Terms and Privacy

Last Revised: 5 August, 2022 SelectMedia Ltd. and its affiliates (the “SelectMedia“, “we” or “us“) provides services to online content publishers (“Publishers“), under which the Publishers receive access to our digital ad placement marketplace (collectively, the “Services“), allowing such Publishers to deliver video content and display video ads on the Publisher’s online properties (the “Properties“). This Privacy Policy provides information regarding our privacy practices, including details with respect to the information that may be collected about end users that visit the Properties that embed our Services (“you“, “your” or “User“). Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use available at https://www.selectmedia.asia/terms-and-privacy/ (the “Terms“), which this Privacy Policy is incorporated thereto by reference. 1.Which information we may collect on our Users?

We may collect two types of data and information from our Users:

1.Personal Information – the first type of information we collect is information that identifies or may identify you with reasonable means (hereinafter “Personal Information“), including:

• Device and app information– this category includes your device’s type and model, system language, the device’s operating system (such as Android or iOS), carrier name, browsers installed on the device (such as Chrome or Safari), your device’s IP address, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or other types of unique device identifiers (a number uniquely allocated to your device by your device manufacturer).

2. Non-Personal Information – the second type of information we collect is un-identified and non-identifiable information pertaining to an End-Users, which may be made available or gathered via the End-User’s use of the Services (“Non-Personal Information”). Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc. For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists. Types of Non-personal Information we collect from or about you:

• Ad information– this category includes information about the online ads and personalized content we have served (or attempted to serve) to you. It includes how many times an ad has been served to you, what page the ad appeared on, whether you viewed, clicked on or otherwise interacted with the ad, ad engagement history and whether you visited the advertiser’s website, downloaded an app or purchased the product or service advertised.

• Location information– the Company collects information about your coarse location (such as city and country). For example, we may use the IP address to identify your general location. This information does not tell us where your device is precisely located. This information is sent as a normal part of internet traffic.

• In addition, certain advertisers may also collect the precise location of your device (using GPS signals, device sensors, Wi-Fi access points, Bluetooth signals, Beacons signals and cell tower ids that can be used to derive or estimate precise location, or other geo-location data), when location services have been enabled by the End-User (you typically have to choose to turn on device-based location services).

• Technical and log information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g., the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).

• Analytics information: We collect information about your use of the Services, such as applications’ usage, log files, the End-User activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.

• Anonymous information: We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose, such as for advertising or marketing purposes.

2. How Do We Collect Information on Our Users?

There are two main methods we use:

1.We collect information through your interaction or use of the Properties. In other words, when you are using the Properties, including when you use the Service through any Properties, we are aware of it and may gather, collect and automatically record the information relating to such usage, either independently or through the help of third-party services as detailed below. This information includes information about the websites and apps you visit, the comments you submit or upload through the Properties, as well as information the developer or publisher of the Property provided to us.

2.We collect information which you provide us voluntarily. For example, we collect Personal Information which you voluntarily provide when you contact us directly.

3.When you communicate with us (for example when you send us an email with a comment or feedback) we collect the Personal Information you provided us with.

4.We also collect information (including Personal Information) about you from third parties, for example our business partners, for marketing purposes and to deliver products or services you request.

We store the Personal Information either independently or through the help of our authorized third-party service providers as detailed below.

3.What are the Purposes of the Collection of Information?

We collect Personal Information for the following purposes:

1.Personalizing your Experience – we will use and disclose your information (including your Personal Information) in order to provide and operate the Service, including for user authentication and identity verification purposes, as well as to enable us to provide our Users with a better and personalized user experience, with more relevant content and marketing materials; For example, we can suggest content that you might like based on your activity on our Service.

2.Security and protecting rights – we will use and disclose your information (including your Personal Information) to investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate any fraud, security or technical issues, or respond to a government request. We also reserve the right to disclose any information in case we believe, in good faith, that such disclosure is appropriate or necessary in order to enforce our policies, take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, protect the security or integrity of the Service and our servers and protect the rights and property of SelectMedia, its users and/or others.

3.Advertising – we also use and share your information, including Personal Information you volunteered to us, with our partners (in various jurisdictions around the world) for advertising purposes.

4.Direct Marketing – if you registered with our Service we may send you promotional material, either concerning the Service or our partners’ marketing products, which we believe may interest you. You may choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the unsubscribe link in the emails that you receive from us. Please note that even if you unsubscribe, we may continue to send you service-related updates and notifications;

5.Service Improvement – we will use and disclose your information to further develop, customize, and improve the Service based on Users common preferences and uses. 

6.Research and Analytics – we will use and disclose your information for statistical and research purposes, as well as to create and provide our business partners and affiliates with aggregated statistical data.

7.Communications – we use the information that we have to communicate with you – for example, we will use your contact details to respond to your queries or feedback, and to provide you with technical assistance and support.

4.Sharing Information with Third Parties

We work with third party companies, who integrate our Service on the Properties, as well as other third parties who help us provide and improve our Service or who use advertising or related products.

SelectMedia may share, transfer, and disclose to our business partners any Non-Personal and Personal Information, in order improve our Service.

SelectMedia may share Non-Personally and Personal Information in any manner required and permitted for such information, as well as  (i) with our third party business partners for use in advertising targeting (e.g. through ad networks or servers); (ii) for the purposes described in the section above.

Please note that any information you voluntarily make available through the use of the Service, including your Personal Information (e.g. your profile picture, email address, comments or any User Generated Content), is available to the public. You may change, at any time, your privacy settings in our Service or otherwise avoid posting such content through the Service.

Except as set forth herein, SelectMedia will not share any Personal Information it collects with any third party. Notwithstanding the foregoing, we may disclose Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the Terms, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User’s support requests; (e) to respond to claims that any content available on the Service violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of SelectMedia, its Users, or the general public; (h) when SelectMedia or any of its affiliates is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (i) to collect, hold and/or manage your Personal Information through SelectMedia’s authorized third party service providers (for example, Amazon Web Services or other cloud service companies), as reasonable for business purposes,; (j) pursuant to your explicit approval prior to the disclosure; or (k) to cooperate with third parties for the purpose of enhancing the User’s experience.

For avoidance of doubt, SelectMedia may transfer and disclose to third parties or otherwise use Non-personal Information at its sole discretion.

5.International Data Transfers 

Please note that our businesses, as well as our trusted partners and service providers, are located around the world. Any information that we collect (including your Personal Information) is stored and processed in various jurisdictions around the world (including in the United States), for the purposes detailed in this Privacy Policy. 

We use best efforts to ensure that your Personal Information is protected in accordance with our privacy policy, through contractual means (such as by using the contractual clauses approved by the relevant regulators for data transfer) or other means (such as ensuring that the jurisdiction imposes adequate safeguards for data protection). In any event, by using or accessing this Service, you consent to your information being collected, used, and transferred as disclosed herein. In certain instances, the data protection and other laws of these jurisdictions may not be as comprehensive as those in your country – but we will accord by the terms of this Privacy Policy.

6.User Rights

You may contact us at [email protected], at any time, and request: 

• To access, delete, change or update any Personal Information relating to you (for example, if you believe that your personal information is incorrect, you may ask to have it corrected or deleted);
• That we will restrict or cease any further use of your Personal Information (for example, you may ask that we will stop using or sharing your personal information with third parties). 

Please note that these requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.

If you have any general questions about the Personal Information that we collect about you and your End Users and how we use it, please contact us at [email protected].

Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection authority.

7. Deletion of Personal Information

We store our registered users’ Personal Information as long as they are active on our platforms (for example, when a user visited the Properties or commented on our platform). This information will be retained for up to two (2) years after the user last activity on our platforms.

If for any reason you wish to rectify, update or delete your Personal Information stored with us, please send us an e-mail to: [email protected], and we will make reasonable efforts to delete any such Personal Information pursuant to any applicable privacy laws.

8.Minors

To use the Service, you must be at least over the age of thirteen (13), unless the data protection laws in the country where you reside stipulate a higher age, in which event you must be at least over that age (“Age of Majority“). SelectMedia does not knowingly collect Personal Information from children under the Age of Majority and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the Age of Majority are not using the Service. In the event that it comes to our knowledge that a person under the Age of Majority) is using the Service, we will prohibit and block such User from accessing the Service and will make all efforts to promptly delete any Personal Information stored with us with regard to such User.

9.Security

We take a great care in implementing and maintaining the security of the Service, and the User’s Personal Information. The Personal Information is hosted on Amazon Web Services, which provides advanced security features. SelectMedia employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information. However, we do not and cannot guarantee that unauthorized access will never occur.

10.Third Party Software/Service

While using the Service we may be using third party software and/or service, in order to collect and/or process the information detailed herein. Such software includes without limitation [provide list of processors].

11.Third Party Services

While using the Service you may encounter links to third party Content, Properties and/or Third Party Sites, including through User Generated Content posted through the Service (collectively, “Third Party Services“). Please be advised that such Third Party Services are independent from SelectMedia, and if you click on any of these links, these Third Party Services may use cookies and other web-tracking technologies to collect non-personal and/or personal information about you. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such services. We encourage you to carefully read the privacy policies and the terms of use or service of such third parties, as their terms, not ours, will apply to any of your interactions with such third parties.

12.Tracking Technologies

When you access or use the Service, SelectMedia may use industry-wide technologies such as “cookies” (or similar technologies), which store certain information on your computer (“Local Storage“), and similar tracking technologies, which will allow us to enable automatic activation of certain features, and make your experience much more personalized, convenient and effortless. The tracking technologies used by the Service are created per session, do not include any information about you other than your session key, and are removed as your session ends. It is easy to prohibit the Local Storage. Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, your online experience may be limited. Please note that your browser enable you to disable all cookies (if you do not know how to do this, check out the “Help” file of your browser), however, this may interfere with your use of the Website or other internet websites. If you use a new computer, upgrade or change web browsers or take any action which results in the deletion of the “opt out” cookie, you will need to perform this opt-out process again upon any such change.

You can turn off the third party cookies for advertising purposes by visiting the Network Advertising Initiative.

13.Changes to the Privacy Policy

SelectMedia reserves the right to change this Privacy Policy at any time and at its sole discretion, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the Service, through our website or by sending you an e-mail to the e-mail address that is registered with your User Account. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

14.Representative for data subjects in the EU and UK

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/cc/selectmedia

15.Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to contact our Data Protection Officer, by sending us an e-mail at: [email protected], and we will make an effort to reply within a reasonable timeframe.