Privacy Policy

1. Identification of the person responsible for the treatment.
2. Essential points of our policy.
3. What information will we collect from you?
4. How will we use your personal information? What services do we provide?
5. What is the legal legitimacy for the treatment of your data?
6. Transfer of data and international transfers.
7. Exercise of your rights and Delegation of Data Protection.
8. Retention periods and Cookies.
9. Security and confidentiality.
10. Kids.
11. Update of the privacy policy.

1. Identification of the person responsible for the treatment.

RICH AUDIENCE TECHNOLOGIES, S.L. and RICH AUDIENCE INTERNATIONAL, S.L., is responsible for the treatment of your personal data in order to provide you with the services identified in section 4 of this privacy policy (the "Website").

RICH AUDIENCE TECHNOLOGIES, S.L. (Previously Pubnet Publicidad y Marketing S.L.) is a company with headquarters in Av. Francesc Macia 54, Floor 3, 08208, Sabadell, Barcelona, Spain and VAT number is ESB64388259 and RICH AUDIENCE INTERNATIONAL, S.L., is a company with headquarters in Av. Francesc Macia 54, Floor 3, 08208, Sabadell, Barcelona, Spain and VAT number is ESB66779976 (hereafter "Rich Audience").

At Rich Audience, we are committed to the fundamental right of the protection of your personal data and this privacy policy is intended to inform you of your rights under the General Data Protection Regulations ("GDPR").

We inform you that Rich Audience has a Data Protection Delegate in accordance with the GDPR, who is at your disposal for any questions or queries that you want to make in relation to this matter, and to which you can contact from here.

2. Essential points of our policy.

In this privacy policy, we explain each of the services that Rich Audience offers that require the processing of your personal data.

Therefore, you will be informed of:

• The purposes for processing your personal data or to which means Rich Audience treats your personal data.
• The legal basis that justifies said treatment for each purpose.
• If there is any communication of your data to third parties or an international transfer of the same. In this sense, we inform you that we do not transfer your data to any third parties, unless there is a legal obligation (derived from a request from the State Security Forces or Courts or Courts), or unless it is essential to lend you a service, in which case, we will ask for your express consent.
• The period of conservation of your data that is necessary to maintain the relationship or to provide the service or function that you have requested. Therefore, if we do not need your data to provide you with any services, these will be blocked and will only be accessible by the Public Authorities in case there are legal, administrative, and tax claims according to the deadlines established by each regulation. Once the blocking period has elapsed, the data will be completely deleted.

3. What information will we collect from you?

You should know that there are different ways to collect personal data:

1. The data that you provide us directly.
• We collect information about you when you contact us through the channels enabled for it, such as the contact form or when you register on our Website.
• When you contact us through these channels, we will request your express consent to collect your email, your name and surname, date of birth, and other data that may be necessary to meet your request.
• All the fields that appear marked with an asterisk (*) in the forms provided to you on the channels will be required to be completed, so that the omission of any of them could lead to the impossibility of being able to provide the requested services. You must provide truthful information, understanding that identity theft or the use of aliases or anonymous names is forbidden.
• You cannot, at the time of providing any data that you may be asked in the channels, choose injurious expressions, coinciding with brands, trade names, names or pseudonyms of characters of public or famous relevance for which use you are not authorized.
• It is essential that you safeguard at all times your reference data, passwords and access codes that you generate. You will be solely responsible for the use of your personal account, and in this sense, you undertake to make diligent use of said information, not to make it available to third parties, and to inform us, without delay, of any loss or theft of this information.
• In order for the information provided to always be up-to-date and free of errors, you must inform Rich Audience, as soon as possible, of any changes to your personal data that may occur through an email to the address given here.
• Also, by clicking on the "I accept" button (or equivalent) incorporated in the aforementioned forms, you declare that the information and the data that you have provided are accurate and true.
2. The data obtained indirectly.

When you browse, different cookies and other tracking devices can be installed on your device, as we explain in our cookies policy.

Likewise, for the advertising marketplace service that Rich Audience offers, and which allows the diffusion and advertising optimization in the media of our partners, a large amount of information can be gathered. However, this information does not allow the direct identification of any particular person. Below, we detail the information we collect on the platform:

• Device Identifiers: with the objective of controlling the frequency and delivery of the campaigns.
• Information related to the Device: with the objective of segmenting advertising to the appropriate devices and for statistical purposes.
• Non-precise position information (IP): with the objective of segmenting advertising for services and products available only in your country.
• Accurate position information (APP Only): Provided that the user has authorized the application to access this data, with the objective of segmenting advertising to services available in the geographical area.
• Events related to the ads: with the objective of controlling the diffusion of the campaigns, number of ad impressions, interaction with the ads, etc.
• Events related to the execution environment of the advertisement: Website information, content, page views, etc. with the objective of controlling the campaign's delivery environment and being able to apply Brand Safety measures.
• Public IP: The complete IP of the user is only used in a transactional way with our advertising partners (Sell Side Platforms, Demand Side Platforms and Brand Safety tools). In the rest of the cases, we work with the anonymized IP, eliminating the last group of information. For example, 192.168.10.100 is anonymized in the system as follows: 192.168.10.xxx or 192.168.10.0.

At Rich Audience, we take the privacy of users very seriously, which is why we limit the uses and situations in which information is collected indirectly. As a result, in many situations the collection and storage of data is totally excluded.

Some of the blocked uses are:

• Any data related to users under 16 years of age.
• Elements that allow the user to be identified, by way of example and not limitation: Name, address, place of work, date of birth, telephone number, email, etc.
• Elements related to confidential user data (health, political, religious or sexual orientation, etc.).
• Unique Technical Identifiers: Any mechanism that allows to identify the user in a unique way without the possibility of opposition by the user (MAC Address, Apple UDID, Machine Fingerprint, etc ...).

4. How will we use your personal information? What services do we provide?

Rich Audience acts as responsible for the processing of personal data for the following purposes:

1. Manage your access as a registered user.
2. Keep you informed about the products and services of Rich Audience, as well as send you news, notify you of events and other activities that are of interest to you.
3. Perform segmentation tasks and obtain profiles through the analysis of the use of the services offered.
4. Provide you with the services that you have requested and attend to your requests for information, as well as facilitate the exercise of your rights.

Additionally, Rich Audience acts as a data processor of personal data, which identifies or makes the user identifiable, for the provision of the Advertising Marketplace services, with the following purposes:

1. Analytics: Aggregate measurement of the data of each advertising action (number of impressions, clicks, interactions, etc ...) in order to report to the partners and clients of Rich Audience.
2. Ad serving and Frequency Control: With the aim of limiting the delivery and number of exposures of a user to the same advertisement (for example 3 times a day).
3. Re/Targeting: Rich Audience uses data that allows to segment the campaign to users based on the information collected (for example, its location, device, content visited, etc.).
4. Data shared with third parties: With the objective that independent companies help Rich Audience analyse results, measure delivery, segment ads, avoid fraud and, in general, audit the quality of service.

5. What is the legal legitimacy for the treatment of your data?

Rich Audience will treat your personal data in accordance with the following legitimizing bases, depending on the type of data that is provided, as well as the interactions that, as a user, you entail with Rich Audience:

1. The processing of your data related to the contact form, or commercial or advertising communications related to the products and services of Rich Audience are based on the management and processing of the legal relationship established between both parties, i.e., in the management of your own request, in the maintenance of the contact, in the provision of the service that you have requested and, where appropriate, in the legitimate interest of Rich Audience.
2. The treatment of your data for the purpose of segmentation and profiling, is based on your explicit, free and unambiguous consent.

6. Transfer of data and international transfers.

In Rich Audience, we do not transfer your personal data to third parties for their processing with the purposes described. However, if necessary, they will always be transferred based on a legal basis that legitimizes this processing.

Also, in certain situations at Rich Audience we share aggregate data with some of our business partners:

1. Technical Suppliers: This aggregate data does not allow user identification and can be stored by our business partners based on contracts signed with them. Likewise, they have authorization to store this information in their infrastructures (Data Centre / Hosting Providers) and the only authorized use for this information is that necessary to provide Rich Audience with the contracted service. For example, Ad-serving.
2. SSP / DSP Platforms - Each ad request is made available to Rich Audience customers through SSP and DSP platforms (real-time advertising sales platforms, also known as Real Time Bidding).

As a result of the execution of an announcement different third parties can run trackings, save cookies, as well as other data collection tools. These practices are governed by the privacy policies of each provider and can be accessed directly from their websites.

7. Exercise of your rights and Delegates of Data Protection.

We inform you that you can exercise the following rights:

1. Right of access to your personal data to know what data is being used and the operations carried out with this data.
2. Right to rectify any inaccurate personal data.
3. Right to delete your personal data, when possible.
4. Right to request the limitation of the processing of your personal data when the accuracy, legality or necessity of the use of the data is doubtful, in which case, we can keep this data for the exercise and/or the defence of claims.
5. Right to oppose automated decision-making.
6. Right to oppose the processing of your personal data when the legal basis that enables us to process it, according to section 4 above, is the legitimate interest.
7. Right to the portability of your data, when the legal basis that enables us to treat those indicated in section 4 above relies in the existence of a contractual relationship or your consent.
8. Right to revoke the consent granted to Rich Audience.

You can exercise your rights at any time and for free in the following ways:

1. By sending an email to the address listed here identifying who you are and indicating the right you wish to exercise.
2. Addressing a written request to the following address: Rich Audience. Av. Francesc Macia 54, Planta 3. 08208, Sabadell, Barcelona, Spain, identifying who you are and indicating the right you wish to exercise.
3. In addition, when you receive any communication from us, you can unsubscribe from all future commercial communications previously accepted by going to the bottom of that communication and clicking on the unsubscribe button.

Likewise, we inform you that you have the right to file a claim with the Spanish Data Protection Agency if you believe that we have committed an infringement of the legislation on data protection regarding the processing of your personal data.

8.Retention periods and Cookies.

We will only keep your data for as long as it is necessary to offer you these services. Any of the data that you provide through our channels will be blocked as long as it is not necessary to manage the service and will only be available if there is a legal obligation (derived from a request from the Security Forces of the State or of Courts and Tribunals) as well as when you exercise your rights here.

In relation to your personal data obtained through our channels, Rich Audience uses Cookies according to the Cookies Policy that you can see here. In this regard, all data relating to retargeting is stored for a maximum of 12 months. Aggregate information regarding delivery and execution of campaigns can be saved for longer periods.

9. Security and confidentiality.

We are committed to the security of your information. In order to prevent unauthorized access or unauthorized disclosure of personal data, we have taken appropriate technical and physical measures, as well as management processes to safeguard and secure the information we collect from you.

In general, the information stored by our systems uses AES256 and/or FIPS-140 encryption. All our technical infrastructures have different access control mechanisms accepted as standard in the industry.

10. Kids.

Children under 16 years can not use the services available through the website without the prior authorization of their parents, guardians or legal representatives, who will be solely responsible for all acts performed through the website by minors under their care, including the completion of the forms with the personal data of said minors and the marking, where appropriate, of the boxes that accompany them. In this sense, and to the extent that Rich Audience does not have the capacity to control whether users are minors, parents and guardians must authorize the necessary mechanisms to prevent minors from accessing the website and/or provide personal data without their supervision, not giving Rich Audience any responsibility in this regard.

11. Update of the privacy policy.

We make our best efforts to keep our privacy policy fully updated monthly. If we make changes, these will be clearly identifiable in a clear and specific way, as allowed in the relationship we have established with you (for example: we can communicate these changes by email).