PRIVACY POLICY
Last updated July 24, 2025

This privacy notice for MINZPRO DIGITAL LIMITED ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process) your information when you use our services ("Services"), such as when you:
• Visit our website at https://minzpro.com/
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics in the related sections below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights in the related sections of this Privacy Policy below.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
4. AUTOMATED DECISION-MAKING AND PROFILING
5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
6. INTERNATIONAL DATA TRANSFERS
7. COOKIES AND TRACKING TECHNOLOGIES
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. DO WE ENGAGE IN PROFILING OR AUTOMATED DECISION-MAKING?
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS NOTICE?
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
17. DATA CONTROLLER


1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us.

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• phone numbers

Sensitive Information. We do not process sensitive information.


2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.


3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent in Section 8 of this Privacy Policy.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
༚ send users information about special offers and discounts on our products and services,
༚ develop and display personalized and relevant advertising content for our users.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the information is publicly available and is specified by the regulations


4. AUTOMATED DECISION-MAKING AND PROFILING

In Short: We may use automated decision-making in the form of profiling to tailor advertising content to individual users, but we do not make any legal or similarly significant decisions solely based on automated processing.

Under Article 22 of the GDPR, individuals have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects them. While our advertising processes may involve limited profiling for the purpose of customizing advertising content, we do not carry out fully automated decision-making with legal or significant effects. You may object to such processing at any time by contacting us.


5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.


6. INTERNATIONAL DATA TRANSFERS

In Short: We are based in Hong Kong and process your data globally, including outside the European Economic Area (EEA).

If you are located in the EEA, UK, or Switzerland, your information may be transferred to and processed in countries outside of these regions, including Hong Kong. We ensure that appropriate safeguards are in place under applicable data protection laws, such as the use of Standard Contractual Clauses approved by the European Commission, to protect your information during such transfers.


7. COOKIES AND TRACKING TECHNOLOGIES

In Short: We may use cookies and similar technologies (such as pixels and tracking scripts) to collect and store your information, deliver personalized content, and improve user experience. You have control over their use.

What Are Cookies?

Cookies are small data files that are placed on your device when you visit a website. They are widely used to make websites work or operate more efficiently, as well as to provide reporting information.

We may use the following categories of cookies:

• Strictly Necessary Cookies – Required for website functionality and security.
• Performance and Analytics Cookies – Help us analyze how users interact with our website.
• Functionality Cookies – Remember your preferences and settings.
• Advertising/Targeting Cookies – Used to deliver advertisements more relevant to you and your interests.

Some of these cookies are placed by us (first-party cookies), and some by third-party service providers (third-party cookies), such as analytics providers or advertising networks.

Pixel Tags and Other Technologies

We may use pixel tags (also known as web beacons) to track the actions of users on our site and to measure the effectiveness of our campaigns. These technologies can also be used in emails to determine whether they have been opened or interacted with.

Third-Party Tracking

Third-party service providers (such as advertising networks or analytics providers) may use tracking technologies to collect information about your activities on our website and other sites over time. This information may be used to deliver targeted ads based on your browsing behavior.

We currently may use third-party technologies such as:

• Google Analytics
• Facebook Pixel
• Other programmatic ad platforms

Please refer to their respective privacy policies for more information.

Your Choices and Consent

Depending on your location, you may be presented with a cookie banner or pop-up when first visiting the site. This banner allows you to:

• Accept all cookies
• Reject all except strictly necessary cookies
• Customize your cookie preferences

You can also manage cookies via your browser settings, where you can block or delete cookies at any time.

For EU/EEA/UK visitors, our use of cookies and other tracking technologies is based on your explicit consent, except for strictly necessary cookies.

Do Not Track

Your browser may offer a “Do Not Track” signal. Currently, our systems do not recognize or respond to browser “Do Not Track” signals. However, you can manage cookie preferences using the tools described above.


8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.


10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at: ceo@minzpro.com


11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change personal data provided or withdraw your consent at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (i) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you - for example, to send you service-related messages, to respond to service requests, or for other non-marketing purposes.


12. DO WE ENGAGE IN PROFILING OR AUTOMATED DECISION-MAKING?

In Short: We may use limited profiling for advertising optimization, but we do not make decisions that produce legal or similarly significant effects for users.

We may use certain forms of automated processing of personal data (profiling) to deliver more relevant advertising or to analyze interactions with our Services. For example, we may group users by inferred interests or prior interactions in order to improve advertising relevance.

However, we do not use profiling or automated decision-making in a way that produces legal effects or similarly significant consequences for individuals as defined under Article 22 of the GDPR. Any automated processing we use does not evaluate aspects of your personality, performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements in a way that would affect you significantly.

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, you have the right to object to profiling under certain circumstances. Please contact us at ceo@minzpro.com if you would like to learn more or exercise your rights.


13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of the USA, you are granted specific rights regarding access to your personal information.

We do not collect the following categories of personal information:
1. Identifiers – contact details, such as real name, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address.
2. Protected classification characteristics under the federal law – gender and date of birth.
3. Commercial information – transaction information, purchase history, financial details, and payment information.
4. Biometric information – fingerprints and voiceprints.
5. Internet or other similar network activity – browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
6. Geolocation data – device location.
7. Audio, electronic, visual, thermal, olfactory, or similar information – images and audio, video or call recordings created in connection with our business activities.
8. Professional or employment-related information – business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
9. Education Information – student records and directory information.
10. Inferences drawn from collected personal information – inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics.
11. Sensitive personal Information.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section "HOW DO WE PROCESS YOUR INFORMATION?".

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?".

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.


14. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.


15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by the following email address: ceo@minzpro.com


16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request by the following email address: ceo@minzpro.com


17. DATA CONTROLLER

In Short: We are the Data Controller under the GDPR and similar data protection regulations.

MINZPRO DIGITAL LIMITED
Registered office: Unit 2a, 17/F, Glenealy Tower No.1, Glenealy Central, Hong Kong SAR, China
Email: ceo@minzpro.com

If you have any questions or wish to exercise your data rights, please contact us via this address.