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Privacy Policy

Last updated: March 04, 2026

Introduction

This Privacy Policy ("Policy") outlines the privacy practices of SM DISTRIBUTION USA INC ("we," "us," or "our") in relation to the use of our website, platform, and services. This Policy applies to all services offered by Adflay. The terms "User," "You," and "Your" refer to users of our platform, whether Publishers, Advertisers, or end users.

Adflay understands the importance of privacy and the protection of Personal Information. This Policy describes how we collect, use, disclose, and safeguard your information when you use our services, including the GemiWall offerwall platform.

This Policy complies with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), California Consumer Privacy Act ("CCPA"), and other applicable data protection laws. For GDPR inquiries, contact us at privacy@adflay.com.

For purposes of this Policy, "Personal Information" means information that identifies you, either directly or indirectly, including name, email address, physical address, payment information, device identifiers, and other data that can be used to contact or identify you.

How We Obtain Personal Information

Adflay collects Personal Information from the following sources:

  • Your account registration and application

  • Your creation and maintenance of your Adflay account

  • Your participation in offerwall surveys and offers

  • Your responses to communications from Adflay

  • Your use of our platform, website, and services

  • Third-party partners and data providers

  • Cookies, tracking pixels, and similar technologies

You may decline to provide Personal Information by not engaging in these activities. However, this may limit our ability to provide some or all of our services to you.

Technical Information Collected

We also collect non-personally identifiable technical information, including:

  • IP address and device identifiers (IDFA, GAID, etc.)

  • Browser type, version, and language settings

  • Operating system and platform information

  • Cookie data and tracking information

  • Account activity and usage patterns

  • Referrer URLs and clickstream data

  • Web request timestamps and session data

This technical information alone does not enable us to personally identify or contact you.

Why We Collect Personal Information

The lawful bases for processing your information are:

  • Your consent – You have given explicit permission

  • Contract performance – Processing is necessary to fulfill our agreement with you

  • Legal obligations – Processing is required to comply with laws

  • Legitimate interests – Processing is necessary for our or third party's legitimate interests, except where your rights override

How We Use Personal Information

Adflay uses your Personal Information for the following purposes:

  • Evaluating and verifying account applications

  • Processing payments and financial transactions

  • Providing and operating our advertising and monetization services

  • Matching you with relevant surveys and offers

  • Delivering targeted advertising and measuring campaign performance

  • Communicating with you about your account and our services

  • Sending administrative information and policy updates

  • Processing, formatting, and displaying customized content

  • Analyzing usage patterns to improve our platform

  • Detecting, preventing, and addressing fraud and security issues

  • Ensuring technical functioning and maintaining backups

  • Complying with legal obligations and enforcing our terms

  • Conducting research and development

  • Marketing: If you are based in the EU, we will only use your personal information for electronic marketing if permitted by law or with your consent. You can opt out of marketing communications at any time through your account settings.

Offerwall Survey Data Collection and Usage

GemiWall provides survey opportunities through our offerwall platform that allow users to participate in market research in exchange for rewards. This section describes how we collect, use, and protect survey-related information.

Survey Profile Information

To participate in offerwall surveys, you may be asked to complete a profile with demographic information. This helps us and our survey providers match you with relevant surveys. Profile information includes:

  • Full name and email address

  • Date of birth and gender

  • ZIP code/postal code and geographic location

  • Ethnicity and language preferences (optional)

  • Household income, education level, and employment status

  • Marital status and household composition

  • Other demographic details relevant to survey matching

Important: By completing your survey profile, you acknowledge and agree that this information will be shared with our third-party survey providers for the purpose of matching you with relevant survey opportunities. This sharing is essential for the survey platform to function.

Information Collected Through Surveys

When you participate in individual surveys, we may collect:

  • Survey responses and opinions you provide

  • Consumer preferences and purchasing behaviors

  • Product usage information

  • Device information (type, OS, browser)

  • Survey completion status and interaction patterns

  • Your user ID to track completion and credit rewards

How We Use Survey Information

  • Providing market research insights to survey providers and clients

  • Matching you with relevant survey opportunities

  • Verifying survey completion and crediting rewards

  • Detecting and preventing fraudulent survey activity

  • Improving survey quality and user experience

  • Complying with obligations to survey partners

Third-Party Survey Providers

Offerwall surveys are provided by third-party market research companies. Your survey profile information will be shared with these providers to:

  • Match you with surveys fitting your demographic profile

  • Verify eligibility for specific surveys

  • Prevent duplicate participation across platforms

  • Ensure survey quality and prevent fraud

  • Facilitate reward crediting

Each third-party survey provider has their own privacy policy. We encourage you to review their policies before participating. Once your information is shared with third-party providers, their use is governed by their own privacy policies.

Information Sharing and Disclosure

We may share your information in the following situations:

  • Business Partners: With advertisers, publishers, and survey providers as necessary to deliver services

  • Service Providers: With third-party vendors who perform services on our behalf (payment processing, analytics, hosting)

  • Legal Requirements: When required by law, court order, or to protect our rights

  • Business Transfers: In connection with a merger, acquisition, or sale of assets

  • With Your Consent: When you have given explicit permission

  • Aggregated Data: We may share anonymized, aggregated data that cannot identify you

We do not sell your personal information to third parties for their marketing purposes.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and track information about your use of our services.

Types of Cookies We Use:

  • Essential Cookies: Necessary for the platform to function properly

  • Analytics Cookies: To understand how users interact with our services

  • Advertising Cookies: To deliver and measure advertising campaigns

  • Preference Cookies: To remember your settings and preferences

We use cookies for tracking clicks on ads, crediting leads to the correct accounts, and statistical analysis. A cookie is a small file containing a string of characters that uniquely identifies your browser. Cookies cannot damage your files or read information from your hard drive.

Web Beacons

A web beacon (also called a pixel tag) is a transparent graphic image placed on a website or in an email to monitor user behavior. When HTML code for a web beacon retrieves the image, it can pass along information such as IP address, time viewed, browser type, and previously set cookie values.

You can control cookies through your browser settings, but disabling cookies may limit your ability to use certain features of our platform.

Data Security

Adflay implements appropriate technical and organizational security measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit and at rest

  • Secure server infrastructure with regular security audits

  • Access controls and authentication requirements

  • Regular security assessments and penetration testing

  • Employee training on data protection practices

  • Incident response and breach notification procedures

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

Data Retention

We retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

  • Account information is retained while your account is active

  • Transaction records retained for 7 years for tax and accounting purposes

  • Survey response data may be retained longer for research validation

  • Deleted information may be retained in archival copies for fraud prevention

When we no longer need your information, we will securely delete or anonymize it.

Your Privacy Rights

Depending on your location, you may have the following rights:

  • Access: Request access to your personal information

  • Correction: Request correction of inaccurate information

  • Deletion: Request deletion of your personal information

  • Portability: Request a copy of your data in a portable format

  • Opt-Out: Opt out of certain data processing activities, including marketing

  • Withdraw Consent: Withdraw consent where processing is based on consent

  • Object: Object to processing based on legitimate interests

  • Restrict Processing: Request restriction of processing in certain circumstances

To exercise these rights, contact us at privacy@adflay.com. We will respond within 30 days.

Your Rights Under GDPR (EU Residents)

If you are based in the European Union, you have specific rights under the GDPR:

  • Right of Access – Confirm whether we are processing information about you and request access

  • Right to Rectification – Correct inaccurate or incomplete information

  • Right to Erasure (Right to be Forgotten) – Request deletion of your data

  • Right to Data Portability – Obtain your personal data in a structured, commonly used format

  • Right to Restriction – Request restriction of processing in certain cases

  • Right to Object – Object to processing based on legitimate interests or for marketing

You have the right to lodge a complaint with your local data protection authority if you believe your rights have been violated.

California Consumer Privacy Act (CCPA)

If you are a California resident, you have specific rights under the CCPA:

  • Personal Information We Collect: Name, address (optional), demographics, statistical usage data

  • Right to Know: What personal information is collected, used, shared, or sold

  • Right to Delete: Request deletion of your personal information

  • Right to Opt-Out: Opt out of the sale of personal information (we do not sell your information)

  • Right to Non-Discrimination: You will not be discriminated against for exercising your CCPA rights

To exercise these rights, email privacy@adflay.com.

International Data Transfers

If you are located outside the United States, you acknowledge and agree that by using Adflay's services, your Personal Information will be collected, stored, and used in the United States. The collection, storage, transfer, and use of your information will be governed by the laws of the United States.

Children's Privacy

Our services are not intended for individuals under the age of 18. Adflay does not knowingly collect personal information from children under 18. If we learn that we have collected Personal Information from a minor, we will delete it promptly.

Third-Party Links and Services

Our platform may contain links to third-party websites and services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post any changes on this page and update the "Last Updated" date. For material changes, we will notify you via email or platform notification.

Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

SM DISTRIBUTION USA INC
Privacy Officer
13206 101TH STREET
OZONE PARK, NY 11417
United States

Email: privacy@adflay.com

To Request Survey Data Deletion:
Send an email to privacy@adflay.com with the subject line "Survey Data Deletion Request" and include your user ID or email address. We will process your request and confirm deletion within 30 days.