Privacy Policy of the Services of the ayeT-Studios GmbH

The ayeT-Studios GmbH d/b/a “ayeT-Studios” and any future corporate affiliates (collectively, “ayeT-Studios”) put great efforts in making sure that personal information is safe and used only in full compliance with applicable data protection laws and regulations.

This privacy policy (“Policy”) explains ayeT-Studios’ privacy practices for processing personal information via ayeT-Studios’ Services (the “Services”). It applies whenever you access or use a mobile application or website that is connected and/or uses the Services (as applicable). Please take the time to read the full Policy.


The ayeT-Studios Services Privacy Policy


ayeT-Studios develops and operates several services in the ad-tech environment, such as a mediation platform, programmatic mediation platform, incentivized offer walls, direct sales service and other online advertising-related services, all of which may include advertising management services, such as optimization, ad serving, campaign management and the compilation of relevant statistical data (collectively, the “Services”).

This Policy explains ayeT-Studios’ privacy practices for processing personal information via the Services and it applies whenever you access or use the Property of a Supply Partner that is connected to and/or uses the Services. Our Services are not directed to children under 16 years of age and we do not intentionally or knowingly collect personal information on such users.


1. The Services


ayeT-Studios provides advertisers, agencies, DSPs and/or ad networks (collectively, “Demand Partners”) and website and/or mobile application/website developers and/or owners and/or publishers (collectively, “Supply Partners”; Supply Partner and Demand Partners are also referred to hereinafter as “Customers”) with the following Services:
- Mediation service, that enables Supply Partners to optimize placement of ads by third-party Demand Partners on their website or mobile application/website (“Property”) and for Demand Partners to buy ad inventory and serve ads directly on such Property;
- Programmatic Mediation service, that enables Supply Partners and Demand Partners to use programmatic auction for the sale and purchase of advertising space inventory on the Property;
- Offer Wall service, that enables Supply Partners and Demand Partners to use an opt-in scrollable offers which includes individual Ads to integrate into Property.
- Direct Sales service, that enables Supply Partners and Demand Partners to run ad campaigns on certain Property.
- From time to time, ayeT-Studios may offer ancillary services to the services described above and additional services.
- ayeT-Studios has no direct interaction with the individuals that visit Customers’ services (“Users”), except for the ayeT-Studios Offer Wall service where ayeT-Studios provides technical support only in behalf of Supply Partner to Users of the Offer Wall.
- ayeT-Studios’ Customers are required to provide an adequate notice to Users about this Privacy Policy and to provide a privacy policy of their own, as required by the applicable legislation.



2. The Personal Information that ayeT-Studios collects and receives


ayeT-Studios collects personal information in order to provide the Services and for other specific purposes, as described in this Privacy Policy. Please note that you are not required by law to provide ayeT-Studios with any personal information.

ayeT-Studios only collects information that the Supply Partner had instructed ayeT-Studios to collect, in writing, prior to such collection, and subject to your permissions inside the Property and/or your mobile device.

As an example, ayeT-Studios’ Software Development Kit (“SDK”) that may be installed on the Property you are using will not collect your location data unless you affirmatively allowed/enabled the Property to collect it. Other information may be received via an API integration between ayeT-Studios’ server and trusted third-party’s servers and additional information may be received by embedding tags on websites you visit.

From time to time, ayeT-Studios may use additional or alternative tools to collect information, in which case this Privacy Policy will be amended accordingly.

When interacting with the Property, ayeT-Studios may collect/receive the following information:

- Information about your device, such as device type and model, network provider, browser type, language.
- Information about the Property, such as package name, keywords, version.
- Information about your operating system, such as Android, iOS.
- Information about your mobile advertising identifiers, such as your Advertising ID (Apple: IDFA or Google: GAID).
- Information provided by your device, such as device IP address, network connection type and device GPS location (only if you provide permission).
- Information ayeT-Studios may receive from Supply Partners, such as your age, gender, zip code, GPS location.
- Information ayeT-Studios may receive from Third Parties about you from sources other than the Property, such as non-precise device location based on IP address, device specifications and User’s interests.
- Demographic and user interest data that you choose to share with us by taking part in surveys or similar. Those data collected through the survey process can be associated with aforementioned data / cookie collected data.


When interacting with the Property and you choose to participate in surveys or similar, ayeT-Studios may collect/receive and share the following information:

- ayeT-Studios may share your personal information and/or social-demographic information, including, without limitation, a unique identification number (“UID”), postal code, region, province, gender, marital status, education, ethnicity/race (where permitted by applicable law), employment related information, non-personally identifiable information on household members, consumer product and service usage and ownership (e.g., computers, cars, mobile devices, video games, etc.), home ownership, pet ownership, employment information (e.g., title, role, travel, industry, etc.), and social grade, with third party sample/market research companies (individually each a “Third Party MR Company” and collectively the “Third Party MR Companies”) for the following purposes:
a. Identifying client survey opportunities that you may be eligible for through the Third Party MR Companies; and
b. Disclosing such data elements to clients of the Third Party MR Companies for audience measurement services; and
c. Appending such data elements to completed client surveys and delivering the appended survey data to clients of the Third Party MR Company(ies) for analytical or research purposes; and
d. Other uses as set forth in their privacy policy.
- If you are eligible for a client survey opportunity offered through a Third Party MR Company, the Third Party MR Company will provide your unique identification number and a survey link to us and we will invite you to participate in the client survey through our incentivized offer walls. We will not share your name, email address, or phone number with the Third Party MR Companies. In connection with the sharing of your information with a Third Party MR Company, your information may be transferred and stored outside of your country of residence, including, without limitation, in the United States, and by agreeing to this privacy policy you are agreeing to the processing and exportation of your personal information as set forth in this Section. If you complete one of those surveys, your responses go to the MR company (not to us), and will be governed by the MR company’s privacy policy. If you have any questions about this data sharing or if you want to opt-out, please contact privacy@ayetstudios.com. If you opt-out, it is the responsibility of us to inform the Third Party MR Companies. Please note that ayeT-Studios is solely liable and responsible for managing all opt-out requests. Your participation in such survey opportunities does not entitle you to any benefits offered by, or membership with, the Third Party MR Companies.



3. What does ayeT-Studios do with Personal Information?


ayeT-Studios uses the personal information that it collects and receives -

- to provide the Services;
- to enable and optimize the Services’ tools and features
- to study and analyze the functionality of the Services, Customers’ and Users’ activities,
- to provide support,
- to measure the Services’ activity for pricing purposes,
- to maintain the Services
- to improve the Services and to continue developing the Services.


ayeT-Studios may use the information collected to evaluate Users’ interests and behavior on a pseudonymous, no-name basis in order to being able to deliver tailored content. If necessary, ayeT-Studios may use identifiable information to enforce its terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Services, and to take any action in any legal dispute and proceeding.

ayeT-Studios commits to process personal information solely for the purposes described in this policy. To the extent relevant and possible, ayeT-Studios will make efforts to maintain accurate information that is complete and up-to-date.


4. Sharing Personal information with others


ayeT-Studios may share personal information for the following purposes:

Share it with its trusted Demand Partners:

- For the purpose of serving you with contextual and/or targeted ads that are relevant to you and may interest you.
- For ad reporting purposes and for Demand Partners to have information about the performance of their ad campaigns and improve their ads performance over time.


Share it with Supply Partners:

-To help them understand how Users are engaging with ads, what kind of Users are most engaging with certain types of ads on their Property, and what kind of ads are published on their Property;


Share it with Third Parties:

- To receive additional data on you from sources other than the Property in order to help analyze and enrich the information collected on you, as well as serve you with more relevant and targeted ads on the Property and elsewhere.
- To receive Third Party’s services, such as fraud protection, bot detection, rating, analytics, viewability, geo location services, ad security and verification services.


Share it with ayeT-Studios’ corporate affiliates in order to provide the Services.

Share it with law enforcement and/or government agencies, courts, and/or other organizations: (a) as required by law, such as to comply with a subpoena, or similar legal process; and/or (b) when ayeT-Studios believes in good faith that disclosure/sharing is necessary to protect its rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

Share or transfer it, if ayeT-Studios is involved in a merger, acquisition, or sale of all or a portion of its assets, as part of such transaction. You will be notified via a prominent notice on ayeT-Studios’ website of any change in ownership or uses of this information. In any event, your information will remain protected under this Policy;

Share it in any other circumstances where ayeT-Studios receives your written consent.


5. Aggregated and analytical information


ayeT-Studios may use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies, and they may use their own cookies to provide their service (for further information about cookies, please see the ‘Cookies’ section in this policy).

ayeT-Studios uses the standard analytics tools such as:

- Google Analytics
- Google Firebase


and may use additional or other analytics tools, from time to time.

The privacy practices of these tools are subject to their own privacy policies and can be found here:

Google Analytics: http://www.google.com/analytics/learn/privacy.html

Google Firebase: https://policies.google.com/privacy


6. Cookies


Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie.

ayeT-Studios uses session cookies for legitimate purposes, such as facilitation of the use of the Property you use and its features and tools. To clarify, ayeT-Studios’ cookies do not collect any personal information about you. When you visit a website, the cookie can recognize your device based on internal identifier of ayeT-Studios’ systems and in the future, if you return to that website, it can read that cookie to remember you from your last visit. By keeping track of you over time, cookies may be used by ayeT-Studios and its Demand Partners Advertisers to deliver ads targeted to you and track your engagement with these ads.

If you wish to delete cookies or limit the kinds of cookies that can be placed on your device you need to check out the settings in your browser, use the ‘Help’ tab or look for settings like ‘Options’ or ‘Privacy.’ From there, you may be able to delete cookies, block them or control when they can be placed.


7. User Choice


If you have an account in the Services, at any time, you may disable your account through your account page or by sending an opt-out or account deletion request to: support@ayetstudios.com. Thereafter, ayeT-Studios will stop collecting any personal information from you.

However, ayeT-Studios may store and continue using or making available certain personal information that is related to you. For further information, please read the Data Retention section in this policy

If you wish to opt-out from collection and use of precise location data for advertising, you can turn location services off through your device settings. The latest versions of iOS and Android allow you to limit which particular applications can access your location information.

You also can limit the use of identifiers for ad targeting on your devices. If you turn on this setting, apps are not permitted to use the advertising identifier to serve consumers targeted ads.

As an example, for iOS, the controls are available through Settings > Privacy > Advertising > Limit Ad Tracking. For Android, Google Settings > Ads > Opt Out of Interest-Based Ads.

Although this tool will limit the use of tracking data for targeting ads, companies may still be able to monitor your app usage for other purposes, such as research, measurement, and fraud prevention.

You can reset the identifiers on your mobile device in the device settings. iOS users can do this by following Settings > Privacy > Advertising > Reset Advertising Identifier. For Android, the path is Google settings > Ads > Reset advertising ID.

Following such restart, the device is harder to associate with past activity, but tracking can start anew using the new advertising identifier.

If you delete all cookies, you’ll also delete the cookies that indicate your preference to opt out of targeted ads. Please note that even if you opt out of targeted advertising, a company may still use cookies for other purposes, such as to limit the number of times you’re shown a particular ad.


8. Your California Privacy Rights


If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of personal information relating third parties to which ayeT-Studios has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes.

To make such a request, please contact us at: privacy@ayetstudios.com.


9. Accessing Your Personal Information


At any time, you may contact us at: privacy@ayetstudios.com and request to access the personal information that ayeT-Studios keeps about you. ayeT-Studios may need to ask you to provide it with certain credentials to make sure that you are who you claim you are. If you find that the information on your account is not accurate, complete or updated, then please provide us the necessary information to correct it.

At any time, you may contact ayeT-Studios at: privacy@ayeT-Studios.com and request to access the personal information that ayeT-Studios keeps about you, and to verify the accuracy of the data.

If you’d like us to delete data that you have provided via the Property, please contact ayeT-Studios at: privacy@ayetstudios.com and ayeT-Studios will respond within a reasonable time after receiving your email.

Please be advised that ayeT-Studios may retain and use your personal information as necessary to comply with its legal obligations, resolve disputes and enforce ayeT-Studios’ agreements.

In addition, after ayeT-Studios deletes your personal information, residual copies may take a period of time before they are deleted from ayeT-Studios’ active servers and may remain in ayeT-Studios’ backup systems.

ayeT-Studios may redact from the data which it will make available to you, any personal information related to others.


10. Your EU Data Subject Rights


ayeT-Studios is committed to assist its controllers as to data subjects’ rights under the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR).

Please note that under the GDPR ayeT-Studios processes data provided into the Services as a processor and not as a controller (i.e. Supply Partners). As a processor, ayeT-Studios is committed to assist its controllers to fulfill data subjects’ GDPR rights.

Therefore, if you wish to exercise your rights under the GDPR or have any questions in this matter, please contact the relevant ayeT-Studios’ controller directly. When needed and upon request, ayeT-Studios will assist its controllers.

ayeT-Studios conducts periodical assessments of its data processing and privacy practices to ensure that it complies with this Policy, update the Policy when necessary, and ensure that the policy is properly displayed and accessible.


11. Data Retention


As a general practice, ayeT-Studios stores your personal information for as long as you use the Property and for a 30 days thereafter. ayeT-Studios uses your personal information in these cases for internal reporting, analysis and to provide the Services. ayeT-Studios may save and use your personal information, in certain required cases, for a longer period of up to 90 days after you discontinue using the Property, if ayeT-Studios needs your personal information for invoicing, reporting, discrepancy investigation reasons.

ayeT-Studios also uses and stores your personal information to prevent fraud. In certain cases, where ayeT-Studios suspects that the Property that you have used may be vulnerable to fraudulent activities, ayeT-Studios may store and use your personal information, if needed, after you discontinue using the Property for fraud detection purpose.

Please note that ayeT-Studios may be required to retain certain information by law. Aggregated data may be retained by ayeT-Studios for longer periods and via a third-party analytics platform.

ayeT-Studios will ensure that personal information processed for no longer than necessary for the purposes for which the personal information was provided.

In any case, as long as ayeT-Studios uses your personal information to provide the Service, ayeT-Studios will keep the information about you, unless ayeT-Studios is required by law to delete it, or if ayeT-Studios accepts your request to delete the information, pursuant to applicable laws, or if ayeT-Studios decides to remove it at its discretion.

As a Customer, as long as you use the Services, ayeT-Studios will keep information about you, unless it is required by law to delete it, or if ayeT-Studios decides to remove it at its discretion.


12. Transfer of data outside your territory


ayeT-Studios may store and process information in various sites throughout the globe, including in sites operated and maintained by cloud-based service providers.

If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you provide ayeT-Studios your express and unambiguous consent to such transfer.

If you are a resident of the European Economic Area (EEA), your personal data is processed and stored by Amazon Web Services (AWS) Cloud in the US on ayeT-Studios’ behalf in accordance with the highest degree of security of AWS.

ayeT-Studios may implement additional onward transfer mechanisms, as may be available from time to time.


13. Information Security


ayeT-Studios is committed to safeguarding the confidentiality of your personal information. ayeT-Studios and its hosting services implement systems, applications and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

As an example, ayeT-Studios limits access to information to authorized personal on a need to know basis in order to operate, develop or improve the Services.

While all measures provided reflect the current industry standard of security, ayeT-Studios cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.


14. Changes to this Privacy Policy


From time to time, ayeT-Studios may update this Policy. If the updates have minor if any consequences, they will take effect 7 days after ayeT-Studios posts a notice on the Services’ website. Substantial changes will be effective 30 days after ayeT-Studios’ notice was initially posted.

Until the new policy takes effect, you can choose not to accept it and terminate your use of the Services. Continuing using the Services after the new policy takes effect means that you agree to the new policy.

Note that if ayeT-Studios needs to adapt the policy to legal requirements, the new policy will become effective immediately or as required.


15. Contact Us


Please contact ayeT-Studios’s Data Protection Officer at: privacy@ayetstudios.com for further information.

Last updated: September 20, 2018