Privacy Policy

Last updated: October 23, 2026

Introduction

This Privacy Policy explains how YUN SHENG INTERNATIONAL TRADING (HONG KONG) LIMITED ("svelanosolution", "we", "our", or "us") collects, uses, shares, and protects personal data when you use the svelanosolution platform, websites, and related services (the "Services"). For the purposes of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the "PDPO"), we are the data user of the personal data described in this policy, except where we handle data on behalf of a customer as described in section 3. 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, subject to section 7.
• To meet legal, regulatory, and contractual obligations.

3. Our role in the data we handle

For account, billing, and platform usage data, we act as the data user and decide how that data is used. For audience segments, conversion events, and other personal data that a customer uploads or connects to a campaign, the customer is responsible for that data and for having a lawful basis to use it. We process it on the customer's instructions to deliver and measure the campaigns the customer configures.

4. How we rely on your personal data

We collect and use personal data for the purposes set out in section 2, and we limit collection to what is necessary for those purposes. Where we rely on consent — for example for non-essential cookies or for direct marketing — you can withdraw that consent at any time. We do not use your personal data for a new purpose without telling you first, unless the law allows it.

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.

5. 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.

6. 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. Hong Kong does not have a single statute dedicated to cookies, so our approach follows the PDPO and the guidance issued by the Privacy Commissioner for Personal Data on online tracking, together with the cookie rules that apply in other markets where our users are located. You can accept, reject, or customise these categories at any time using the Cookie Settings link in the footer, or through your browser settings.

7. Direct marketing

We will not use your personal data for direct marketing unless you have given the consent required under Part 6A of the PDPO, and we will stop using it for that purpose if you ask us to. Every marketing message we send includes a way to opt out, and opting out does not affect service or transactional messages about your account. We do not provide your personal data to third parties for their own marketing without your written consent.

8. Data security

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

• encryption of data in transit and at rest where appropriate to the system;
• role-based access controls and least-privilege administration;
• logging of workspace and administrative activity;
• vulnerability management and 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.

9. 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.

10. Your rights

Under the PDPO you may ask whether we hold personal data about you, request a copy of it, and request correction of data that is inaccurate. Where other data protection laws apply, you may also have rights to access, correct, delete, or restrict the processing of your personal data, to object to certain processing such as direct marketing, and to request data portability. To make a data access request or a correction request, contact privacy@svelano.com. We will respond within the period required by applicable law.

If you are not satisfied with how we have handled your request, you may complain to the Office of the Privacy Commissioner for Personal Data in Hong Kong, or to the supervisory authority that applies where you live.

11. International transfers

Information may be transferred to and processed in countries other than Hong Kong, including where our service providers operate. Section 33 of the PDPO, which would regulate cross-border transfers, is not currently in force, so we protect these transfers through contractual commitments and by reviewing the jurisdictions and providers involved before data is transferred.

12. Children

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

13. 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.