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Privacy policy

Effective from 02/11/2026

1. Who is responsible for your data

The controller of personal data on this site is Elite. Please send any questions and requests about your data to: elitezoom@gmail.com.

2. What we collect

The site collects data only after you click agree on the cookie notice. We then record:

• page views and clicks through to the partner's offer page;
• IP address, browser information (User-Agent) and the country determined from the IP address;
• the Facebook click ID in the ad link (fbclid) and the cookies _fbc, _fbp;
• a random ID stored in a cookie to recognize the same browser;
• the campaign, ad set and ad IDs contained in the ad link;
• your choice on the cookie notice (agree or decline), its time and the version of the notice.

This site has no forms and does not ask for your name, phone number or email. If you leave your details on the partner's site, the partner may report the result back to us (for example, a registration or a deposit), sometimes with an email or phone number. We keep them only as a one-way SHA-256 hash to send to Meta and delete them as soon as they have been sent.

3. Purposes

• Measuring the effectiveness of advertising on Facebook and Instagram.
• Helping Meta optimize ad delivery to people who may be interested.
• Recording the results (registration, deposit) that the partner reports back for your click.

4. Who we share data with

• Meta (Meta Platforms Ireland Ltd. and Meta Platforms, Inc.) via the Conversions API, from our server: events (page view, click to offer, registration, deposit), IP address, browser information, _fbc, _fbp, the browser's random ID and country (the last two as SHA-256 hashes), and a hashed email or phone number if the partner sends one.
• Partner (the offer page you are taken to): only a random click ID and the campaign, ad set and ad IDs. The partner does not receive your IP address or cookies from us.
• Cloudflare, Inc.: hosts the site and data on our behalf (data processor).

Meta and Cloudflare process data on servers outside Vietnam. We do not sell your data.

5. Retention period

• Clicks with IP address, browser information, _fbc, _fbp: deleted after 30 days. The provider's backup systems may keep deleted copies for up to 30 more days, and a click with a result waiting to be sent to Meta is kept for up to 7 more days — in total up to 67 days.
• Result records (without IP address): 90 days.
• Records of your choice on the cookie notice: 400 days, to prove consent.
• Aggregate statistics not linked to individuals: 400 days.
• Cookies in your browser: _fbc, _fbp and the random ID 90 days; the cookie storing your choice 365 days.

6. Consent, refusal and withdrawal

Before you choose, the site sends nothing to Meta and does not record you. If you click decline, we store only that choice (the choice cookie and the record mentioned in section 2), set no tracking cookies and send nothing to Meta. You can change your mind at any time via the small link in the corner of the page. When you withdraw consent, the cookies above are deleted, we stop recording and do not send Meta any unsent results from this browser.

7. Your rights

Under Personal Data Protection Law No. 91/2025/QH15 and its implementing documents, you have the right to: be informed about the processing of your data; consent or not consent; withdraw consent; access, request correction or deletion of data; request restriction of processing; object to processing; file complaints, denunciations and lawsuits, and claim damages in accordance with the law.

To exercise these rights, send an email to elitezoom@gmail.com. Since we do not know your name, please tell us when you visited the site or the value of the cookie _fbp in your browser so we can find the right data. We reply within the time limit set by law.

8. Changes to this policy

When the policy changes, we update this page and the effective date above.