Last updated: September 21, 2025
This privacy policy (this “Privacy Policy”)
          explains how Couponewstar and our Affiliates (“we”, “our” or “us”) collect, use and
          disclose your personal data. This Privacy Policy applies to Couponewstar (“Platform”) and
          related services (collectively, our “Services”), which informs you of our policies
          regarding the collection, use, and disclosure of personal data when you use our Services
          and the choices you have associated with that data.
By downloading, accessing, using
          and/or interacting with our Services, you fully understand about our collection, use and
          disclosure of your personal data as described in this Privacy Policy. This Privacy Policy
          is incorporated by reference into the end user license agreement available at Terms of
          Service (the “EULA”) and is subject to the provisions of the EULA. Capitalized terms used
          but not defined in this Privacy Policy shall have the meaning ascribed to such terms in
          our EULA.
This Privacy Policy will help you to understand:
What Personal Data We
          Collect and How We Use
Cookies and Similar Technologies
How We Entrust A
          Third-Party to Process, Share, Transfer and Disclose Your Personal Data
How Long We
          Keep Your Personal Data
The Security of Your Personal Data
Children
Your
          Rights
Changes
Addendum
Contact Us
1. What Personal Data We Collect
          and How We Use
We provide various articles created based on users' shopping
          experiences and impressions. You can access our service without registering or logging in.
          Certain products on our website are controlled by third parties, including third parties
          located outside the EU/EEA, which shall be borne by its own privacy policy respectively.
          We collect and process your personal data only to the minimum extent necessary to achieve
          the following purposes, based on appropriate legal grounds.
1.1
In order to
          provide some location-based services such as forming a team with people nearby, we may
          collect your IP address, GPS, RFID, your home address.
The processing activity for
          this purpose is based on your consent. We will ask for your consent when you turn on this
          feature and you have the right to withdraw your consent at any time.
1.2
To
          improve our services and correct errors that occur during your use, we may collect
          relevant information while you browse our platform, including but not limited to your
          behavioral data, device information, and network status.
The processing activity for
          this purpose is based on our legitimate interests and will not override your legal rights
          and interests.
1.3
In order to comply with applicable law (such as anti-money
          laundering regulations), we may collect your device and network information.
The
          processing activity for this purpose is necessary for compliance with the legal obligation
          we subject to.
2. Cookies and Similar Technologies
We use cookies and other
          similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to
          enhance your experience using the Services. Cookies are small files which, when placed on
          your device, enable us to provide certain features and functionalities.
You have the
          option to permit installation of such Cookies or subsequently disable them. You may accept
          all cookies, or instruct the device or web browser (as applicable) to provide notice at
          the time of installation of cookies, or refuse to accept all cookies by adjusting the
          relevant cookie retention function in your device. However, in the event that you refuse
          to install cookies, your browsing experience may be interrupted.
3. How We Entrust a
          Third-Party to Process, Share, Transfer and Disclose Your Personal Data
We may share
          your personal data with the following categories of third parties in order to provide our
          Services to you
3.1 Affiliates
We are a global company and has affiliates all
          over the world. In order to provide our Services, we will share your personal data with
          our affiliates based on the respective legal basis and data processing agreements signed
          between us.
3.2 Advertising
This type of service allows User Data to be utilized
          for advertising communication purposes displayed in the form of banners and other
          advertisements on this Website, possibly based on User interests.
This does not mean
          that all Personal Data are used for this purpose. Information and conditions of use are
          shown below.
Some of the services listed below may use Cookies to identify Users or
          they may use the behavioral retargeting technique, i.e. displaying ads tailored to the
          User's interests and behavior, including those detected outside this Website. For more
          information, please check the privacy policies of the relevant services.
In addition
          to any opt out offered by any of the services below, the User may opt out of a third-party
          service's use of cookies by visiting the Network Advertising Initiative opt-out page .
(1)AdSense:
-
Google
          AdSense is an advertising service provided by Google Inc. This service uses the
          "Doubleclick" Cookie, which tracks use of this Website and User behavior concerning ads,
          products and services offered.
-
Users may decide to disable all the Doubleclick
          Cookies by clicking on: google.com/settings/ads/onweb/optout
-
Personal Data
          processed: Cookies; Usage Data
-
Place of processing: Ireland - Privacy Policy -
          Opt Out
3.3 Data Analytics
In order to better understand and provide more
          effective services, we may conduct research and analysis on the collected personal data,
          such as your behavior data on our platform. We may analyze, categorize, and segment this
          personal data. The research and analysis may be presented on an aggregate basis.
We
          may also use third-party Service Providers to monitor and analyze the use of our Service.
          These third parties have access to your Personal Data only to perform these tasks on our
          behalf and are obligated not to disclose or use it for any other purpose. For more
          information, please visit the privacy policies of the partners found here:
(1)Google
          Analytics:
-
Google Analytics is a web analysis service provided by Google Inc.
          ("Google"). Google utilizes the Data collected to track and examine the use of this
          Website, to prepare reports on its activities and share them with other Google
          services.
-
Google may use the Data collected to contextualize and personalize
          the ads of its own advertising network.
-
Personal Data processed: Cookies;
          Usage Data
-
Place of processing: Ireland - Privacy Policy - Opt Out
(2)Google
          Tag Manager:
-
Google Tag Manager is a tag management service provided by Google
          Ireland Limited.
-
Personal Data processed: Usage Data.
-
Place of
          processing: Ireland - Privacy Policy.
3.4 Remarketing and behavioral targeting
This
          type of service allows this Website and its partners to inform, optimize and serve
          advertising based on past use of this Website by the User.
This activity is
          facilitated by tracking Usage Data and by using Trackers to collect information which is
          then transferred to the partners that manage the remarketing and behavioral targeting
          activity.
Some services offer a remarketing option based on email address lists.
In
          addition to any opt-out feature provided by any of the services below, Users may opt out
          by visiting the Network Advertising Initiative opt-out page .
Users may also opt-out
          of certain advertising features through applicable device settings, such as the device
          advertising settings for mobile phones or ads settings in general.
(1)Google Ads
          Remarketing (Google Ireland Limited)
-
Google Ads Remarketing is a remarketing
          and behavioral targeting service provided by Google Ireland Limited that connects the
          activity of this Website with the Google Ads advertising network and the DoubleClick
          Cookie. Users can opt out of Google's use of cookies for ads personalization by visiting
          Google's Ads Settings .
-
Personal Data processed: Cookies; Usage Data.
-
Place
          of processing: Ireland - Privacy Policy - Opt Out .
(2)Remarketing with Google
          Analytics (Google Ireland Limited)
-
Remarketing with Google Analytics is a
          remarketing and behavioral targeting service provided by Google Ireland Limited that
          connects the tracking activity performed by Google Analytics and its Cookies with the
          Google Ads advertising network and the Doubleclick Cookie.
-
Personal Data
          processed: Cookies; Usage Data.
-
Place of processing: Ireland - Privacy Policy
          - Opt Out .
3.5 Traffic optimization and distribution
This type of service
          allows this Website to distribute their content using servers located across different
          countries and to optimize their performance.
Which Personal Data are processed
          depends on the characteristics and the way these services are implemented. Their function
          is to filter communications between this Website and the User's browser.
Considering
          the widespread distribution of this system, it is difficult to determine the locations to
          which the contents that may contain Personal Information of the User are transferred.
(1)Cloudflare
          (Cloudflare Inc.)
-
Cloudflare is a traffic optimization and distribution
          service provided by Cloudflare Inc.
-
The way Cloudflare is integrated means
          that it filters all the traffic through this Website, i.e., communication between this
          Website and the User's browser, while also allowing analytical data from this Website to
          be collected.
-
Personal Data processed: Cookies; various types of Data as
          specified in the privacy policy of the service.
-
Place of processing: United
          States - Privacy Policy.
3.6 Law enforcement / legal obligation
(1) Anti-cheat
          and anti-fraud companies
We may share the information required for detecting,
          investigating, and preventing cheating on the platform and violations of the End User
          License Agreement, solely for the purposes of detecting, investigating, and preventing
          violations on the platform.
(2) Public authorities and auditors
Some personal
          data shall be disclosed to public authorities, e.g., tax and customs authorities,
          auditors, and other competent parties in accordance with the applicable laws.
3.7
          Sale or merger
A third party that acquires all or substantially all of us or our
          business. We may disclose information to a third party in the event that we sell or buy
          any business or undergo a merger, in which case we will disclose your data to the
          prospective buyer of such business. We may also disclose information to a third party if
          we sell, buy, merge or partner with other companies or businesses, or sell some or all of
          our assets. In such transactions, personal data may be among the transferred assets. You
          will be notified via email, in-app/in-game notice and/or notice on our website of any
          change in ownership or users of your personal data.
4. How Long We Keep Your Personal
          Data
4.1 How we determine
We determine the retention period of your personal
          data taking consideration of the following elements:
period of the contractual
          relationship with you;
sensitivity of the personal data;
time elapsed since your
          last interaction with us;
security reasons;
applicable statutes of
          limitation;
ongoing or potential litigation or dispute;
regulatory or legal
          obligation to retain the personal data.
4.2 How long we keep your personal data
We
          may retain most of your personal data as long as needed to provide services or products to
          you, or as required or permitted by applicable laws.
When destroying personal data,
          measures will be taken to make the personal data irrecoverable or irreproducible, and
          electronic files which contain personal data will be deleted permanently using a technical
          method which makes the files irreproducible.
In the event that the processing and
          retention period have terminated, but personal data is required to be retained
          continuously for other reasons including but not limited to for the purposes as prescribed
          under applicable laws, the relevant personal data will be stored and maintained separately
          from other types of personal data. If you require us to destroy your personal data before
          the end of its life cycle (as set out in the retention policy above), we will destroy your
          personal data in accordance with local laws.
5. The Security of Your Personal Data
We
          are committed to maintaining the privacy and integrity of your personal data no matter
          where it is stored. Our group companies have information security and access policies that
          limit access to our systems and technology. We also protect data through the use of
          technological protection measures such as encryption. Your personal data will remain
          subject to our technical and organizational controls and our policies and procedures
          (including but not limited to this Privacy Policy).
Unfortunately, the transmission
          of information via the internet is not completely secure. Although we will use
          commercially reasonable efforts to protect your personal data, we cannot guarantee the
          security of the information transmitted to our services; any transmission of your
          information is at your own risk.
In the case of a personal data breach, we will
          notify the personal data breach to the supervisory authority competent, where feasible,
          not later than 72 hours after having become aware of it, unless the personal data breach
          is unlikely to result in a risk to the rights and freedoms of you. When the personal data
          breach is likely to result in a high risk to the rights and freedoms of you, we will
          communicate the personal data breach to you without undue delay.
6. Children
You
          hereby represent that you are an “adult” (as defined in the applicable in your
          jurisdiction) and have the requisite power and authority to access and/or use our
          Services. If you are not an adult, you must obtain the consent of your parent or legal
          guardian to use the Services. Usually our Services are not intended for children under the
          age of 16(this age requirement may vary in your country and is set forth in the table
          below) and we do not knowingly collect any personal data from such children. Children
          under the age of 16 should not use or attempt to use our Services, and if you are under
          16, please do not attempt to use our Services.
In the event that we learn that we
          have inadvertently gathered personal data from a child under the age of 16, we will take
          reasonable measures to delete such information from our records. Parents who believe that
          we might have gathered any information from or about a child under the age of 16 may
          submit a request to the email address set forth in the section “Contact Us” below.
7.
          Your Rights
7.1 The right to be informed
You have the right to be provided with
          clear, transparent and easily understandable information about how we use your personal
          data and your rights. This is why we are providing you with the information in this
          Policy.
7.2 The right of access
You have the right to obtain access to your
          personal data. This is so you are aware and can check that we are using your personal data
          in accordance with applicable data protection laws. Please contact us and submit a request
          to the email address set forth in the section “Contact Us” below.
7.3 The right to
          rectification
You have the right to rectify your personal data if it is inaccurate or
          incomplete. If you believe that we hold any other personal data about you that is
          inaccurate, you can change the information you are able to modify in the corresponding
          settings. For information that you cannot change, please contact us via email.
7.4
          The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple
          terms, enables you to request the deletion or removal of your personal data where there is
          no compelling reason for us to keep using it. This is not an absolute right to erasure and
          exceptions apply.
You may request that we erase the personal data we hold about you
          in the following circumstances:
you believe that it is no longer necessary for us to
          hold such personal data; or
you believe the personal data we hold about you is being
          unlawfully processed by us.
We may need to retain personal data if there are valid
          grounds under data protection laws for us to do so (e.g., for the defense of legal claims
          or freedom of expression) but we will let you know if that is the case. Where you have
          requested that we erase personal data that has been made available publicly on the
          Services and there are grounds for erasure, we will use reasonable steps to try to tell
          others that are displaying the personal data or providing links to the personal data to
          erase it too.
You can also exercise your right to restrict our processing of your
          personal data (as described below) whilst we consider your request.
7.5 The right to
          restrict processing
You have a right to require us to stop processing the personal
          data we hold about you other than for storage purposes in certain circumstances. Please
          note, however, that if we stop processing the personal data, we may use it again if there
          are valid grounds under data protection laws for us to do so (e.g., for the defense of
          legal claims or for another’s protection). As above, where we agree to stop processing the
          personal data, we will try to tell any third party to whom we have disclosed the relevant
          personal data so that they can stop processing it too.
You may request we stop
          processing the personal data we hold about you where:
you believe the personal data
          is not accurate for the period it takes for us to verify whether it is accurate;
you
          wish to erase the personal data as the processing we are doing is unlawful but you want us
          to retain the personal data but just store it instead; or
you wish to erase the
          personal data as it is no longer necessary for our purposes but you require it to be
          stored for the establishment, exercise or defense of legal claims.
7.6 The right to
          data portability
You have rights to obtain and reuse your personal data for your own
          purposes across different services. For example, if you decide to switch to a new
          provider, this enables you to move, copy or transfer your personal data easily between our
          IT systems and theirs safely and securely, without affecting its usability.
7.7 The
          right to object to processing
You have the right to object to certain types of
          processing, including processing for direct marketing (which we perform only with your
          consent).
7.8 The right to lodge a complaint
You have the right to lodge a
          complaint about the way we handle or process your personal data with your national data
          protection authority.
7.9 The right to withdraw consent
If you have given your
          consent to anything we do with your personal data, you have the right to withdraw your
          consent at any time (although if you do so, it does not mean that anything we have done
          with your personal data with your consent up to that point is unlawful). This includes
          your right to withdraw consent to us using your personal data for marketing purposes.
7.10
          The right not to be subject to automated decision making
You have the right not to be
          subject to a decision based solely on automated processing (including profiling) which
          produces legal (or similarly significant) effects to you.
We usually act on requests
          and provide information free of charge, but may charge a reasonable fee to cover our
          administrative costs of providing the information for:baseless or excessive/repeated
          requests; or further copies of the same information. Alternatively, we may be entitled to
          refuse to act on the request.
Please consider your request responsibly before
          submitting it. We will respond as soon as we practically can, generally within one month
          from when we receive your request but, if the request is going to take longer to deal
          with, we will come back to you and let you know.
We will also cooperate with the
          third-parties who have data interaction with us to ensure your rights pursuant to
          applicable laws and regulations.
8. Changes
If we make any material changes to
          this policy, we will post the updated policy here and notify our users. Please check this
          page frequently to see any updates or changes to this policy.
9. Addendum
9.1
          Brazil Addendum
If you are located in Brazil, you acknowledge that we are bound by
          the Brazil’s General Data Protection Law (Lei Geral de Prote??o de Dados Pessoais, LGPD).
          If you have any questions, concerns or complaints about this Privacy Policy, or how we
          handle your Personal Data, please contact us at the as shown in section “Contact Us”
          below.
9.2 Columbia Addendum
If you are located in Columbia, you acknowledge
          that we are bound by the Statutory Law 1581 of 2012 (Law 1581). If you have any questions,
          concerns or complaints about this Privacy Policy, or how we handle your Personal Data,
          please contact us at the address as shown in section “Contact Us” below.
9.3 Turkey
          Addendum
If you are located in Turkey, you acknowledge that we are bound by the Law
          on Protection of Personal Data, Law No. 6698 (LPPD). If you have any questions, concerns
          or complaints about this Privacy Policy, or how we handle your Personal Data, please
          contact us at the address as shown in section “Contact Us” below.
9.4 Peru
          Addendum
If you are located in Peru, you acknowledge that we are bound by The
          Personal Data Protection Law N° 29733 (PDPL) and the Supreme Decree N°
          003-2013-JUS-Regulation of the PDLP (Regulation). If you have any questions, concerns or
          complaints about this Privacy Policy, or how we handle your Personal Data, please contact
          us at the address as shown in section “Contact Us” below.
10. Contact Us
If you
          want to lodge a complaint about how we handle your personal data, or need to contact us
          for any other reason (including exercising any rights related to the above personal data),
          please send your request to:[email protected]
 
PRIVACY POLICY