While using our Ad Services, we may (but do not necessarily, or always) collect a variety of information from the End-User. However, our properties are designed to process information in such a manner that the information cannot be directly attributed to a specific, identifiable individual without the use of additional information (such as name, address, or email address). Below are some of 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;
• IP addresses, including both IPv4 and IPv6 are used to bid on advertising inventory;
• Geo-location data is used to bid on advertising inventory;
• Precise Location Data (data obtained from a device about the physical location of the device) is used to bid on advertising inventory;
• Precise Location Data (data obtained from a device about the physical location of the device) is used to bid on advertising inventory;
• GPS coordinates, where available;
• stored in browser cookies, are used for profiles on the ad servers;
• Mobile device identifiers are used to track mobile traffic and are shared with advertisers and agencies to tailor the advertising experience;
• Pixel Data (data obtained through or in connection with the placement of any pixel mechanism) is used as part of the user matching process;
• Other data on whether a user viewed or clicked on an Ad is shared with advertisers and agencies.

We use the information we collect for a variety of business purposes, including:

• Providing and improving our 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 can bid on and fill that inventory with relevant ads.
• Data modeling and behavioral targeting. To ensure the optimal use of our ad services, we develop and use data models that try to predict End-Users’ potential future behavior and interests on a per-device basis or across devices. This also allows us to effectively deliver highly-relevant ads to the right users;
• 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 behavior from occurring while delivering our Ad Services..
• 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 behavior 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, and finally, (iv) to ensure our terms and conditions are enforced.

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 when you visit SAPPOC’s Websites. We and our third-party partners may use cookies and similar tracking technologies to collect and use information about you.
• 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.
• APIs. An application programming interface (API), like the SDK, is used to call or request for information.

We use these tracking technologies to collect information automatically from End-Users’ devices. 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, our Clients may use information that we share with them to establish connections among related devices (such as smartphones, tablets, and computers) for targeted advertising, analytics, and reporting purposes. They may match an 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 Media Buyers 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.

While using SAPPOC Properties, visitors may be asked to voluntarily provide personal information. This might occur when visitors register for an SAPPOC 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.

We may use cookies and pixel tags on SAPPOC 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, and customize user experience. More information is provided on “Section 3 – Cookies and Similar Tracking Technologies.”

SAPPOC may obtain data from third party companies for the purpose of informing ad selection. This data is supplied in aggregate form and may include Personal Information as defined under the GDPR. SAPPOC Clients may collect Personal Information on their own websites. These details are provided directly by the individual Internet user through online order forms, contests, etc. Personal Data provided through an advertiser’s website is not visible to SAPPOC while being entered, nor provided to SAPPOC at any time in the future. This information collected by the advertiser is subject to the privacy policy of the individual advertiser involved.

The information we collect on SAPPOC Properties may be used for:

• Account management. Create access to an SAPPOC 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.

The information we collect is generally shared in relation to the use of SAPPOC Ad Services. Below, we detail some instances when information is shared:

• To Publishers: We may disclose information to allow them to analyze the effectiveness and performance of our Ad Services and to offer targeted ad inventory.
• To Buyers and Advertisers: We may share information we collect in connection with our Ad Services for purposes relevant to our business relationships with them, such as for billing purposes, dispute resolution, or fraud prevention and to allow them to make decisions regarding buying advertising inventory on our publishers’ digital properties and other websites and applications. 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, Their Marketing, and Service Providers: So they may provide targeted content and advertising to End Users on mobile websites and/or apps.
• To Other Third Parties that Target Advertising. This may include, for example, platforms that work directly with marketers (sometimes called demand-side platforms), analytics companies, data management platforms that help marketers maintain and use data, proximity solution providers, and other advertising technology 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.
• 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.

As Requested by the End-User. Lastly, we may disclose an individual’s information to any other person with the individual’s consent to such disclosure.

In connection with the GDPR, CCPA, and other relevant Privacy Laws, the SAPPOC Opt-Out process describes the steps you need to take to request the deletion or pull-out of data being used by our platform for internet-based advertising and cross-device targeting purposes.

You can opt-out by clicking the button below:

Opt Out

Please take note that this opt-out option is cookie-based. So if you change 0or update your browser, delete cookies, or switch to another device, you will have to repeat the process and opt-out again. Lastly, if your browser is using third-party cookie blockers, it may cause our opt-out option button to not work properly.

If you would like to opt-out of one of our Clients’ properties, you may check the opt-out process detailed in their site. You can usually find this information on their Privacy Policies or Web Opt-Out Policies.

End-Users who would like to opt-out or receiving advertising from our Clients on our own apps and partner apps, can do the following:

• iOS Users: Those with iOS 6.0 or higher can opt-out of most cross-app advertising by enabling “Limit Ad Tracking.” If you’re on iOS 7 or higher, go to Settings > Privacy > Advertising, and switch on “Limit Ad Tracking.” For those using iO6, go to Settings > General > About > Advertising, and switch on “Limit Ad Tracking.”
• Android Users: You can opt-out of most cross-app advertising with your Android device by going to Google Settings > Ads > Select opt-out of internet based ads.

Take note that the steps above are subject to possible changes made by the above platforms. If your device does not fall under the above categories, please check your device’s settings.

If you would like to opt-out of receiving promotional messages from SAPPOC via direct email marketing, click the “Unsubscribe” button located at the bottom of the email. Otherwise, you may contact us here. If you are one of our Clients, however, you may still receive emails from us that are relevant to our business relationship.

This Policy is limited to SAPPOC Properties and Ad Services. It does not cover, unless otherwise stated in this Policy, the privacy and information-collection practices of other third-parties, including our Clients or partners that use or link to our Properties and Ad Services.

When using our website, apps, and other properties, you may be directed to other websites, apps, and properties. This does not signify an endorsement on our part. SAPPOC is not responsible for third party privacy and information-collection practices. Moreover, this policy does not cover the collection, usage, and disclosure of information by other organizations, such as Facebook, Twitter, LinkedIn, and Google, where SAPPOC may also have social media pages. We encourage you to read and review third-party policies and terms and conditions and use third-party services at your own discretion.

SAPPOC End-Users have the right to request access to, change, update, or delete personal information as required. According to applicable laws, a small fee to access and disclose this personal information may be charged, but End-Users will be informed beforehand should this be the case.

Moreover, End-Users can withdraw consent allowing us to collect and process personal information at any time. Doing so will not affect the lawfulness of any data processing we may have done before the consent is withdrawn or impact any processing done within the bounds of applicable laws that previously depended on that consent.

European Economic Area (EEA) residents also have the right to (i) object to the processing or request portability of their personal information and (ii) complain to a data protection authority about SAPPOC’s collection and use of personal information. To exercise the right to object, email us at legal@SAPPOC.co. For more information about making a complaint, contact your local data protection authority via the information listed here.

We will retain personal information for the period necessary to fulfill the purposes outlined in this Policy and where we have ongoing legitimate business needs to do so (for example, to provide the Ad Services, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations) unless a longer retention period is required or permitted by law. We retain the information collected from SAPPOC Websites and SAPPOC Ad Services for as long as necessary to achieve our objectives as detailed in this Policy, and to comply with our legal obligations, resolve disputes, and enforce our agreements.

Residents of the European Economic Area (EAA), Switzerland, or the United Kingdom may obtain a copy of your personal information or request for an amendment or correction of such information by contacting us at legal@SAPPOC.co. More information can be found on Section 6.

We use reasonable organizational, technical, administrative, and physical safeguards to protect the personal information we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe and secure. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. If you have reason to believe that your data is at risk, please immediately notify us of the problem by contacting us here or emailing legal@SAPPOC.co.

SAPPOC is a global media and technology company. As such, we have offices located in multiple countries and also work with other global companies and technologies. Thus, this requires us to transfer your personal data outside the country where it was first provided. Moreover, SAPPOC Properties and Ad Services are hosted in both the United States and Singapore. Your data may be transferred to, stored, and processed by us in our facilities and our partners in locations where data protection laws may differ from the laws of your country of residence.

With that in mind, we have safeguards in place in accordance to relevant laws to protect your personal data. These include (i) requiring all group companies to protect personal data being processed in accordance with EU data protection laws by implementing the European Commission’s Standard Contract Clauses for transfers of personal information between group companies, and adhering to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement with regard to personal data.

The legal grounds for SAPPOC to process the Personal Information detailed above for the purposes covered in this policy are explained below:

• You have given consent. We primarily rely on your consent to gain access to and collect information stored on your device. This also applies when we work with publishers and mobile app developers as we contractually require them to only pass data that’s legally acquired. In relation to this, we understand that consent may be withdrawn at any time as explained in “Section 5.4 RIGHT TO PROTECT YOUR DATA.”
• It’s in line with our legitimate interests and that of our Clients. We rely on our legitimate interests and that or our Clients to process your personal information, except in cases when your data protection interests or fundamental rights are infringed upon. More information can be found in Section 2.2 and Section 3.2.
• Contractual and obligations. Some data may need to be processed to fulfill the terms in our contractual relationships (such as customer records and information) and to comply with legal or regulatory obligations. Should you require more information regarding our legal grounds for processing personal information, please contact via the information provided in Section 9 – CONTACT US.

When Personal Information is transferred outside of the EEA, Switzerland, or the UK, SAPPOC will put in place appropriate safeguards to ensure it’s protected. Moreover, your Personal Information will only be transferred to countries outside EU/EEA as permitted by applicable laws, such as based on your consent, based on the adequacy decisions of the European Commission, and by contractual regulations such as the EU Standard Data Protection Clauses. More information of how we handle International Data Transfers can be found in Section 5.7.

Under the GDPR, you are provided with rights with regard to the Personal Information we hold about you. These include the right to access data, to correct data, to object to its processing or withdraw consent, the right to erasure, and finally, the right to lodge complaints. More information can be found in Section 5.4 RIGHT TO PROTECT YOUR DATA.