MultiBrain INC. ("MultiBrain" or “We”) is committed to protecting consumer privacy and providing transparent information about the collection and use of personal information. This Privacy Policy ("Policy") outlines how MultiBrain collects, processes, and shares personal information when delivering mobile advertising automation technology and solutions to advertisers, buyers, app developers, and publishers of mobile apps and websites (collectively, "Clients" or “You”). Our practices are designed to ensure market quality and transparency, aligning with regulations on data privacy.

This Policy applies specifically to information gathered through MultiBrain’s Ad Services, which may include advertising, measurement, data validation, fraud protection, and related services. The Policy also explains your choices regarding the processing of your information within these services. The parties acknowledge that you shall act as a Controller and we shall act as a Processor of your Personal Information.

For purposes of this Policy, "Personal Information" refers to data that identifies or can be reasonably linked directly or indirectly to you or your household. This Policy does not cover anonymous, de-identified, or aggregated information as defined by applicable law.

MultiBrain collects various types of information to optimize ad delivery and provide a personalized advertising experience for End-Users. This section describes the types of information we collect through our Ad Services and how it may be used.

We collect Personal Information when you voluntarily provide it to us, such as when you give us feedback or request information. This Personal Information will only be used to respond to your feedback or fulfill your request.

To deliver relevant ads, MultiBrain may identify your device using unique identifiers, including:

Device-Related Identifiers: Including IP addresses, device type (e.g., smartphone), device model, operating system (e.g., Andorid), device language, carrier (e.g., Verizon), network connection type (e.g., WiFi or cellular), and hashed MAC addresses (MD5 format).

App-Related Identifiers: Such as the device’s Identifier for Vendor (IFV), an identifier unique to an app publisher.

These identifiers help us ensure ad relevance, perform frequency capping, and optimize ad delivery based on device and operating environment.

To enhance ad relevance, MultiBrain may use precise location data linked to your Device Identifier, such as GPS coordinates, which may be obtained from apps and websites where you have opted to share your location. Additionally, we may use data about device movement, proximity to other devices, and other available system data. Location data is used for:

Ad Targeting: To deliver ads based on relevant geographic areas or locations.

Performance Metrics: To analyze impressions, clicks, and other ad performance indicators to evaluate marketing impact.

If you prefer not to share precise location data, you can opt out using your mobile device’s settings. Ads will still be served based on broader location data, such as location inferred from IP addresses.

When you access our services through mobile websites or apps, we automatically collect certain information using "cookies" and other tracking technologies, including:

Cookies: Small data files stored by your device’s web browser that help us recognize your device, track user interactions, and personalize the experience. We use both session cookies (which expire once you close your browser) and persistent cookies (which remain until deleted) for tracking and analytics.

Log Files: We collect data such as IP address, browser type and language, device type, timestamp, amount of data transferred, referring page, and the type of content delivered.

You may adjust your browser settings to block or remove cookies; however, doing so may impact your experience with our services. This information helps us optimize ad content, track engagement, and improve the quality of our services.

MultiBrain may permit publishers and advertisers to use web beacons or "pixels" – tiny graphics similar to cookies – within advertisements to collect non-personal information or aggregate data. Pixels help us track ad engagement, such as views or clicks, and optimize the delivery of content.

Our partners may collect additional information via cookies, similar trackers and share it with MultiBrain. This data, including app or website usage details, is combined with the information we collect to enrich our insights and improve ad targeting. You may have the option to modify or disable data collection in your device’s settings.

For effective ad delivery, we share relevant data with our SSP partners and advertisers, including:

Device Information: Such as device type, manufacturer, model, operating system, carrier, and network type.

Geolocation Data: Town-level data (or more precise data with opt-in) is used by SSPs for targeted advertising. Users can opt out of precise location tracking if desired.

User Interaction Data: Information on ad views and clicks to assess ad performance.

Authentication-Derived Identifiers: Hashed identifiers (e.g., email or phone number) created using methods like SHA-256 or MD5 are used by DSPs to personalize ads. Note that no authentication-derived identifiers are collected from EU-based users.

By understanding how users interact with ads and gathering relevant device and location data, MultiBrain ensures optimized and relevant ad delivery for improved user experiences.

MultiBrain uses the information we collect to provide, optimize, and improve our advertising services, and to deliver relevant, personalized ads to users. The information we gather is essential for the functioning of our Ad Services, including ad targeting, reporting, and analytics. Below are the key ways we use the information collected:

We use the information we collect to deliver and enhance our Ad Services, including the optimization of ad delivery and ad targeting. This includes:

Device Identification: Using automatically transmitted device characteristics and identifiers (e.g., Device ID, IP address, operating system) to uniquely identify and link different devices used by the End-User.

Precise Geolocation: With user consent, we may collect and use geolocation data to serve location-based ads and to track ad effectiveness.

This data helps ensure ads are displayed to the right audience at the right time, improving overall ad performance.

MultiBrain works with publishers and app developers to offer advertising inventory, while advertisers and buyers (DSPs) bid on and place ads in that inventory. We use the data collected to:

Tailor Ad Content: Select and display relevant ads based on user behavior, interests, and device information.

Ad Placement: Ensure that ads are placed in the appropriate environments, whether on websites or within apps.

We may use the information collected to help our advertising partners predict future user behavior and interests. This allows advertisers to select highly relevant ads for the right users, based on data from multiple devices or specific devices. This process, known as behavioral targeting, helps improve the effectiveness of advertising campaigns.

Opt-Out Option: Depending on your jurisdiction, you may have the right to opt out of behavioral targeting. If you wish to opt-out, you can do so through the settings on your device or by directly contacting MultiBrain. For third-party publishers or advertising clients using our Ad Services, you will need to opt-out directly with them according to their privacy policies.

We collect data on ad performance, including impressions, clicks, and conversions, to:

A). Track Ad Effectiveness: Measure the success of ad campaigns, including metrics like click-through rates and app installs.

B). Generate Reports: Provide detailed performance reports to our clients, helping them assess the success of their campaigns and make data-driven decisions.

To ensure the quality and integrity of the data used in our Ad Services, we use the information collected to:

A). Validate Data: Match End-User information across devices and platforms to ensure the accuracy of data.

B). Prevent Fraud: Identify and filter out invalid impressions, clicks, installs, or ad queries, reducing the risk of fraudulent activities in our Ad Services.

We may use the information we collect for several essential purposes, including:

A). Compliance with Legal Requirements: To comply with legal obligations or respond to requests from government authorities, including those from the End-User’s country of residence.

B). Protection of Rights and Safety: To protect our business, our subsidiaries, our clients, and user privacy and safety.

C). Audits and Security: To conduct internal audits and assessments related to security, accounting, or corporate processes.

D). Enforcement of Terms: To ensure compliance with our terms and conditions, preventing misuse of our services.

Your Personal Information may be processed in the country where it was collected, as well as in other countries, including the United States, where data protection laws may be less stringent than those in your country of residence. When applicable, we will take appropriate protective measures to ensure the international transfer of Personal Information, such as:

A) . Standard Contractual Clauses (SCCs)

B). Transfers to countries with adequacy decisions

You have the option to opt out of certain data processing activities:

A). Limit Ad Tracking: You can limit ad tracking on your device through its settings, which will prevent ads from being selected based on your activities across different websites or apps. However, you will still see ads, but they may not be as relevant.

B). Opt-Out Cookies: For services using cookies, we offer opt-out cookies that allow you to decline ad targeting across the websites you visit.

By using the information we collect, MultiBrain ensures that ads are more relevant, helps improve our advertising services, and provides transparency and control to users over how their data is used.

At MultiBrain, we are committed to protecting your privacy. We do not sell, rent, or lease your personal information to third parties. We may, however, share your personal information with certain parties as described below, in accordance with this Privacy Policy.

Personal information related to you may be shared with our employees, external consultants, and affiliates, who are bound by confidentiality obligations and governed by this Privacy Policy. This ensures that your personal information is only used in accordance with the terms of this policy.

We may share personal information with third-party service providers, vendors and Sub-processors, including but not limited to: Cloud service providers, Analytics and anti-fraud partners, Advertising demand partners who assist us in providing our advertising services. These service providers, vendors and Sub-processors process your personal information on our behalf and are contractually obligated to maintain the confidentiality and security of your data. They are only permitted to use your personal information to the extent necessary to provide the services we request.

In the event of a merger, acquisition, or any other structural change involving our company, we may transfer your personal information to the acquiring or merging entity, provided that the receiving entity will continue to honor the terms of this Privacy Policy.

If our business is sold or transferred, or if we undergo insolvency or bankruptcy proceedings, your personal information may also be transferred as a business asset. Any acquiring company will inherit the rights and obligations regarding your personal information as described in this Privacy Policy.

We may disclose your personal information to public authorities in response to lawful requests, including those related to national security or law enforcement. We will disclose your personal information only to comply with relevant laws or in response to requests from law enforcement or other public authorities, where required by law.

We may share your personal information with third parties that you authorize or request us to send it to, such as service providers or partners with whom you interact through our services. This includes sharing your personal information with third-party advertising partners for the purposes of delivering relevant ads.

We may disclose non-personal information, including aggregated, de-identified, or anonymized data, to business partners, including analytics companies, advertisers, ad networks, and other third-party partners. This type of information is not linked to any specific individual and is used for general marketing, research, and analysis purposes.

You can opt-out of sharing your personal information with additional third parties by using the "Limit Ad Tracking" settings on your device. By doing so, you will continue to see ads, but they will not be tailored based on your activities across different websites or apps.

Our processing of your Personal Information is based on any of the following lawful grounds:

A). You hawe given consent to the processing of your Personal Information for one or more specific purposes;

B). processing is necessary for the performance of a contract to which you are party or in order to take steps; at the request of you prior to entering into a contract;

C). processing is necessary for compliance with a legal obligation to which we are subject;

D). processing is necessary in order to protect the vital interests of you or of another natural person;

E). processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;

F). processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal information, in particular where you are a child.

We retain various types of personal information about you for different lengths of time, depending on the purposes for processing, our legitimate business needs, and any legal requirements under applicable law.

We will keep your contact details to maintain communication with you. If you wish to delete your contact details, you can reach out to our privacy team at [email protected]. However, we may retain your contact details for necessary legal reasons or proceedings, even if we do not actively use them.

We will also retain personal information even after you leave our Website if it is reasonably required for resolving disputes, preventing fraud, or enforcing this Privacy Policy and our Terms of Use. We may retain aggregated, non-identifiable information indefinitely, but will delete or anonymize any potentially identifiable information once it is no longer needed for processing.

In general, we will retain your information as long as you continue using our Website, unless the law requires us to delete it or we decide to remove it at our discretion, as outlined in this Privacy Policy and our Terms of Use.

Multibrain takes reasonable and appropriate technical and organizational measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the personal information. We implement appropriate technical and organizational measures to protect personal information, including:

A). Encryption in transit and at rest

B). Access controls and authentication

C). Monitoring, auditing, and incident response plans

The following applies to all users, regardless of the legal frameworks governing the processing of their personal information.

We are committed to providing you with choices regarding how we use and share your personal information, and we will honor your preferences.

We collect and process personal information necessary for the purposes described in this Privacy Policy. You can stop using our services at any time, at which point we will cease collecting your personal information. However, as previously outlined, we may retain and continue to use or make available certain personal information as required.

You may request the termination of your account and the deletion of your personal information by contacting us directly. If you choose to terminate your account, we will delete your account information from our active databases, while securely storing all relevant data associated with the account.

You have the right to request a copy of the personal information we have collected about you. You can also request that we transfer your personal information to a third party of your choice or provide copies of your personal information to facilitate such a transfer.

When we delete your personal information, it will be removed from our active databases. However, we may retain a limited number of copies in our archives for legal or business purposes, as specified in this Privacy Policy.

lease note that while some web browsers offer a "Do Not Track" (DNT) feature, our Website does not currently respond to DNT signals.

A). Access your Personal Information

B). Request rectification or erasure

C). Object to or restrict processing

D). Request data portability

E). Withdraw consent at any time.

If you wish to exercise any of your rights regarding your personal information, please contact us by emailing "[email protected]".

You can stop using our services at any time. Additionally, you may control the personal information we collect from your device by adjusting the permission settings on your browser or mobile device.

To exercise any of the rights outlined in this section, please submit your request via email to [email protected].

Only you, or a person authorized to act on your behalf, may make a request related to your personal information. Requests for access may be made up to twice within a 12-month period.

When submitting your request, please ensure you provide enough information to allow us to reasonably verify your identity or authority to make the request, and detail your request clearly so that we can assess and respond accurately.

If we are unable to verify your identity or your authority to make the request, or if we cannot confirm the personal information related to you, we will not be able to respond to your request. Any personal information provided in your request will only be used to verify your identity or authority.

We will notify you with the reason for the delay and the extended period in writing. Our response will be delivered either by mail or electronically, based on your preference.

We will not charge a fee for processing or responding to your request unless the request is excessive, repetitive, or manifestly unfounded. If a fee is applicable, we will inform you of the reasons and provide an estimate before proceeding with your request.

You will not be required to create an account to exercise your rights under this policy, and your access to or use of our services will not be restricted or priced differently simply because you have chosen to exercise any of your rights.

If you disagree with our response, you can appeal our decision by contacting us. We will review your appeal and provide a final response, including an explanation, within 60 days. If you are unsatisfied with our decision, we will provide information on how to file a complaint with the relevant supervisory authority or Attorney General.

If you are a California resident, state laws including the California Consumer Privacy Act ("CCPA") allow you to make certain requests about your personal information. Specifically, you may request us to:

Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information

The CCPA further provides you with the right not to be discriminated (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide our services to you. We also will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you.

Please also note that if your personal information has been collected by us as a result of a your use of Client’s services, we collect and maintain your personal information under the directions of the relevant Client. If these circumstances apply to you and you wish to access or delete any personal information that we have collected about you, please direct your query to the relevant Client as this may expedite the completion of your request. We nevertheless provide reasonable assistance to our Clients to give effect to consumer choices as appropriate and required by applicable laws.

The CCPA provides certain rights if a company "sells" personal information, as such term is defined under the CCPA. We do not engage in activities that would be considered "sales" of personal information under the CCPA and you may "opt-out" of certain sharing your personal information as described in Section 4.7 above.

Shine the Light Disclosure: The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, or if you are an authorized agent making a request on a California consumer’s behalf, please contact us at [email protected].

MultiBrain is committed to continually reviewing and improving its privacy practices. As part of this commitment, we may update this Privacy Policy from time to time.

Minor changes will take effect 14 days after the notice is posted. Significant changes, which could substantially affect the way we handle your personal information, will take effect 30 days after the notice is posted.

If any update to this policy materially reduces the protection of your privacy rights under the then-current policy, you will have the option to decline the new policy and stop using our Website. By continuing to use our Website after the updated policy takes effect, you agree to the revised terms.

Please note that if we need to adapt this policy to comply with legal requirements, the new policy will take effect immediately or as required by law.

If you have any questions or suggestions regarding MultiBrain’s Privacy Policy, please contact us at [email protected]. For your protection, please do not include sensitive information.