This privacy policy set out:

• What data we collect and from which sources;
• Our commitments regarding your data;
• How your data is (or is not) used by Ogury;
• How your data may be shared with third parties;
• the rights and choices you have over your dataif you are located in the EEA, the UK, or Switzerland orin a regulated U.S. State, so that you can easily exercise them.

When we say “Ogury,” “we,” or “us” in this privacy policy, we mean Ogury Limited (including its subsidiaries and affiliates) that acts as the controller of your data. A controller is the entity which, alone or jointly with others, determines the purposes and means of the processing of personal data.

This notice does not cover how our partners may use your data or when we use your data on behalf of our clients as a processor (or service provider), which is explained in their own privacy policies. When you visit our corporate websitehttps://ogury.com/ ourWebsite Privacy Policy applies.

We’ve tried to make this as easy to read as possible. Please sit back, relax and enjoy the reading. If anything is unclear, please contact us atdpo@ogury.co so we can assist.

Our activities

We provide digital advertising services that allow:

• publishers to monetize their content by making ad space available on their digital properties available for purchase;
• and brands to purchase the opportunity to show ads on digital properties visited by an audience that may be interested in their products or services.

We also offer advertising-related services to publishers and brands, including measuring and reporting on advertising performance, preventing fraud, resolving errors, and other services aimed at making the buying and selling of advertising placements seamless, efficient, and effective.

How do we do it?

Let’s begin with the foundational principle of our privacy-centric services:we don’t know (and don’t need to know) who you are. We don’t know your name, your postal address, your phone number, your email address, your exact location or any other information that would allow us to directly and indirectly reveal your identity. 

Instead, when you visit a digital property using our services – such as your favourite gaming app – we use cookies and non-cookie technologies to distinguish your browser or app from others and assign to it a limited amount of data to serve ads that may be of interest to you. 

We decide what ad you see based on our recommendation algorithms that can operate in three ways: 

• Contextual-based targeting– By relying solely on our own understanding of the key audience details of a particular ad space on a given digital property, built from multiple data points and criteria, such as:
  • contextual information about the ad space, including characteristics of the ad space (e.g., format, size, visibility), the semantic context surrounding the ad space, the date and time of your visit, and the city where you are located;
  • the responses you voluntarily submit to us when completing surveys that we present in place or after advertisements on the digital property;
  • and aggregated data obtained from third parties (e.g., official reports and market figures). 
• Identifier-based targeting – By relying on identifiers provided by brands to define specific audiences to target.
• Hybrid – By relying on identifiers provided by brands, while extending the delivery to other ad spaces that contextually match.

Data we use and its sources

Glossary

Data from publishers

We collect the following categories of data from publishers’ digital properties using our services (please refer to the glossary above for further information): 

• Identifiers
• User Choice Data 
• Device Data 
• Internet Service Data
• Location Data
• Contextual Data
• Survey Data
• Engagement Data

Data from brands

When you click on an ad we serve to you and land on a brand’s digital property, we may collect the following categories of data, provided that the brand decided to integrate our cookie or non-cookie technologies (please refer to the glossary above for further information):

• User Choice Data
• Device Data
• Internet Service Data
• Interaction Data

Data from third parties

We collaborate with various third parties in the context of the provision of our services, which independently gather and may provide Third Party Data  to us (please refer to the glossary above for further information). As an example, we may receive non-precise information about your location (country, region or city) from third parties.

Our commitments regarding data we use

• We don’t know (and don’t need to know) who you are– Our services are designed to prevent us from using any data that would directly and indirectly reveal your identity, such as your name, your postal address, your phone number, your email address, or your exact location. However, data we use (see sectionData we use and its sources) is qualified as personal data by applicable privacy laws and regulations and we take the utmost care to protect your privacy and the confidentiality of your data.

• No knowledge about your precise location – We don’t use any precise location data.

• No sensitive data– We don’t use any information that would be considered sensitive, special, or similar under applicable privacy laws and regulations, such as information revealing your political opinions or religious beliefs, information concerning your sexual orientation, or health-related information.

• No child data – We don’t use any personal data that we know relates to children under the age of 16 years or under the age required for parental consent as determined by any applicable jurisdiction, whichever is older.

• No user profiling – We don’t analyse your data to make predictions or assessments about your likely personal preferences, behaviour, or any other relevant traits or serve ads to you based on this information. However, we may pass data to third party advertising platforms that use it in accordance with their own privacy policies. 

Use of data

Data is used for the following purposes: 

How we disclose data

We are committed to apply appropriate measures to ensure that any disclosure of data complies with applicable privacy laws and regulations and your choices, while prioritising the protection ofyour privacy and the confidentiality of your data.

Data may be disclosed to the following categories of third parties:

• Publishers and brands– We may disclose aggregated data derived from your data, such as aggregate reporting about monetization performance or ad campaigns performance, to publishers and brands to help them understand the performance of our services. Such aggregated reporting does not contain any information that could be deemed personal under applicable privacy laws and regulations.
• Third party advertising platforms– We may disclose your data to third party advertising platforms to allow them to bid on and fill ad spaces on digital properties with their own ad campaigns. Clickhere to view the list of third party advertising platforms we work with.
• Brands’ partners– Some brands may request that we disclose your data to their own partners through the ads we serve for advertising-related purposes, such as measuring the effectiveness of their campaigns. 
• Vendors, and other service providers– We may disclose your data to third-party service providers, vendors, contractors, or agents so that they can perform functions on our behalf and provide services necessary to the operation of the business, such as data hosting and fraud prevention.
• Subsidiaries and affiliates– We may disclose your data to our subsidiaries and affiliates when necessary for the purposes described in this policy.
• Any third party for legal, regulatory, judicial or administrative purposes – We may also disclose your data when we deem it necessary or appropriate for the following reasons: (i) to comply with applicable privacy laws and regulations; (ii) in response to subpoenas, warrants, or other legal processes; (iii) when required by public and government authorities; (iv) to enforce our terms and conditions; (v) when we believe in good faith that such disclosure is necessary to protect our rights or those of our affiliates and subsidiaries; and (vi) to establish or exercise our legal rights, or to defend against legal claims.
• Any third party for business transfer purposes – We may transfer your personal data in connection with an actual or proposed successor entity in the event of a corporate merger, consolidation, sale or transfer of all or a part of our business or assets, bankruptcy, or other corporate restructuring.

Data retention

We retain your data for the period necessary to fulfil the original purpose(s) for which it was collected, as outlined in this privacy policy. Typically, your data is kept in our systems for up to13 months upon collection, then automatically deleted or aggregated. 

We may retain that information, in an aggregated format, indefinitely. In such cases, we commit to not re-identifying the information.

Industry self-regulation for online interest-based advertising

Ogury is not a member of the self-regulatory organisations, such as theNetwork Advertising Initiative (“NAI”), theDigital Advertising Alliance (“DAA”), theEuropean Digital Advertising Alliance (“EDAA”) and theDigital Advertising Alliance of Canada (“DAAC”), that develop industry self-regulatory principles and standards for online behavioural advertising.

However, you can use the following platforms provided by these self-regulatory organisations to quickly and easily opt out of receiving online behavioural advertising from a range of companies participating to their initiatives, including third party advertising platforms to whom we may share your data:

• NAI’s platform
• DAA’s platform
• EDAA’s platform
• DAAC’s platform

Additional information for individuals in the EEA/UK and Switzerland

If you are an individual located in the EEA, the UK, or Switzerland, these additional disclosures below apply to you. 

Endorsement of industry best practices

We support industry initiatives forgreater transparency and user control over the use of data for advertising purposes. This is the reason why we participate in theIAB Europe Transparency & Consent Framework (“IAB EU TCF”), comply toIAB EU TCF’s Specifications and Policies, and only deliver advertisements in digital properties that deployed an IAB EU TCF-compliant consent and management platform. Ogury’s identification number within the IAB EU TCF is 31.

Legal basis for processing your personal data

Our legal basis for collecting and using your data, as outlined in this privacy policy, isthe consent you expressed in digital properties using our services, depending on the source of your data. This means we don’t deliver ads to you unless you have explicitly agreed to receive them.

You can withdraw your consent at any time by following the instructions provided below.

Your privacy rights

You have the following rights over your personal data:

• The right to withdraw your consent – You have the right to change your mind at any time and withdraw the consent you gave to the processing of your data by Ogury. 
• The right to rectification – You have the right to rectify inaccurate data or have incomplete data be completed.
• The right to be forgotten – You have the right to request the deletion of your data we may hold.
• The right to restriction of processing – Under certain circumstances, you have the right to ask us to restrict processing of your data.
• The right to data portability – You have the right to ask that we transfer the data you gave us to another organisation, or to you, in certain circumstances.
• The right of access – You have the right to obtain a copy of all your personal data we may hold. 
• The right to lodge a complaint to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA arehere and the UKhere.

To exercise one of these privacy rights, please consult ourUser Choice Portal. Don’t worry, we will not discriminate against you for doing so. 

Data transfer outside the EU/EEA

During the delivery of our services, your data may be transferred to, and processed by us, our service providers and/or partners, in countries outside the EU/EEA that are subject to different standards of data protection which may not provide the same level of protection as your jurisdiction. In such cases, when these countries do not benefit from an adequacy decision under the Article 45 of the GDPR, we take appropriate steps to ensure that transfers of data are in accordance with applicable privacy laws and regulations, such as relying on the EU-US Data-Privacy Framework or requiring the recipient to comply with the Standard Contractual Clauses adopted by the European Commission.

Additional information for residents of regulated U.S States

Certain states, including California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia, have enacted consumer privacy laws that grant their residents certain rights and require specific disclosures (“State Privacy Laws”). If you are a resident of one of these states, this section applies to you. This section also serves as our California Notice at Collection.

This Policy explainshow we collect (including the sources of collection) and use,disclose, andretain information about you in connection with the Platform, including our activities that constitute targeted advertising, sharing, and sales of personal data as such terms are defined under State Privacy Laws. As required by certain State Privacy Laws, below we use a table to explain this same information, including the categories of personal data we collect, the types of entities to which we disclose it, and the ways we use each category of data. The table explains our practices today and over the preceding 12 months.

We generally do not collect information that is considered “sensitive” under State Privacy Laws

Your Rights

Your Opt-Out Rights

Certain disclosures described in the table above, in particular to advertising technology partners, may sometimes constitute a sale or sharing, or the use of personal data for targeted advertising as defined under State Privacy Laws. 

You may opt out of these activities by following the steps on ourUser Choice Portal. Note that because these opt outs are specific to the device or browser on which they are exercised, you will need to opt out on each browser and device. If you live in California or Colorado, you may also opt out by visiting our websites with a legally recognized universal opt-out signal enabled, such as the Global Privacy Control.

We do not knowingly sell or share personal information about consumers under the age of 16, or the permitted legal age, where older.

Your Other Rights

Access, Correction, and Deletion

You have the right to (1) request to know more about and access your personal data, including in a portable format, (2) request deletion of your personal data, and (3) request correction of inaccurate personal data.

You may exercise your rights by:

• following the steps on ourUser Choice Portal; or
• calling us toll-free on +1 (855) 590-4158.

Non-discrimination

As is your right, we will not discriminate against you for exercising your privacy rights.

Appeals

If we deny your request, you may appeal our decision by contacting us atdpo@ogury.co. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

Authorized Agents

If you are an authorized agent seeking to make a request to opt out of sales, sharing, or targeted advertising on behalf of a consumer, please email us atdpo@ogury.co.

If you reside in California, you may also designate an authorized agent to submit an access, deletion, or correction request on your behalf. We may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may contact the individual who is the subject of the request to verify their own identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a California resident, please email us atdpo@ogury.co.

Annual Request Statistics 

During the period January 1, 2023 to December 31, 2023, we received the following number of requests from individuals in the United States:

• Requests to know from individuals: 0 requests.
• Requests to delete from individuals: 0 requests.
• Requests to opt out from individuals: 0 requests.

Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, please contact Ogury’s Data Protection Officer:

• by email atdpo@ogury.co, or 
• by mail using the details provided below:
  • Ogury Limited – 3rd Floor, Classic House, 174-180 Old Street – London EC1V 9BP
• If you are based in the EEA, you can also contact our EEA representative by mail using the details provided below:
  • Ogury France – 52 rue de Dunkerque – 75009 Paris – France

Changes to this Policy

We review and update this privacy policy periodically in response to changing legal, technical or business developments. The date of its most recent revision is January 14th, 2025. If we make material changes to this Policy, we will post the updated version on our website and may take additional steps to notify you before the changes take effect.