Privacy Policy

1. Data Controller

Inotium Limited (Hong Kong, HKSAR), BRN 78930718.
Registered office: 14/F, China Hong Kong Tower, 8 Hennessy Road, Wan Chai, Hong Kong.
Email: privacy@inotium.com

2. Data We Process

Account and contact data; technical data (IP, cookies, device), campaign events (impressions, clicks), billing details (for invoicing), correspondence and operational logs.

3. Purposes

Providing and billing the services, analytics and optimisation, security and abuse prevention, support, and compliance with legal obligations.

4. Legal Bases

Contract with the Client, legitimate interests (e.g., security/improvement), legal obligations, and consent where required by law.

5. Transfers & Storage

Data may be processed in Hong Kong and other locations by our vendors and hosting providers. For transfers from the EEA/UK we use Standard Contractual Clauses (SCCs) with additional safeguards.

6. Retention

  • Technical logs and campaign events: 12–24 months;
  • Billing/accounting records: ≥ 7 years or longer if required by law;
  • Account data: during the contract and up to 30 days after termination for export, then deletion/archival.

7. Data Subject Rights

Access, rectification, erasure, restriction, portability and objection — contact privacy@inotium.com. We may request identity verification.

8. Sub-processors

We engage service providers (hosting, analytics, ESP, etc.) under data-protection agreements. An up-to-date list is available upon request.

9. Security & Incidents

We apply technical and organisational measures appropriate to risk. In case of a personal-data incident, we will notify in a timely manner as required by applicable law and contracts.

10. Cookies

We use cookies for authentication, analytics and personalisation. For EEA/UK visitors we obtain consent for non-essential cookies.

Last updated: 25 Oct 2025