Privacy Policy

Last Updated: February 2, 2026

1. Introduction

789 Soft Limited ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our email marketing platform at 789soft.com.

2. Company Information

• Company Name: 789 Soft Limited (789軟件有限公司)
• Registration Number: CR-2156789
• Address: Unit 1203, 12/F, Tower A, Millennium City 5, 418 Kwun Tong Road, Kwun Tong, Kowloon, Hong Kong
• Email: [email protected]
• Phone: +852 2156 7890

3. Information We Collect

3.1 Personal Information

We may collect the following personal information:

• Name and contact information (email address, phone number)
• Account credentials (username and password)
• Payment information (cryptocurrency wallet addresses)
• Telegram username for support communications

3.2 Campaign Information

• Website URLs you wish to promote
• Affiliate tracking links
• Target countries and categories
• Email content and subject lines (AI-generated or user-provided)

3.3 Usage Data

• IP address and browser information
• Pages visited and features used
• Campaign performance metrics (sends, opens, clicks)
• Credit usage and transaction history

4. How We Use Your Information

We use the collected information for:

• Providing and maintaining the Service
• Processing and deploying email campaigns
• Generating AI-powered content using Google Gemini API
• Processing payments and managing credits
• Providing customer support via Telegram
• Monitoring and analyzing usage patterns
• Preventing fraud and abuse
• Improving our Service and developing new features
• Communicating with you about your account and campaigns

5. Third-Party Services

5.1 Google Gemini API

We use Google Gemini API to generate email content. When you use the AI generation feature, your website URL and campaign parameters are sent to Google's servers for processing. Google's privacy policy applies to this data: https://policies.google.com/privacy

5.2 Payment Processors

We use cryptocurrency payment processors for USDC/USDT transactions. These processors have their own privacy policies governing the collection and use of your payment information.

6. Data Sharing and Disclosure

We do NOT sell, trade, or rent your personal information to third parties. We may share information only in the following circumstances:

• Service Providers: With trusted third-party service providers (Google Gemini API, payment processors) who assist in operating our Service
• Legal Requirements: If required by law, court order, or government regulation
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• Consent: With your explicit consent

7. Email List Privacy

• Our subscriber lists are proprietary and confidential
• We do not share subscriber email addresses with clients
• All subscribers have opted in through legitimate means
• Subscribers can opt-out at any time via unsubscribe links
• We maintain strict CAN-SPAM and GDPR compliance

8. Client Confidentiality

We are committed to protecting your business confidentiality:

• We do not share client campaign data with other users
• We do not publish case studies without explicit permission
• We do not disclose client identities or business relationships
• All client information is treated as strictly confidential

9. Data Security

We implement appropriate technical and organizational measures to protect your data:

• Secure HTTPS connections for all web traffic
• Password hashing using industry-standard algorithms
• Regular security audits and updates
• Access controls and authentication requirements
• Encrypted storage of sensitive information

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

10. Data Retention

• Account information: Retained while your account is active
• Campaign data: Retained for 12 months after campaign completion
• Transaction records: Retained for 7 years for accounting purposes
• Usage logs: Retained for 90 days

11. Your Rights

You have the right to:

• Access: Request a copy of your personal data
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your data (subject to legal requirements)
• Portability: Request transfer of your data
• Objection: Object to certain data processing activities
• Withdraw Consent: Withdraw consent at any time

To exercise these rights, contact us at [email protected]

12. Cookies and Tracking

We use essential cookies for:

• Session management and authentication
• Remembering user preferences
• Security and fraud prevention

We do not use advertising or tracking cookies from third parties.

13. Children's Privacy

Our Service is not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected such information, please contact us immediately.

14. International Data Transfers

Your information may be transferred to and processed in Hong Kong and other jurisdictions where our service providers operate. By using our Service, you consent to such transfers.

15. GDPR Compliance (EU Users)

If you are located in the European Economic Area (EEA), you have additional rights under GDPR:

• Legal basis for processing is your consent and contractual necessity
• Right to lodge a complaint with a supervisory authority
• Right to data portability in machine-readable format
• Right to object to automated decision-making

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on this page and updating the "Last Updated" date. Your continued use of the Service constitutes acceptance of the updated policy.

Public website cookie choices

On your first visit, We value your privacy offers Customize, Reject All and Accept All. Use Cookie settings at the bottom of any page to change your choice at any time. Reject All keeps necessary security, verification and account-session cookies active.

This public website currently has no analytics or advertising trackers and no optional display-preference storage.

The first-party 789soft_privacy_choice cookie remembers your choice for up to 180 days. It stores the notice version, allowed categories and update time without a unique visitor identifier. Image verification uses a separate first-party HttpOnly/SameSite cookie lasting up to 10 minutes; existing account-session cookies protect signed-in access.

These choices apply to this website. Consent to process an enquiry, account agreements and advertising on partner properties are handled separately. Any broader platform cookie descriptions in this policy do not mean those trackers are installed on the public website. If browser storage is unavailable, the notice may appear again.

Website enquiry and verification records

Enquiries are saved in a private server directory for the team to respond. Only a reference, enquiry type and timestamp appear in email notifications; your brief remains in the private record. Routine website enquiry records are retained for 90 days unless an ongoing request requires separate agreed handling.

A first-party HttpOnly, SameSite cookie links your browser to a six-digit verification image. The code expires in 10 minutes, locks after three incorrect attempts and is consumed for a new saved enquiry. Only a keyed digest is stored, alongside short-lived anti-abuse records. Account session cookies are separate and expire after inactivity.

Use the contact information below to request access, correction or deletion. Do not include passwords, payment details or personal subscriber lists in website enquiries.

17. Contact Us

For privacy-related questions or to exercise your rights, contact us:

• Email: [email protected]
• Phone: +852 2156 7890
• Telegram: Website support
• Address: Unit 1203, 12/F, Tower A, Millennium City 5, 418 Kwun Tong Road, Kwun Tong, Kowloon, Hong Kong