Privacy Policy

1. Nature and Purpose of This Domain

is operated by the Operator as a node within a programmatic digital advertising infrastructure. It is not a consumer-facing application and does not provide services or products to individual end users. Its sole function is to support the technical delivery of advertising content within real-time bidding and direct advertising environments.

2. Data Processed Through This Domain

In the course of its technical operation, this domain may process the following categories of data:

• IP address and coarse geographic location inferred from it
• Device type, operating system, and browser attributes
• Request timestamps and HTTP metadata
• Referral URLs and advertising request parameters
• Online identifiers, including cookie IDs, mobile advertising identifiers, and hashed device signals

Such data is processed exclusively for the following purposes:

• Technical delivery of advertising impressions within programmatic and direct advertising environments
• Bid request processing and auction participation
• Frequency management and campaign pacing
• Detection and mitigation of invalid traffic, click fraud, and impression fraud
• Performance analytics and infrastructure security

This domain does not knowingly collect directly identifying personal data such as names, postal addresses, email addresses, or financial details.

3. Legal Basis for Processing

Processing is carried out on the basis of the Operator's legitimate interests in maintaining the secure, efficient, and commercially viable operation of advertising infrastructure, including fraud prevention and system integrity. Where the placement of cookies or equivalent tracking technologies requires consent, such consent is obtained either by the Operator's supply and demand partners or through consent management platforms (CMPs) deployed by the publisher properties in which advertising is served.

4. Profiling and Automated Decision-Making

The Operator does not carry out processing that constitutes solely automated decision-making producing legal or similarly significant effects on data subjects within the meaning of Article 22 of the GDPR. Where audience segmentation or profiling activities are conducted, these are limited to technical advertising purposes and do not produce decisions with legal or equivalent effect on individuals.

5. Cookies and Tracking Technologies

This domain may deploy cookies and functionally equivalent technologies as described in the Operator's Cookie Policy. These include technologies used for impression delivery, frequency capping, attribution, viewability measurement, and invalid traffic detection.

6. Disclosure to Third Parties

Data processed through this domain may be disclosed to the following categories of recipients:

• Demand-side platforms (DSPs) and advertising agencies
• Supply-side platforms (SSPs) and publisher technology providers
• Ad exchanges and header bidding partners
• Data management platforms (DMPs) and audience segmentation providers
• Independent measurement, verification, and brand-safety providers
• Fraud detection and traffic quality services

All recipients process data under appropriate contractual arrangements and are required to comply with applicable data protection legislation, acting as either independent controllers or processors as the circumstances dictate.

7. International Data Transfers

Given the global nature of programmatic advertising infrastructure, data may be transferred to and processed in jurisdictions outside the European Economic Area (EEA). Where such transfers take place, the Operator ensures that appropriate safeguards are in place, including Standard Contractual Clauses or equivalent mechanisms recognised under applicable law.

8. Data Retention

Technical operational data, including IP addresses, request logs, and HTTP metadata, is retained for a maximum period of 180 days from collection. Advertising identifiers, online identifiers, and data retained for fraud prevention and traffic quality purposes are retained for up to 2 years. Upon expiry of the applicable retention period, data is permanently deleted or rendered irreversibly anonymous.

9. Security

The Operator implements appropriate technical and organisational measures to safeguard processed data against unauthorised access, accidental loss, alteration, unlawful disclosure, or destruction, in accordance with applicable data protection standards.

10. Rights of Data Subjects

Subject to applicable law and any limitations permitted thereunder, data subjects may exercise the following rights:

• Right of access to personal data held by the Operator
• Right to erasure where no legitimate basis for continued processing exists
• Right to object to processing carried out on the basis of legitimate interests
• Right to rectification of inaccurate data
• Right to restriction of processing pending resolution of an objection or accuracy dispute
• Right to lodge a complaint with a competent supervisory authority

Please note that the right to data portability under Article 20 GDPR does not apply in this context, as processing is carried out exclusively on the basis of legitimate interests and not pursuant to consent or contract.

All requests will be assessed individually and may be subject to identity verification. Supervisory authority complaints may be directed to the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP) at www.dataprotection.ro.

11. Contact

Data protection enquiries may be submitted via the contact form. Please describe the nature of your request in sufficient detail to enable the Operator to respond appropriately.