Privacy Policy

1. Introduction

Welcome to the privacy policy of Bold Ocean, operated by Changzhou Jingtu International Trade Co., Ltd. (Business Registration Number: 91320411MADH337131), located at Xinbei District, Longhu Tang Street, Longye Road and Fengwan 3rd Building, Unit 06009, Changzhou, Jiangsu, China.

This policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website, engage our AI PPC marketing consultancy services, or otherwise interact with Bold Ocean. We are committed to protecting your privacy and handling your data in an open and transparent manner.

2. Information We Collect

We may collect and process the following categories of personal data:

• Identity Data: Full name, job title, company name
• Contact Data: Email address, telephone number, business address
• Financial Data: Billing information, payment details, invoicing records
• Technical Data: IP address, browser type and version, device identifiers, time zone, operating system, platform
• Usage Data: Pages visited, navigation paths, click behaviour, session duration, referral sources
• Marketing Data: Communication preferences, responses to campaigns, survey data
• Campaign Data: Advertising account access credentials (provided by clients), campaign performance metrics, audience data within ad platforms
• Cookie Data: Information collected through cookies and similar tracking technologies (see our Cookie Policy)

3. How We Use Your Information

We use the personal data we collect for the following purposes:

• Service Delivery: To provide AI PPC marketing consultancy, campaign management, performance reporting, and strategic recommendations
• Communication: To respond to inquiries, send project updates, deliver audit reports, and provide customer support
• Account Management: To manage client accounts, process payments, and maintain billing records
• Improvement: To analyse website usage, improve our services, develop new features, and enhance user experience
• Marketing: To send you relevant industry insights, case studies, and service updates (only with your consent)
• Legal Compliance: To comply with applicable laws, regulations, and legal processes
• Security: To detect, prevent, and address fraud, technical issues, or threats to our services

4. Legal Basis for Processing

We process your personal data under the following legal bases:

• Consent: Where you have given clear consent for us to process your personal data for specific purposes, such as receiving marketing communications
• Contractual Necessity: Where processing is necessary for the performance of a contract with you or to take pre-contractual steps at your request (e.g., providing a free PPC audit, onboarding a new client)
• Legitimate Interest: Where processing is necessary for our legitimate business interests, such as improving our services, understanding client needs, and maintaining security, provided these interests do not override your rights
• Legal Obligation: Where processing is necessary to comply with a legal obligation to which we are subject

5. Information Sharing

We do not sell your personal data. We may share your information in the following circumstances:

• Service Providers: We work with trusted third-party providers including cloud hosting providers, payment processors, analytics platforms (e.g., Google Analytics), advertising platforms (e.g., Google Ads, Meta Ads), and communication tools. These providers process data on our behalf under strict contractual obligations.
• Advertising Platforms: In the course of managing your PPC campaigns, we access and manage data within advertising platforms such as Google Ads, Microsoft Advertising, Meta Ads, LinkedIn Ads, and TikTok Ads as authorized by you.
• Legal Requirements: We may disclose your data if required by law, regulation, legal process, or enforceable governmental request.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred as part of the transaction. We will notify you of any such change.
• With Your Consent: We may share data with other third parties when you have given us explicit permission to do so.

6. Client Engagement & Project Data

As an AI PPC marketing consultancy, we handle sensitive business and campaign data on behalf of our clients. This section addresses specific data practices related to our professional services:

• Campaign Performance Data: We collect, analyse, and store campaign metrics including impressions, clicks, conversions, cost data, and audience insights to optimize your PPC performance.
• Professional Communications: Records of project-related communications including emails, meeting notes, strategy documents, and audit reports are retained to ensure service quality and continuity.
• Advertising Account Access: Clients may grant us access to their advertising accounts. We use this access solely for the purposes outlined in our service agreement and follow platform-specific security protocols.
• Billing & Invoicing: We maintain records of invoices, payment history, and contractual terms for accounting and legal compliance purposes.
• AI & Machine Learning: Our AI tools process anonymized and aggregated campaign data to improve bidding strategies and recommendations. Individual client data is never shared across accounts without explicit consent.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:

• Active Client Data: Retained for the duration of our business relationship plus 3 years for reference and legal compliance
• Prospect Data: Audit reports and inquiry data are retained for up to 2 years from last contact
• Financial Records: Invoicing and payment data are retained for 7 years in accordance with tax and accounting regulations
• Website Analytics: Aggregated analytics data is retained for up to 26 months
• Marketing Consent Records: Retained for as long as consent remains active, plus 1 year after withdrawal

When data is no longer required, it is securely deleted or anonymized.

8. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete personal data
• Right to Erasure: Request deletion of your personal data where there is no compelling reason for continued processing
• Right to Data Portability: Request transfer of your data to another service provider in a structured, machine-readable format
• Right to Restrict Processing: Request that we limit how we use your data
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of processing prior to withdrawal

To exercise any of these rights, please contact us at info@boldocean.xyz. We will respond to your request within 30 days.

9. Data Security

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

• Encryption of data in transit (TLS/SSL) and at rest
• Multi-factor authentication for access to systems containing personal data
• Regular security assessments and vulnerability testing
• Access controls limiting data access to authorized personnel only
• Secure cloud infrastructure with reputable providers
• Employee training on data protection and security best practices
• Incident response procedures for prompt handling of any data breach

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but are committed to maintaining the highest practical standards.

10. International Transfers

Bold Ocean is operated by Changzhou Jingtu International Trade Co., Ltd. based in Changzhou, Jiangsu, China. Our services are provided globally, and your data may be transferred to and processed in countries outside your country of residence.

Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by relevant authorities
• Ensuring receiving countries have adequate data protection laws
• Implementing additional technical and organizational measures where necessary

11. Children's Privacy

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child, we will take steps to delete it promptly. If you believe a child has provided us with personal data, please contact us at info@boldocean.xyz.

12. Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last updated" date at the top of this page
• Post a notice on our website for a reasonable period
• Where required, notify you directly via email

We encourage you to review this policy periodically to stay informed about how we protect your data.

13. Contact Us

If you have any questions, concerns, or requests regarding this privacy policy or our data practices, please contact us:

• Company: Changzhou Jingtu International Trade Co., Ltd.
• Brand: Bold Ocean
• Email: info@boldocean.xyz
• Phone: +31 689926638
• Address: Xinbei District, Longhu Tang Street, Longye Road and Fengwan 3rd Building, Unit 06009, Changzhou, Jiangsu, China
• Business Registration Number: 91320411MADH337131