply with all applicable laws, policies and regulations relating to the collection and use of End User's Personal Information to protect the security of User's Personal Information. If the developer believes that the use of the Menta platform products or services will cause the developer's application to not comply with applicable laws, policies and regulations, the developer can contact the Menta platform,You can also discontinue products or services that use the Menta platform.
- The developer shall inform the end user of the integration of the products or services of the Menta platform in its application, and the collection, use, storage, sharing, processing and protection rules of the personal information necessary for the end user by using the products or services of the Menta platform (I. E. This privacy policy), in a prominent position of its application or in other ways that can reach the end user (including but not limited: provide a link to this privacy policy for end users to view in a prominent place in the user agreement or privacy policy of its application),And obtain the complete, legal and effective authorization consent of the end user for the collection, use, storage, sharing and processing of personal information related to the end user during the use of the products or services of the Menta platform. If the developer's application provides personalized recommend functions or services, the developer shall, in accordance with the relevant requirements of laws, regulations or supervision,Clearly inform the end user, prominently identify the promotion or information of the personalized recommend, and provide the end user with the option to turn off or exit the function or service in its application. If the developer's application end user is a minor under the age of 14, the developer must ensure that the end user's parents or other guardians collect, use, store, share, transfer (if applicable) the end user's personal information related to the Menta platform products or services. Complete, legal, and valid authorization consent during the use of Menta platform products or services.
- Developers should provide end users with easy-to-operate mechanisms to access, correct, delete their personal information, revoke or change their authorization consent, and cancel their personal accounts.
- Developers should ensure that end users or regulatory authorities will not collect, use, store, share, process, disclose their information in accordance with the provisions of this privacy policy against us in any form of demands, requests, complaints, penalties, etc. Such as the developer's end users due to the collection, use, storage, sharing, processing and disclosure of their information under this privacy policy, resulting in any form of claims, demands, complaints, penalties, etc,The developer will be responsible for the full settlement; If it causes us to have a corresponding form of loss, the developer will be responsible for giving us full compensation.
We hope that developer applications that integrate Menta platform products or services collect and use personal information of end users in a legal and compliant manner, but we do not know and cannot control how any developers and their applications use the personal information of end users they control. Therefore, they should not be responsible for their behavior.We recommend that end users carefully read the user agreement and privacy policy related to the developer application, and confirm that they fully understand and agree how they collect, use, store, share, and process end users' personal information before using the developer application.
This Privacy Policy does not apply to services provided by third parties that are displayed on our Services, linked to our Services, or re-packaged with those third party privacy policies that apply to our Services. Although third parties display, link to or re-package our services, we do not know or control their behavior, and therefore are not responsible for their behavior.Developers and end users are requested to exercise caution in accessing or using their services until they have reviewed and accepted their privacy policies.
The content of the Menta platform product or service specifically obtained by the end user is selected by the developer according to its application needs, and may vary depending on the mobile phone model, system version and developer application used by the end user. The personal information that the Menta platform product or service may obtain depends on the specific type/version of the developer application used by the end user and the function used by the end user.If certain services are not covered or specific functions are not provided in some developer application versions, the content of this privacy policy relating to the above services/functions and related personal information will not apply.

Please developers and terminal users must read this privacy policy carefully, and integrate and use the products or services of the Menta platform after confirming full understanding and consent.

We value the trust that terminal users place in us when providing us with terminal users personal information, and we will treat end user personal information and protect the security of terminal users information in accordance with this Privacy Policy.

How we collect and use personal information

Personal information refers to all kinds of information recorded in electronic or other ways that can identify the identity of the end user or reflect the activities of the end user alone or in combination with other information. In accordance with the principles of legality, legitimacy and necessity, we only collect information necessary for the realization of product functions. In your use of Menta Platform products or services,The Menta Platform collects and uses your personal information for the following purposes described in this Privacy Policy in accordance with the principles of lawfulness, rightfulness and necessity:

（1）help developers register, log in and use the Menta platform service platform

Developers who use our services can log into a registered Menta platform account. When registering the Menta platform account, the developer needs to provide us with information including but not limited to the following information: user name, contact name, company name, application name and URL, email, contact address, mobile phone number, receiving bank and account number,And create a password. This information is collected to help developers complete registration and enjoy the service in cooperation with the Menta platform.

（2）Personal information we may collect

Personal information involved in the use of MentaSDK functions and services

Location Information	[Optional information] Country, time zone and location (country and preferred language)
Device/Ad ID	[Necessary information] Android ID, OAID, IDFV, mobile advertising identifier (such as Apple IDFA, Google ad ID) [Optional information] International Mobile Equipment Identity (IMEI), MAC address, International Mobile Subscriber Identity (IMSI)
Device Information	[Necessary Information] Equipment manufacturer, equipment model, equipment operating system information, equipment type, equipment screen information, equipment network information, hardware serial number, equipment sensor information, restricted advertisement tracking (LAT) status, mobile phone startup time, mobile phone user name summary, equipment storage capacity information [Optional information] CPU type, device battery information, device volume and font size, whether it is a simulator, system Build type, system Build label, system Build user, Radio firmware version, system startup program version number, hardware name, host address, system development code number, system source control version number,Device display version number, device board name
Application message	[Required information] application package name, application version, features, and SDK version of the Menta partner [Optional information] Whether it is downloaded from the application store and the list of installed applications; Special Note: For download advertisements, we will judge whether you have installed the products promoted by the advertisement before displaying them. If you have installed them, we will not display the advertisement (we call it display filtering), and notify the server not to return the corresponding advertisement when your device requests the advertisement next time, thus improving the user experience.In this scenario, Menta will only report the information about the ads that are "displayed and filtered" and will not collect the information about other installed applications.
Use data	[Required Information] When you interact with an advertisement promoted by us, we will collect information about your interaction with the advertisement, such as browsing and clicking on the advertisement.
Other Information	[Optional Information] Device event information (such as system crash, system activity), timestamp, date and time of your request and source URL, user agent.

Permission Request

Special note: If you use a developer application integrated with the Menta SDK, the Menta SDK will apply for the corresponding permission through the developer application. The developer shall inform you of the Menta SDK, subject name, type and purpose of processing personal information, privacy policy, etc., and can use the Menta SDK to carry out relevant business functions after obtaining your consent.There may be some differences between the information fields collected by different SDK versions and whether they are optional. The collection information is based on the SDK version accessed by the developer application. The developer must ensure that the user agrees to the Privacy Policy Before initializing the Menta SDK. The Menta SDK users will not collect information and apply for permission until they agree to the privacy policy.

Android operating system application permissions list:

Jurisdiction	Function	USES AND PURPOSES	Timing of invocation
INTERNET mobile phone network request	[Optional] Mobile phone network	For online advertising service requests	After the user clicks agree to the privacy policy, the developer calls the SDK function that requires this permission
ACCESS_WIFI_STATE and ACCESS_NETWORK_STATE get WIFI network changes	[Optional] Monitor WIFI network changes	For online advertising service policy updates	After the user clicks agree to the privacy policy, the developer calls the SDK function that requires this permission
AD_ID mobile phone Google ads Id	[Optional] Permission to Obtain Google Advertising Id on Mobile Phone	Advertising and advertising monitoring attribution, anti-cheating	After the user clicks agree to the privacy policy, the developer calls the SDK function that requires this permission

iOS operating system application permissions list:

Jurisdiction	Function	USES AND PURPOSES	Timing of invocation
NSUserTrackingUsageDescription	[Optional] Obtain device identification to identify device information	Advertising and anti-cheating	After the user clicks agree to the privacy policy, the developer calls the SDK function that requires this permission

When you browse, click on the advertisement we promote, download and use the product (such as application) promoted by the advertisement, we will collect the following information from advertisers, advertising demand-side platforms, programmatic advertising trading platforms or third-party attribution platforms used by them:

Location Information	[Optional information] country, city;
Device/Ad ID	[Necessary information] IMEI, OAID, IDFV, mobile advertisement identifier (such as Apple IDFA, Google advertisement ID),MAC address;
Device Information	[Necessary information] equipment manufacturer, equipment model, equipment operating system information, equipment language, equipment type, equipment network information, equipment operator;
Application message	[Optional information] the application package name and application version of the Menta partner;
Use data	[Required Information] The timestamp of the installation event or other events;
Other Information	[Optional information] user agent;

When Menta is the advertising demand side platform ("DSP"), the programmatic advertising trading platform and traffic supplier platform may transmit personal information to us through API and other technologies, which may include:

Location Information	[Optional information] country, time zone and locale (country and preferred language);
Device/Ad ID	[Necessary information] international mobile device identification number (IMEI), Android ID, OAID, IDFV, mobile advertising identifier (such as Apple IDFA, Google advertising ID), MAC address;
Device Information	[Necessary information] device screen information, device manufacturer, device model, device operating system information, device type, device network information, restricted advertising tracking (LAT) status;
Application message	[Required information] application package name, application version and features of the Menta partner;
Use data	[Necessary information] when you interact with the advertisement we promote, we will collect information about your interaction with the advertisement we promote, such as browsing and clicking on the relevant information of the advertisement;
Other Information	[Optional Information] Information transmitted by other advertising information exchange platforms or media platforms, user agents.

third-party sdk privacy agreement

Advertising Platform Name

Developer (Process Principal Name)

Types and Fields of Personal Information

Purpose and scenario of use

Privacy Policy Link

Admob & Ad manager

Google LLC and its affiliates

We (here we refer to Google) collect information about the apps, browsers and devices you use to access Google services in order to provide useful features such as automatic product updates, dimming the screen when the battery is low, and so on.

The information we collect includes a unique identifier, browser type and settings, device type and settings, operating system, mobile network information (including carrier name and phone number), and app version number. We also collect information about how your apps, browsers, and devices interact with Google Services,Include the IP address, crash reports, system activity, and the date, time, and referrer of the corresponding request.

We collect this information when the Google service on your device communicates with our server (for example, when you install an application from the Play Store, or when the service checks for automatic updates). If you are using an Android device with Google apps installed,Your device then periodically communicates with Google servers to provide information about your device and the connection to Google services. This information includes your device type and carrier name, crash reports, apps you have installed, and other information about how you use your Android device (depending on your device settings).

Subject to the Admob privacy policy

https://policies.google.com/privacy

How we share, provide and publicly disclose personal information of end users

（1）Sharing

We will not share your personal information with any company, organization or individual other than Mentor, except in the following circumstances:

obtain your explicit consent or authorization in advance;
Provide in accordance with the mandatory requirements of laws and regulations, administrative and judicial departments;
To the extent permitted by laws and regulations, it is necessary to provide for the protection of the interests, property or safety of Mantou, Mantou's affiliates or partners, you or other Mantou users or the public;
Only by sharing your personal information can we realize the core functions of our products and/or services or provide the services you need;
to deal with your disputes or disputes with others at your request;
Comply with the relevant agreements signed with you (including online signed electronic agreements and corresponding platform rules) or other legal documents provided;
Use based on academic research;
It is used based on social public interests and public health emergencies in accordance with laws and regulations.

（2）Entrusted processing

We may entrust authorized partners to process your personal information in order to provide you with corresponding products or services. However, we will only share your personal information for lawful, legitimate, necessary, specific and explicit purposes, and will only share personal information necessary to provide products or services. If one of our partners uses your personal information for a purpose not entrusted to us,It will be with your consent separately.

Our partners include the following types:

(1) Suppliers of technical services. We may provide your personal information to third parties who support our functions, including suppliers who provide us with infrastructure technology services, data analysis services and data processing services.

(2) Advertising and analysis service partners. We will comply with laws and regulations and industry common security technology, and entrust these partners to process information related to advertising, coverage and effectiveness.

If we entrust our partners to process personal information, we will sign a data protection agreement with them, requiring them to process personal information in accordance with the agreement, this privacy policy and relevant laws and regulations. In order to ensure the security and control of data in the third party, we have launched Yunding service to provide a safe and reliable data use and storage environment in the cloud,Ensure the security of user data.

（3）Transfer

If Personal information needs to be transferred due to merger, division, dissolution, bankruptcy and other reasons, we will inform you of the name or name and contact information of the recipient, and require the company or organization receiving your personal information to continue to be bound by this privacy policy, otherwise, we will require the company or organization to seek authorization from you again.

（4）Public disclosure

We will only disclose your personal information in the following circumstances, and under the premise of taking security measures that meet industry standards:

disclose the corresponding personal information according to the scope of authorization that you have separately agreed;
If you seriously violate laws and regulations or relevant agreements and rules, we may disclose your relevant violations and the measures we take against you.

How We Store and Protect End Users' Personal Information

（1）Storage Period

We retain personal information about end users only for as long as it is necessary for them to use the Menta Platform products or services. If the end user cancels the account or actively deletes the above information, we will save the information of the end user in accordance with the provisions and requirements of laws and regulations. After the end user logs out of the account or actively deletes the above information,We will no longer use the personal information of end users for commercial purposes, but we may anonymize the personal information of end users for use.

（2）Depositary Area

Personal information of end users is stored within the territory of the People's Republic of China. If some of the services involve the need to transmit the personal information of end users abroad, we will strictly follow the provisions of laws and regulations and seek the consent of end users to ensure the security of personal information of end users.

（3）Safety measures

We attach great importance to the security of personal information of end users. We will take reasonable security measures (including technical and management aspects) to protect the personal information of end users in accordance with the mature security standards and specifications of the industry, so as to prevent the personal information provided by end users from being accessed, publicly disclosed, used, modified, damaged, lost or leaked due to improper use or unauthorized use.
We will adopt reasonable and feasible security measures and technical means such as encryption technology and anonymization processing in accordance with industry standards to store and protect the personal information of end users, and use trusted security protection mechanisms to prevent the personal information of end users from malicious attacks.
We will fully protect the personal information security of end users through the establishment of security management departments, security management systems, data security management processes and other measures. At the same time, we will adopt a strict data use and access system to ensure that only authorized personnel can access the personal information of end users, and conduct security audits on data and technology in a timely manner.
Please fully understand that even if we have complied with relevant laws, regulations and national standards, and have done our best to take the above reasonable and effective security protection measures, due to the continuous innovation of technical means in the Internet industry and the possible existence of various malicious means, we cannot guarantee an absolutely safe environment for the Internet, but we will do our best to ensure the security of the personal information you provide to us.When you use the services of the Menta platform, problems may occur beyond the scope of our control. Therefore, in order to fully guarantee the security of your personal information, we strongly recommend that you take protective measures in the process of using Menta platform services, including but not limited to using complex passwords, changing passwords regularly, and not disclosing personal information such as your account password to others.
According to our security management system, the leakage, damage or loss of personal information is listed as the most serious security incident. Once it occurs, the company's highest-level emergency plan will be activated.

（4）Notification of security incidents

We will formulate emergency plans for network security incidents, and regularly organize security plan drills to deal with system vulnerabilities, computer viruses, network attacks, network intrusions and other security risks in a timely manner. In the event of an incident that endangers network security, we will immediately initiate an emergency plan and take appropriate remedial measures in a timely manner,Strive to prevent the expansion of the impact and consequences of such security incidents, and report to the relevant competent authorities in accordance with the regulations.
Personal information leakage, damage, and loss are company-level major security incidents. We will be responsible for organizing members of the working group to conduct security plan drills on a regular basis to prevent such security incidents from happening. In case of misfortune, we will start the emergency plan according to the highest priority and form an emergency response team to trace the cause and reduce the loss in the shortest time.
In the unfortunate event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform the end user of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and you can independently prevent and reduce risks. Suggestions, remedial measures for you, etc. We will promptly inform you of the incident in the form of in-station letter notification, mail, letter, text message, etc,When it is difficult to inform one by one, we will issue the announcement in a reasonable and effective manner. At the same time, we will also take the initiative to report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

How we handle the personal information of minors

Menta service is mainly for adults. We do not actively and deliberately collect information about minors, nor do we conduct user portraits or personalized recommend for minors. In the personal information collection scenarios we disclose, we use device information to distinguish specific information subjects rather than age dimensions. In a scenario where cooperation transmits and shares data to us,We clearly require our partners to formulate special information protection policies for minors according to the actual situation of their own products and services, and adopt stricter data desensitization and encryption technology to protect minors.

If the end user is a minor according to applicable laws, please be sure to carefully read the privacy policy of the developer or advertiser's application and this privacy policy under the supervision and guidance of parents or other guardians before using the developer's application that has integrated with Menta products and services or the advertiser's application that cooperates with Menta,And use the application or provide personal information with the consent of the Guardian.

We protect minors' personal information in accordance with applicable laws and regulations, and will only collect, use, store, share, transfer or publicly disclose minors' personal information when permitted by law, explicitly agreed by parents or other guardians, or necessary for the protection of minors. If we become aware that personal information from minors has been collected without obtaining prior verifiable parental consent,Steps will be taken to delete the information as soon as possible.

If you are a parent or other guardian of a minor, if you have any questions about the personal information of the minor you are monitoring, please contact us through the contact information publicized in this privacy policy.

If you are a user in the United States, we guarantee compliance with the Children's Online Privacy Protection Act (COPPA). If the application of our business partners (for example, application developers) is aimed at children under the age of 13, then they need to make relevant COPPA settings for the application on the Menta platform when using the Menta service,This allows Menta to ensure that the processing of the collected persistent identifiers of users of the application complies with COPPA's regulations, including not being used to serve ads that point to behavior or to track users for that purpose. In addition, we do not knowingly collect other personal information (such as accurate geographic location information) from apps that we know are intended for children under the age of 13.

If a parent or guardian discovers that a child has provided us with personal information without consent, the parent or guardian should contact us in a timely manner. We will take reasonable steps to ensure that such information is removed from our documents.

How to transfer personal information of end users across borders

In principle, the personal information we obtain and generate in China will be stored in China. If cross-border is involved, we will strictly follow the provisions of laws, regulations and relevant standards, carry out data exit security assessment and ensure the personal information security of end users.

How to update this Privacy Policy

In order to provide you with better products and services, we may revise the contents of this privacy policy in due course. Without the explicit consent of the end user, we will not reduce the rights of the end user in accordance with this privacy policy.

After this privacy policy is updated, we will publish it on the main exposure page of the official website of the Menta platform and notify developers in any accessible way. If the developer does not agree with such changes, the integration of the products and services of the Menta platform can be stopped. If the developer continues to integrate the products and services of the Menta platform,This means that the developer agrees to be bound by the revised privacy policy, and notifies the end user of this change, and obtains the end user's complete, legal, and continuous valid authorization consent during the use of the Menta platform products and services. If the end user does not agree with such changes, they can stop using the Menta platform products and services,Developers should provide users with the appropriate implementation mechanism; If end users continue to use developer applications that have integrated Menta platform products and services, it means that end users agree to be bound by this revised privacy policy.

Updates referred to in this Privacy Policy include, but are not limited:

Our service model has changed. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc;
We have undergone significant changes in our ownership structure and organizational structure. Such as business adjustments, changes in owners caused by bankruptcy mergers and acquisitions, etc;
Changes in the main objects of personal information sharing, transfer or public disclosure;
Changes in the rights of end users to participate in the processing of personal information and the manner in which they are exercised;
When the department responsible for handling personal information security, contact methods and complaint channels change;
Other changes that may have a significant impact on the personal information rights and interests of end users.

When this policy is updated, we will archive the old version of this policy for end users to review.

How to Contact Us

（1）If you have any questions, comments or suggestions related to this privacy policy or your personal information, or complaints, reports, please contact us through the following methods.

Company Name: Shanghai Mangtuo Network Technology Co., Ltd.;

Registered address of the company: 2800 Wanyuan Road, Minhang District, Shanghai

zhaogaofeng@advlion.com Mr. Zhao

kongxiangli@advlion.com Mrs.Kong

（2）Under normal circumstances, we will reply within 15 days. If you are not satisfied with our reply, especially if our personal information processing behavior damages your legitimate rights and interests, you can also complain or report to the regulatory authorities such as Internet information, telecommunications, public security and industry and commerce.

（3）If you want us to stop collecting your personal information, you can also contact the APP you are using, and we will assist the APP to handle your needs.

Appendix 1: Definitions

Specific words used in this Privacy Policy have the following meanings:

"We" or "Menta Platform" refers to Menta.
"User" means the terminal user who uses the Developer's product or service.
"Menta affiliates and partners" means our affiliates, investment companies, alliance members, partners and other trusted third-party suppliers, service providers and agents.
Personal information is all kinds of information related to identified or identifiable natural persons recorded electronically or otherwise, excluding anonymized information.
Sensitive personal information is personal information that once leaked or illegally used, it is easy to cause the personal dignity of natural persons to be violated or the personal and property safety to be endangered, including biometric identification, religious beliefs, specific identities, medical health, financial accounts, whereabouts and other information, And personal information of minors under the age of fourteen.
"Personal information subject" refers to the natural person identified by the personal information.
"Deidentification" refers to the process of technical processing of personal information so that it cannot identify the subject of personal information without the use of additional information.
"Anonymization" refers to the process in which the subject of personal information cannot be identified and the processed information cannot be restored through the technical processing of personal information.