Azerion Global Corporate Privacy Notice

Azerion Group N.V and its affiliates and subsidiaries (Collectively or individually, as applicable, referred to as “Azerion”, “we”, “us” or “our”) respects your privacy and recognizes the importance of providing a secure environment for your personal data. We are committed to being transparent about how we collect and process your personal data.

Azerion is a high-growth digital entertainment and media platform while also acting as an intermediary service provider by providing a range of services to other parties such as media buyers, publishers and content providers.

This global corporate privacy notice (“Notice”) applies to all our services (websites, mobile applications and products including events, “Services”) operated by or on behalf of Azerion. It also applies to personal data we may otherwise collect: (i) when you interact with us by means other than an Azerion website or mobile application, for example, through our advertisements; and (ii) from our business partners.

Our different Services have different purposes and features. Accordingly, our Services have their own privacy policies or notices which explain their different features, data collection activities and purposes in detail. Each such specific privacy policy or notice supplements and amends this Notice.

1. Who is responsible for processing your Personal Data?

Azerion Group N.V and its affiliates and subsidiaries are responsible for the processing of your personal data.

2. What types of Personal Data do we process and how do we collect it?

When you use our Services, we collect, use, store and transfer different kinds of personal data. As a general principle, we do not collect and do not ask you to provide any “special categories of personal data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

The personal data that we collect from or about you falls into the following categories:

2.1 Personal Data provided by you

When you use our Services, you provide or asked to give us certain information, including:

- Your account information: On our Services, you have the option register. If you choose to create an account, we ask you to provide certain information to us such as your email address, username and password (hashed) in order to use our Services.

- Information provided in relation to our customer service: When you contact customer service by submitting a request, we collect information about your request (subject and content of your request) and your contact details

If you would like to find out what information you provide to us regarding a specific Service, you can reach us via dpo@azerion.com.

2.2 Personal Data we receive or generate from your use of our Services

When you use our Services, we also process device-related information and information about how you interact with our Services, including:

- Technical information: We collect data automatically from your device, including information regarding how you use our Services. Furthermore, Azerion collects data when you receive an ad delivered by us to a website or mobile application. You may or may not have the ad in-view, interact, or click on it.
  Information we collect automatically from you depends on the Services that you use. Generally, it includes your log-in events, IP or MAC address, device make, model and operating system, mobile network information, unique device identification number, advertising ID, browser type and its settings (such as language), geographic location (e.g., country or city level location or time zone) and other technical information such as information about cell information from the cellular network (for Android apps only) and types of connection (i.e. wifi or cellular).

- Cookies and similar technologies: A “cookie” is a file of information placed on your device when you visit a website. Cookies and similar technologies (such as pixels, web beacons, device fingerprints, etc. For the sake of consistency, all these techniques combined will be hereafter referred to as “cookies”) can enhance your user experience by saving your preferences, personalizing your online experience, and providing you with advertising which is tailored to your interests. We also use cookies for collecting personal data which are listed above. For more information on cookies, please see our Azerion Global Corporate Cookie Notice or specific cookie notices of our Services.

- Your usage: We collect information about how you use our Services. This information includes your preferences, such as your interests, the actions you take, the time and duration of your activity. Furthermore, we collect information about the websites that led you to our Website.

If you would like to find out what personal data we collect automatically regarding a specific Service, you can reach us via dpo@azerion.com.

2.3 Personal Data we collect from other third parties

We receive personal data about you from other sources such as user acquisition companies and social media networks when you choose to connect our Services by using them. When obtaining personal data from third parties, we endeavor to check that data collection done by these third parties is in line with applicable data protection laws and regulations, they have your consent or are otherwise legally permitted or required to disclose your personal data to us.

3. For what purpose we process your data

Generally, the personal data we collect are used to provide more tailored and relevant advertising experiences, to maintain and improve the Services and for other lawful purposes. More specifically, we use process personal data for the following purposes :

- Visiting our offices. In our Azerion offices we meet employees and visitors such as job applicants, suppliers and tradespeople, stakeholders, and any other individuals. If you visit our Azerion premises, you should be aware that we may request your personal data in order to administrate your presence, which will enable you access to our offices. We may also make use of CCTV systems (or other video devices) to record specific spaces of our premises. When we use such video devices, we place warning signs to make sure you are aware that we will record images or videos.

- Attending Azerion events. We regularly organize physical and digital events, such as seminars, workshops or fairs, meetings, webinars or live broadcast events. If you wish to attend one of our events, we will ask you to provide us with your personal data (such as your contact information).
  Keep in mind that we don’t publish lists of attendees for our events but, in rare cases, your contact information may be visible to other attendees.
  Sometimes, our events will be recorded. If we are recording and you are a presenter, your image and audio will be captured in the recording. If you are an attendee, in some cases, you may decide to share your image and audio during the session, for example, if you choose to interact in a Q&A session. For some events, we may publish the recording on our website or social media channels.

- Employee related processes: This includes activities such as job application, hiring, job offer, onboarding, payroll, benefits, training, performance reviews and promotions, complying with laws and regulations (e.g. employment laws, health and safety, tax, immigration, insurance), CCTV and check-ins into facilities, leave and absence management, and termination processes. In brief, we process personal data of employees (and candidates) to make sure that they are working in a safe and secure environment and to fulfil our legal obligations as an employer.

- Administer and improve our Services. This includes activities such as creating and managing your account, simplifying the registration process, identifying and fixing any bugs and errors, providing you with customer support, assessing the overall quality of our Service and aggregating financial reports to pay our business partners.

- Advertising and analytics. This includes activities such as making sure that you do not get the same ad delivered to you repeatedly, the websites you visit do not show advertising to bots and fraudulent traffic, paying our business partners for the promotion of our Services, measuring the effectiveness of advertising and acquiring new users on social media platforms.

- Managing your commercial relationship with us. If you have a commercial relationship with Azerion – as a (prospective) supplier, business customer or partner – we want to make sure that our relationship with you is founded upon transparency, clear accountability and trust. To manage this relationship with you and to ensure compliance with applicable laws, we may process personal data.

- Prevention of fraud and illegal activity. This includes activities such as investigating suspected or detected unauthorized and illegal activity on or through the Services and analyzing data related to fraudulent activities to prevent recurrences and design countermeasures.

- Ensure legal compliance. This includes activities such as enforcing our policies and terms of use, auditing our compliance with applicable law, complying with our legal obligations (e.g. tax and accounting obligations) and establishing, exercising, or defending legal claims. We will also process your personal data if we receive legitimate requests from law enforcement or similar authorities and we can also decide to report fraud and illegal behaviour to such authorities.

- Business process execution and internal management. This purpose includes activities such as conducting (internal) audits and investigations, management of alliances, ventures, mergers, acquisitions and divestitures, re-organizations or disposals and integration with sellers.

If you would like to find out how we use your personal data regarding a specific Service, you can reach us via dpo@azerion.com.

4. On which legal basis do we process your Personal Data?

Our legal basis for collecting and using personal data depends on the personal information concerned, the context in which we collect it and the applicable laws and regulations. We process your Personal Data for the purposes described in this Privacy Notice and in our different privacy notice;

- Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you use our Services for the first time, we ask your consent for the data processing in the context of sending newsletters, personalized advertising, analytics and profiling. We also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.

- Performance of a contract: We process your Personal Data for the performance of a contract or to take steps prior to entering into a contract to which you are party, for example, in context of customer service , where it is necessary for the creation and administration of your account, to support the operation of our Services or to facilitate the delivery of requested Services.

- Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations, for example, in order to verify your age, for tax and accounting purposes or legal disputes as well as any requests or claims from legal authorities.

- Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the service provided to you or to provide you with a better user experience and we transfer your personal data across all our group companies for administrative transfers as well as to identify/determine the size of the user base of our Services. We kindly remind you that you have the right to object to processing. We may also disclose your Personal Data to legal authorities for prevention of a crime, facilitation of an investigation related to public safety, and to protect the security or integrity of our Services.

If you would like to find out on which legal basis we process your Personal Data, you can reach us via dpo@azerion.com.

5. With whom do we share your Personal Data?

Only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data:

- Azerion affiliates and subsidiaries. Due to our global nature, your personal data may be disclosed to other Azerion affiliates and subsidiaries. We will make sure that access to your personal data will be granted on a need-to-know basis. In addition, keep in mind that our Azerion affiliates and subsidiaries are obligated to handle your personal data in accordance with our Azerion Privacy Policies. This ensures that your personal data will be processed by Azerion following the same data protection standards.

We share your personal data with our group companies which are responsible for internal analytics for the purposes of cross-product audience measurement. Where we share your personal data with our group company, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.

- Our service providers. The data that we collect or receive can be processed on our behalf by third-party service providers or sub-processors. We also use sub-processors to help us provide infrastructure services, such as hosting, content delivery networks (CDN), customer support functions,messaging (chat) services, payment service providers, payroll management, ERP and CRM systems, insurance services, health and safety, and benefits. We also use third-party service providers to ensure fraud prevention and security of our Services. Prior to engaging any third party sub-processor, Azerion performs due diligence to evaluate their privacy, security and confidentiality practices, and executes an agreement around data privacy and security.

- Our business partners. Azerion also provides, or enables others to collect, information for purposes of tracking and reporting campaign results of advertising campaigns. Where we offer games from third-party game distributors, your Personal Data can be processed by the third-party game distributors (directly or using cookies or similar technology). Please note that by choosing third-party games, you will be able to play the game in the third-party game developer’s environment over which the third party is in control.

- Third parties in connection with corporate transactions. At times, we may be involved in a merger, acquisition, bankruptcy, joint venture, reorganization, sale of assets or other disposition of all or any portion of our business, assets or stock. In these cases, we may share your personal data with the third party involved in that corporate transaction.

- Others. We provide personal data to any competent law enforcement body, regulatory, government agency, court or other third party (such as professional advisors) when we believe disclosure is necessary as a matter of applicable law or regulation, to enforce our terms and conditions, to protect the security or integrity of our Services, to exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person. Please also note that we can share personal data with third parties in order to protect our legitimate interests. For example, we may also disclose your Personal Data to legal authorities for prevention of a crime, facilitation of an investigation related to public safety, and to protect the security or integrity of our Services.

6. How do we protect your Personal Data?

Azerion has implemented appropriate measures to safeguard and help prevent unauthorized access, to maintain data security, and to correctly use the information we collect in relation to our Services. In order to help ensure a secure and safe experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

7. How long do we store your Personal Data?

Your personal data will only be stored for a period necessary to fulfill the purposes outlined in this Notice. We will, for example, periodically delete unused accounts from our Services and we regularly review and anonymize unnecessary data. Note that if you ask us to remove your personal data, we will retain your data that are necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Where will my Personal Data be processed?

Azerion hosts within the European Economic Area (“EEA”) and your personal data will be stored by Azerion in the EEA. To the extent that your personal data is processed by our partners in a country outside of the EEA, we have taken all such measures as are necessary to ensure an adequate level of protection for your personal data in accordance with the requirements of applicable data protection legislation, including but not limited to Standard Contractual Clauses.

9. Do we collect data from minors?

Generally, our Services are not directed to children under 16 (or other age as required by local law), and they do not knowingly collect personal data from children. In the event we find out that we have processed personal data of anyone under the age of 16 without parental consent, we will promptly delete such data.

Parents of users under the age of 16: if you wish to have access to your child’s personal data to view, correct, or delete the information that we have collected about your child, please send a written request to Azerion, Boeing Avenue 39, 1119 PE, Schiphol-Rijk, The Netherlands, detailing your request along with the proof that you are the parent of that user (to prevent misuse of requests for information), or send an email with all such information to dpo@azerion.com.

10. What are your rights in respect of your Personal Data

Your personal data is stored by Azerion and its business partners. In case the applicable data protection laws provide so, you have:

- Access the Personal Data we hold about you, including information such as the source and categories of data, the processing purposes, the recipients (or categories thereof), and the respective retention period.
- Request an update or correction of your Personal Data so that it is always accurate.
- Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
- Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
- Restrict the processing of your Personal Data, for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.
- Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.
- Right to object In the event and to the extent that we process your Personal Data based on our legitimate interests, you have the right to object to the processing on specific grounds relating to your particular situation. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims. You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.

11. Additional Information for California Residents

This section for California residents supplements the information provided in this Notice and applies solely to visitors, users, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Notice.

We may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)

Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D – Commercial information (such as purchase history)

Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)

Category G – Geolocation data

The CCPA provides consumers (California residents) with specific rights regarding their personal information.

You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions.

You have the right to opt out of any sale of your personal data by us to third parties. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.

Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

If you wish to exercise these rights, you can do so by sending an email containing your request to: dpo@azerion.com.

12. Additional Information for Brazil Residents

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

13. Additional Information for Turkish Residents

Under the law on the Protection of Personal Data No. 6698 was (the “KVKK”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

14. Questions about this Notice or our other Privacy Statements

If you have any questions about this Notice or a Specific Privacy Statement or our use of your personal data, please contact our Data Protection Officer via e-mail at dpo@azerion.com or please send a written request to Azerion, Boeing Avenue 30, 1119 PE, Schiphol-Rijk, The Netherlands.

15. Changes to our Privacy Notice

Azerion reserves the right to update or modify this Notice and any Specific Privacy Statements at any time. Accordingly, we regularly review this Notice and when there is a material change that will have a relevant impact on the processing of your personal data, these changes will be posted on this site.

This Privacy Notice was last updated on:

Version	Last updated
1.0	1 September 2022