Hong Kong Top-Notch Technology Co.,Limited Aptostar Distribution Service Privacy Policy

Updated: February 19, 2025

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

About us

Hong Kong Top-Notch Technology Co.,Limited (hereinafter referred to as “Hong Kong Top-Notch Technology Co.,Limited” or “we”) care deeply about your privacy. This Privacy Policy is designed with your needs in mind. It is essential that you have a thorough understanding of our practices regarding the collection and use of personal information, while ensuring that you have ultimate control over the personal information you provide to us. By using Hong Kong Top-Notch Technology Co.,Limited Aptostar Distribution Service (the “Service”) you are agreeing to be bound by this Privacy Policy between you and the following corresponding entities depending on region:

About this Privacy Policy

This Privacy Policy applies to the Service and is applicable to both developers and users.

Under this Privacy Policy, “personal information” means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information Hong Kong Top-Notch Technology Co.,Limited has access to about that individual, except as otherwise specifically provided by applicable laws in your region. We will use your personal information strictly in accordance with this Privacy Policy. Where the context requires, personal information shall also include sensitive personal data or information, as may be categorized under applicable law.

1，What information we collect and how we use it

We will only collect the information that is necessary for specified, concrete, explicit, and legitimate purposes and shall ensure that the information is not further processed in a manner that is incompatible with those purposes. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our products or services or respond to your queries.

1.1 Users

If you are a user, in order to provide you with our Services, we need you to provide us with the information required to use these Services, including:

1.1.1 Account and bank card information

In order to provide basic payment and quick payment features, we will collect your Hong Kong Top-Notch Technology Co.,Limited Account and bank card information, including your Account ID, bank card number, and bank card expiration date.

1.1.2 Device-related information

In order to provide basic payment services, optimize payment display, and control payment risk, we will collect information about your device, such as device identifier (GAID/GPID), device model, system version information, system language, country/region, network type, and screen display information.

1.1.3 App usage information

In order to provide basic payment services and optimize the user payment experience, we will collect information about your use of the app, such as Aptostar version, app and app developer information, IAPs, and number of days active.

1.2 Developers

If you are a developer, in order to provide you with our Services, we need you to provide us with the information required to use these Services, including:

1.2.1 Information for authentication

In order to certify and review developer qualifications, we collect necessary information from you. If you are an individual developer, we will collect your legal name, certificate number, ID documentation, country, and phone number. If you are a corporate developer, we will collect the company’s registered name and company contact information.

1.2.2 Merchant information

In order for us to successfully send you payment invoices and pay you service fees, we will collect merchant information, including the company name, names of personnel, company address, and account type.

1.2.3 Bank card information

In order to provide you with basic payment services, we will collect your bank card information, including the holder name of bank account, bank name, SWIFT code, and bank account number.

2，How we share, transfer, and publicly disclose your personal information

2.1 Sharing

We do not sell any personal information to third parties.

We may sometimes share your personal information with third parties (as described below) in order to provide or improve our products or services, including offering products or services based on your requirements. Specific information on data sharing is provided below.

2.1.1 Sharing that you actively choose or request

With your consent or at your request, we will share your personal information within the scope of your consent/request with specific third parties designated by you.

2.1.2 Sharing information with our group

In order to successfully conduct business operations and to provide you with all the features of our products or services, we may share your personal information from time to time with our affiliates.

2.1.3 Sharing with third-party service providers and business partners

To help us provide you with products and services described in this Privacy Policy, we may, where necessary, share your personal information with our third-party service providers and business partners. We are committed to ensuring that the sharing of personal information necessary for providing services to you is solely for legitimate, legal, necessary, specific, and explicit purposes. Hong Kong Top-Notch Technology Co.,Limited will conduct due diligence and have contracts in place to ensure that third-party service providers comply with the applicable privacy laws in your jurisdiction. Third-party service providers may also have sub-processors.

2.1.4 Other

In accordance with laws and regulations, legal procedures, litigation, and/or requests from public agencies and government agencies, we may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.

2.2 Transfer

We will not transfer your information to any agents except under the following circumstances:

• We have obtained your express consent.

• If we are involved in a merger, acquisition or sale of all or a portion of assets that may affect your personal information, we will notify you by email and/or by posting a prominent notice on our website or by other appropriate means regarding any changes in ownership, usage rights or choices you may have in connection with your personal information.

• In the circumstances explained in this Privacy Policy or by otherwise notifying you.

2.3 Public disclosure

We may publicly disclose your personal information under the following circumstances: • Where we need to announce a winner of a promotion, competition, or sweepstake, in which case we only publish limited information;

• Where we have obtained your explicit consent, or you have disclosed the information via our services such as on social media pages or public forums; and

• Public disclosure based on law or reasonable grounds, including laws and regulations, legal procedures, litigation, or at the request of relevant government departments.

3，How we store and protect your personal information

3.1 Our security measures

We are committed to ensuring the security of your personal information. In order to prevent unauthorized access, disclosure, or other similar risks, we have put in place all legally required physical, electronic, and managerial procedures to safeguard and secure the information we collect on your mobile device and on our websites. We will ensure that we safeguard your personal information in accordance with applicable law.

All your personal information is stored on secure servers and protected in controlled facilities. We classify your information based on importance and sensitivity and ensure that your personal information has the required level of security. We have special access controls for cloud-based data storage, and we regularly review our information collection, storage, and processing practices, including physical security measures, to guard against any unauthorized access and use.

3.2 Information storage location and duration

Under normal circumstances, the personal information we collect and generate will be stored on servers in Singapore.

If the region where you are located has requirements for information security, we will store the collected and generated personal information in your region in accordance with the laws and regulations of that region.

We retain personal information for the period necessary for the purpose of the information collection described in this Privacy Policy or any separate privacy policy provided for a specific product or service, or as required by applicable laws. We will cease to retain and delete or anonymize personal information once the purpose of collection is fulfilled, or after we confirm your request for erasure, or after we terminate the operation of the corresponding product or service. Where possible, we have indicated how long we typically retain identified categories, types, or items of personal data. In determining the above retention periods, we have taken into account the following factors:

• The amount, nature, and sensitivity of the personal data;

• The risk of harm from unauthorized use or disclosure;

• The purposes for which we process the personal data and how long we need the particular data to achieve these purposes;

• How long the personal data is likely to remain accurate and up to date;

• For how long the personal data might be relevant to possible future legal claims; and

• Any applicable legal, accounting, reporting, or regulatory requirements that specify how long certain records must be kept.

Depending on your jurisdiction, there may be an exception to this for personal information that we are processing for public interest, scientific, historical research, or statistical purposes. We may continue to retain this type of information for longer than its standard retention period, where necessary and permitted based on applicable laws or your request, even if further data processing is not related to the original purpose of collection.

4，Your rights

4.1 Access, correction, and deletion

Depending on applicable laws and regulations, you may have the right to access, rectification, erasure (and certain other rights) in relation to personal information that we hold about you (hereinafter referred to as “the request”). These rights will be subject to specific exclusions and exceptions under applicable laws. You can contact us via privacy@aptostar.com. It will help us to process your request most efficiently if it meets the following conditions: A) The request is submitted through our exclusive request channel detailed above and for the protection of your information security, your request should be in writing (unless the local law explicitly recognizes the oral request); B) You provide sufficient information to enable Hong Kong Top-Notch Technology Co.,Limited to verify your identity and ensure that you are the data subject or legally authorized to act on the data subject’s behalf. Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.

4.2 Withdrawal of consent

You may withdraw your consent previously provided to us for a particular purpose by submitting a request, including collecting, using, and/or disclosing your personal information in our possession or control. Based on the specific service you are using, you can withdraw your consent by contacting us via privacy@aptostar.com.We will process your request within a reasonable time from when the request was made, and thereafter not collect, use, and/or disclose your personal information as per your request. Depending on the extent of your withdrawal of consent, please note that you may not be able to continue receiving the full benefit of Service. The withdrawal of your consent or authorization will not affect the validity of our processing carried out on the basis of the consent up until the point of withdrawal.

4.3 Service or account cancellation

If you wish to cancel a specific product or service, you can contact us via privacy@aptostar.com.

5，Protection of minors

We do not provide services directly to children, nor do we use children’s personal information for marketing purposes. We are committed to protecting the personal information of minors, and when minors use our service, we will provide corresponding protection in strict accordance with national laws and regulations. If you are a parent or guardian and you believe that your child has provided us with personal information without your authorization, please contact us at privacy@aptostar.com to ensure that the information is deleted immediately and that your child’s subscriptions related to the Service are canceled.

6，Contact us

If you have any comments or questions about this Privacy Policy or any questions relating to Hong Kong Top-Notch Technology Co.,Limited ’s collection, use, or disclosure of your personal information, contact us via privacy@aptostar.com or at the address below. When we receive privacy or personal information requests about accessing or downloading personal information, we have a professional team to solve your problems. If your question itself involves a significant issue, we may ask you for more information. If you are not satisfied with the response you received from us in relation to your personal information, you can hand over the complaint to the relevant data protection regulatory authorities in your jurisdiction. If you consult us, we will provide you with information on relevant complaint channels that may be applicable based on your actual situation.

Users can contact us at:

Hong Kong Top-Notch Technology Co.,Limited

Unit 1 On 22nd /F the Cloud NO.111 Tune Chau ST Tai Kok Tsui Hong Kong