Last Updated: October 24th, 2022

This Privacy Policy (“Policy”) details how AlgoriX Technology Pte. Ltd. (“AlgoriX,” “we,” “our,” or “us”) and its global subsidiaries collect, use, and share information. It covers how we handle the following information:

1. About End-Users (“End-Users,” “you,” “your”) of our owned and operated mobile applications (“apps”) and third-party mobile apps that use our Ad Services (see Section 1 for more information on our “Ad Services”) either through a Software Development Kit (“SDK”) or other collection interfaces (“APIs,” “VAST Tags”);
2. About individuals who visit and engage with our (i) corporate website at www.algorix.co and other properties, be it on our (ii) official social media pages and (iii) email marketing, (iv) website subscriptions, and (v) other sales and marketing activities (collectively, “AlgoriX Properties”).

SECTION 1 – INTRODUCTION TO ALGORIX SERVICES

AlgoriX provides mobile advertising automation technology and solutions to advertisers, buyers, app developers, and publishers of mobile apps and websites (collectively, “Clients”). This is done by providing our Clients —and through them, their customers — with tools to deliver relevant online advertising to End-Users through our Ad Services, which include our ad exchange (“AlgoriX Exchange”), advertising platform (“AlgoriX Entregar”), and app publishing arm (“AlgoriX Studios”). More information on these tools can be found in section 3 labeled “Cookies and Similar Tracking Technologies.”

In line with our commitment to market quality and transparency, AlgoriX may also share certain relevant information about End-Users collected through our Ad Services with clients and other third parties for data validation, fraud protection, and marketing purposes in compliance with regulations on personal data.

SECTION 2 – PRIVACY FOR USERS VISITING MOBILE APPS WHERE OUR AD SERVICES ARE IMPLEMENTED  

2.1 WHAT INFORMATION DO WE COLLECT FROM END USERS

While visiting mobile applications using our Ad Services and depending upon the publisher’s choices, we will collect a variety of information from the End-User. Below are the information we collect in relation to our Ad Services:

• Browser and device information received from publishers is shared with advertisers and agencies for responding to requests for advertisements, forecast advertising inventory and troubleshooting any operation issues; This includes:
  
  • Device Type: phones, smart tv, tablet, pc,
  • Device Manufacturer: Device make (e.g., “Apple”).
  • Device Mode: Device model (e.g., “iPhone”).
  • Device OS: Device operating system (e.g., “iOS”).
  • Device Language:
  • Device carrier: Carrier or ISP (e.g., “VERIZON”).
  • Network connection type (e.g., “WIFI”, “Cellular-45”).
  • Device macmd5: MAC address of the device; hashed via MD5.
  • Device IFV: identifier of the device dedicated to an app publisher.

• IP addresses, including both IPv4 and IPv6 (shared with DSPs (Demand Side Partners, which act on behalf of advertisers and agencies  to bid on advertising inventory);
• Geo-location data (town level)  is used by DSPs to bid on advertising inventory;
• UserIDs, stored in browser cookies by DSPs, are stored by DSPs for profiles on the ad servers;
• Mobile device identifiers (IFDA, AAID) are used to track mobile traffic and are shared with DSPs acting on behalf of advertisers and agencies to personalize the advertising displayed;
• Data on whether a user viewed or clicked on an Ad is shared with DSPs acting on behalf of advertisers and agencies for the measurement of ad performance and statistics.

2.2 HOW WE USE THE INFORMATION

We use the information we collect for  the following business purposes:

Providing and improving our advertising services. The information we collect is essential in delivering and optimizing our services (including the Ad Services mentioned above).

Delivering ads. Through our Ad Services, publishers and app developers can offer advertising inventory, while advertisers and buyers (DSPs) can bid on and fill that inventory with relevant ads. 

behavioral targeting. DSPs, acting on behalf of advertisers and agencies match data we pass to them with their own data, trying to predict End-Users’ potential future behavior and interests on a per-device basis or across devices.  This allows Advertisers and agencies to effectively deliver highly-relevant ads to the right users; Algorix does not offer behavioral targeting services itself.

Reports and analytics. We require this information to analyze ad performance, such as tracking views of ads, as well as click-through rates to websites or app stores and/or installs of apps that have been advertised, thus allowing us to improve our Ad Services and provide detailed reports to our Clients as needed.

Data validation and fraud prevention. While providing our Ad Services, it’s sometimes necessary to match End-User information, such as mobile IP addresses, across multiple devices to validate data, filter out invalid impressions, clicks, installs, or ad queries, and prevent fraudulent activity from occurring while delivering our Ad Services.

Other essential usage. We may also make use of information as deemed necessary to (i) comply with legal processes, (ii) as required by government authorities, including and excluding government authorities of  End-Users’ country of residence, (iii) protect our business, rights, privacy, and safety, and those of our subsidiaries and Clients, (iv) carry out audits (security, corporate, accounting) and finally, (v) to ensure our terms and conditions are enforced.

2.3 Joint controllership with our Clients:

We act as joint controller with our Clients (Publishers, Advertisers and Agencies, including Demand Side Platforms “DSPs”) in order to sell Publishers advertising inventory, to permit behavioural targeting by DSPs acting on behalf of Advertisers and Agencies, ensure ad delivery to End-Users, and provide statistics and data validation to our Clients. AlgoriX consequently implemented a joint controllership agreement with its Clients, the main obligations of which are made available to End-Users by writing to: legal@algorix.co

SECTION 3 – COOKIES AND SIMILAR TRACKING TECHNOLOGIES

AlgoriX, our Clients, and our third-party partners collect and use information about End-Users through cookies and other tracking technologies. Below, we detail the technologies we use and how each is utilized. End-Users may opt-out by following the opt-out process detailed in Section 5.2. The use of tracking technologies is subject to prior consent from EU End-Users.

3.1 WHAT TECHNOLOGIES DO WE USE? 

We use a combination of the following tracking technologies to help us collect information:

Cookies. Cookies are small data files containing a string of characters, such as unique browser identifiers. Cookies are stored on your computer or other device and act as unique tags that identify your browser. Our servers may deploy a cookie on your browser only when you visit Algorix’s Website at www.algorix.co , subject to EU End Users’ prior consent.

Pixel Tags. Also known as web beacons or pixels, pixel tags are small blocks of code on a webpage, which can read and place cookies. It enables us to collect information such as IP addresses, time of access, and browser type. 

SDKs. A software development kit (SDK) is a tool or program used by app developers that allow us to serve ads, collect data, and implement other necessary actions related to our Ad Services on mobile applications.

APIs. An application programming interface (API), like the SDK, is used to call or request for information.  

We and our third-party partners, use cookies and similar tracking technologies to collect and use information about you as listed in Section 2.1.

3.2 HOW DO WE USE THESE TECHNOLOGIES FOR ADVERTISING PURPOSES?

We use these tracking technologies to collect information automatically from End-Users’ devices, subject to prior consent from EU End-Users, collected by publishers who work with us, including through the IAB Transparency and Consent Framework, of which Algorix is a member). They help us identify unique browsers or devices used by an End-User and to perform functions like limiting the same ad from continuously reappearing, ensuring that ads are properly displayed on our publishers’ apps and websites, and serving relevant ads to the End-User.

Further on, and subject to prior and express consent from EU End-Users, our Clients will use information that we share with them to establish connections among related devices (such as smartphones, tablets, and computers) for personalized advertising by Advertisers and agencies, and for analytics, and reporting purposes. They may match End User’s devices if the End User logs into the same online service on multiple devices or web browsers, or if the End User’s devices share similar attributes that support an inference that they are used by the same person or household. This means that information about an End User’s use of websites or applications on his or her current browser or device may be combined and used with information from the End User’s other browsers or devices. For example, this allows Advertisers and Agencies to deliver ads on an End User’s tablet-based on activities the End User engaged in on his or her smartphone. To opt-out of cross-device targeting practices, please follow the instructions in the section below.

 3.3 ADHERENCE TO THE TCF IAB – PURPOSES OF THE PROCESSING  -LEGAL BASIS – DATA RETENTION – FOR EU RESIDENTS

We participate in the IAB Europe Transparency & Consent Framework (IAB TCF) in order to obtain appropriate consent from EU End-Users to tracking technologies. We comply with IAB TCF Specifications and Policies. AlgoriX’s identification number within the framework is 1176.

The TC String is a tool created by the IAB TCF permitting to collect End-Users consent or refusal to tracking technologies for advertising purposes, which is passed to Algorix and to its Clients and partners to ensure they are entitled to process the End-User data, in compliance with the GDPR. According to the Belgium data protection authority dated February 2nd, 2022, the IAB Europe is a joint controller with CMPs, publishers and vendors for the collection and dissemination of TC Strings, based on the legitimate interest legal basis, and subject to an opt out system to be implemented; IAB Europe is currently deemed as a joint controller with CMPs, publishers and vendors for the subsequent processing of personal data for advertising purposes, according to the same decision of the Belgium data protection authority. Because the joint controllership has been established by a ruling, we will update from time to time this section to reflect any changes implemented by the IAB Europe to comply with the data protection authority’s decision, which has been appealed.

PURPOSES of the TCF IAB Consent String (See also Section 2.2)	LEGAL BASIS (See also  Section 6.1)	DATA RETENTION
Manage End-User consent to advertising tracking technologies	Legitimate interest, subject to an opt out to be made available	6 months
Store and/or access information on a terminal	End-User consent	6 months
Selecting standard advertisements	Legitimate Interest	After one week the data are deleted
Select personalized ads	End-User consent	After one week the data are deleted
Measure ad performance;	End-User consent	After one week the data is deleted
Develop and improve products	Legitimate interest	After one week the data are deleted
Provide security,	Legal obligation / Legitimate interest	After one week the data is deleted
Fraud prevention, and debugging	Legitimate interest	After one week the data is deleted
Technically deliver ads	Legitimate interest	After one week the data are deleted
Enable cross device targeting	End-User consent	After one week the data are deleted

SECTION 4 – PRIVACY FOR ALGORIX PROPERTIES INTENDED FOR OUR CLIENTS AND PROSPECTS

Information may also be collected while using AlgoriX Properties (as defined at the beginning of this Privacy Policy) such as our website. 

4.1 WHAT CLIENT  INFORMATION DO WE COLLECT ?

Information Directly Provided By You

While using AlgoriX Properties, visitors may be asked to voluntarily provide personal information. This might occur when visitors register for an AlgoriX account, subscribe to our mailing list, fill out a lead generation form on social media, or contact us via our website. Often, the information we collect include contact details (name, email, phone number), personal information (company, job title, office location), messages detailing the nature of communication, and any attachments visitors may include in relation to this. 

Information That’s Automatically Collected,

Subject to prior consent for EU resident Clients, we use cookies and pixel tags on AlgoriX properties to collect information that may be considered as personal data in some countries including those under the EU. This information allows us to keep track of visitor interactions, optimize our services, customize user experience and allow ad retargetting. More information is provided on “Section 3 – Cookies and Similar Tracking Technologies.”.

4.2 HOW WE USE THE INFORMATION COLLECTED FROM OUR CLIENTS AND PROSPECTS

The information we collect on AlgoriX Properties are be used for:

• • Account management. Create access to an AlgoriX account and provide specific data related to the use of our Ad Services
  • Marketing communications. Send out marketing and promotional messages regarding our products and services in line with your content preferences. You may opt out of our marketing communications at any time by following the steps detailed at “Section 5.2 Control and Opt-Out Options”
  • Service messages. Sometimes, we may need to use this information to send out messages for administrative purposes such as to communicate changes in our terms of service, product policies, and other related updates.

• • Case studies and testimonials. With our Client’s explicit content, we may use personal information when drafting case studies and testimonials to be posted on the website. Should you wish to have this content removed in the future, you may do so by sending us a message with a link to the page where the content you wish to remove appears. 

• • Customer service and support. The information you provide may also be used to contact you in response to a request for customer service or support or to provide more information as needed.

• • Analytics and Advertising. We use Google Analytics on our website and other social media and CRM analytic tools in our Properties to collect data for the purpose of research, analysis, and reporting. In some cases, this collected data may also be used for ad retargeting. You may check your opt out options in “Section 5.2 Control and Opt-Out Options.”

• • Improving our products and services. Information collected will also be used to optimize user experience on our Properties, improve the content we provide, deliver more effective marketing campaigns, and manage our client relations.

• Legal purposes and risk management. When necessary and under applicable laws, including those outside the End-Users’ country of residence, we may use this information to comply with legal requirements, mitigate risks and damages to our business and that of our clients, and fulfill other similar requirements.

 4.3 CHART OF EU  CLIENT OR PROSPECT INFORMATION PROCESSED – PURPOSES OF THE PROCESSING  -LEGAL BASIS – DATA RETENTION

INFORMATION (See also Section 4.1)	PURPOSE (See also Section 4.2)	LEGAL BASIS (See also Section 6.1)	DATA RETENTION
Name, surname, zip code, email, phone number, company, job title, office location	Account creation	contract	Duration of the account until deletion requested by client or 3 years after Client’s last connection to the account
Email	Newsletter	consent	Until consent is withdrawn
Billing Information	billing	Contract performance	Duration of the account until deletion requested by client or 3 years after Client’s last connection to the account
Email	support	Legitimate interest/performance of the contract	Duration of the account until deletion requested by client or 3 years after Client’s last connection to the account

SECTION 5 – GENERAL INFORMATION

5.1 HOW WE SHARE THE INFORMATION COLLECTED ABOUT END USERS

The End Users data we collect is shared in relation to the use of AlgoriX Ad Services. Below, we detail when information is shared:

To Buyers and Advertisers:  list here. We share information we collect on End Users in connection with our Ad Services to allow them to make decisions regarding buying advertising inventory on our publishers’  digital properties and other websites and applications, and for billing purposes, dispute resolution or fraud prevention. Moreover, this information, such as a device’s physical location, is also needed to analyze the effectiveness and performance of their advertising campaigns via our services. This also enables buyers and advertisers to provide End-Users with more personalized and relevant content.

To Our Clients’ Attribution and Analytics Partners: We may share end-user information, such as cookie ID, mobile device ID, or other unique identifiers with our clients’ attribution and analytics partners to validate and measure the success and effectiveness of ads delivered via our Ad Services.

To Clients (Agencies and Advertisers, or Demand Side Partners acting on their behalf) So they may provide targeted content and advertising to End Users on mobile websites and/or apps.

They also may use the data along with analytics companies, data management platforms that help DSPs maintain and use data, proximity solution providers, and other advertising technology providers, such as fraud prevention and performance measurement providers. These companies may, for example, provide targeted content and advertising to End-Users and others on third-party mobile websites and/or apps or other advertising media (such as email, direct mail, and display media).

To Execute Business Transfers. In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), the information may also be shared with a third party, as strictly necessary for the purpose of executing business transfers.

To Comply with Legal Requirements. If deemed necessary and appropriate, information may be shared (i) in line with applicable law, including laws outside the End-User’s country of residence, (ii) to comply with legal processes, such as subpoenas, warrants, and others; (iii) as required by government authorities, including and excluding government authorities of  End-Users’ country of residence; (iv) to protect our business, rights, privacy, and safety, and those of our subsidiaries and Clients, and finally, (iv) to ensure our terms and conditions are enforced, (v) to pursue legal action and contain damages we may sustain in relation to such activities.