PubGalaxy Platform Privacy Notice
We at Azerion Technology B.V. (“PubGalaxy”, “we”, “us” or “our”) respect your privacy and recognize the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. your personal data. “Personal data” is any information that relates – directly or indirectly – to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.
PubGalaxy (our “Platform”) provides a variety of online advertising-related services that help our clients to monetize their advertising spaces, buy and sell online ads through programmatic advertising (“Platform Services” or “Services”). Throughout this notice we refer to our third parties that sell advertisement space as “Publishers”. Publishers own or operate digital properties (e.g., websites, apps, Smart TVs, etc., “Digital Properties”) you may use or visit. We refer to third parties that buy advertisement spaces as Supply Side Platforms (“SSPs”). Our technology helps SSPs to serve advertisements that you see online such as in web pages, apps, and video content. This Privacy Notice applies whenever you visit Digital Properties of Publishers using our technology or our third parties use any of our other Services. Please note that PubGalaxy is also integrated with our own SSP solution, Improve Digital. Please see here for the privacy notice of Improve Digital.
The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) related to the use of our Services. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.
In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.
- Who is responsible for the processing of your Personal Data
Azerion Technology B.V. Boeing Avenue 30, 1119PE Schiphol-Rijk, the Netherlands, is responsible (“the data controller”) for the processing of your Personal Data related to the use of our Services when Publishers integrate our technology or use our Services.
- What types of Personal Data do we process and how do we collect it?
When you use our Services or visit Digital Properties of Publishers using our technology, as further explained, we collect, use, store and transfer different kinds of Personal Data via a Prebid process, which will be triggered by our script that we provide to our Publishers for them to insert their website HTML code or in their Software Development Kit (“SDK”**). 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.
**SDK is a collection of software programs for the purpose of creating applications across web and/or mobile platforms for a particular operating system.
The information we collect depends on which of our Services you use and how you use them. We process the following types of your Personal Data:
2.1 Personal Data provided by you
When you use our Platform as Publisher, you provide or be asked to give us certain information, including:
- Information provided in relation to our customer service: When you contact support, we collect information about your request (subject and content of your request) and your name and contact details.
2.2 Personal Data we collect from other third parties
In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data be provided by the following third parties:
- Your Consent String: When you visit Digital Property of Publisher, Publisher obtains your consent for our processing activities as well. If you provide your consent to that Publisher, we will receive your consent string which shall provide us your preferences on our processing activity, from Publisher.
- Technical information: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your devices includes the type of your browser or device, online identifiers (your IP address), site category, geolocation data (precise geographic location, if available from the device, and provided by Publisher, and/or imprecise location as derived from IP address or provided by Publisher), browser settings, screen resolution and other technical information. Depending on the third-parties available in the Digital Property of Publisher, if you enter your email address on the Digital Property of Publisher (either to register, log-in or subscribe to features such as newsletters), in a hashed and pseudonymous form, your email address is used to generate an identifier related to you. Please see Service Specific Information below for detailed information
- Ad information: We collect information about the ads that were shown, such as what type of ad, where in the page they appeared, and whether you interacted with them.
- Content information: We collect information about activity on Digital Property visited, such as pages loaded, or links clicked.
- Do we collect data from minors?
We do not intentionally collect and/or categorize personal information from children. In the event that we learn that we have collected personal data from a user under 16 years of age within the scope of the Services explained in this Privacy Notice, we will delete that data as quickly as possible. If you believe that a user might be under the age of 16, please contact our support team at PubGalaxy Support.
- For what purpose do we process your data?
Depending on which Services you are using and which privacy settings you have selected, we process your Personal Data for the following purposes:
Provision and improvement of our Services
- to allow you to use our Services
- to allow Publishers to use our Services and to integrate with third parties (e.g., traffic authentication solution providers, SSPs)
- to gain insights into the popularity of our Services
- to assess the quality of our Services
- to analyze the performance of our Services
- to aggregate financial reports to pay our business partners
- to pay our business partners for the promotion of our Services
- to provide customer support based on your questions, requests, or complaints
Marketing and analytics
- to deliver (targeted and non-targeted) advertising in our Services
- to measure the effectiveness of advertising
- to understand usage of our Services across all our group companies to support strategy and growth
Compliance with our legal or regulatory obligations
- to determine the legal requirements for processing of your Personal Data (based on your location such as your country)
- to respond to your requests related to your data subject rights
- to comply with our legal obligations (e.g., tax and accounting obligations)
- to inform you about any changes to this Privacy Notice
Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.
- Do we engage in profiling activities?
We do not use any personal data for profiling purposes. The data we receive or generate from the use of our Services allows us to analyze the performance of our Services and improve our services. You have the right to object to this type of processing. You can also go to your privacy settings to review and amend your privacy choices at the Publisher side related to this type of processing at any time.
- On which legal basis do we process your Personal Data?
We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:
As it is explained above when you provide your consent, we share your personal data to our SSP partners, please check their privacy policies for their processing activities.
- Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations. for example, for tax and accounting purposes or legal disputes.
- Performance of a contract: We process your Personal Data for the performance of a contract to which you are a party, for example, in the context of customer service.
Please see for additional information the section with service specific information below.
- With whom do we share your Personal Data?
We will not disclose your Personal Data to any party who is not authorised to process them. To manage our services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the gaming process and in each case only if access to your Personal Data is necessary for the performance of their roles.
Moreover, and 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 in connection with your use of our Services:
- External service providers: We share your Personal Data with external service providers who perform services on our behalf, like IT services, hosting and content delivery services, data management services and traffic authentication solution providers. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
- Supply Side Platforms (SSPs): With your consent, we share your Personal Data with SSPs, including Improve Digital or allow these SSPs to collect your Personal Data when you visit Digital Properties of Publishers using our technology.
- Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.
- Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).
Please see the section with service specific information below for more information about the third parties we may share your data with. Furthermore, you can find the third parties your Personal Data may be shared with by clicking on the following link:
- Where will my Personal Data be processed?
In general, if you are accessing our Services from the European Union (EU) / the European Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with regard to certain activities described in this Privacy Notice, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.
- How do we protect your Personal Data
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.
- How long do we store your Personal Data?
We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Please see below for information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.
- What are your rights in respect of your Personal Data?
To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:
- 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.
- Object to the processing on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. 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 defence 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.
- How can you contact us?
If you have any queries about this Privacy Notice or how we use your Personal Data, please contact us via our Website or our Data Protection Officer via e-mail to firstname.lastname@example.org.
- How often do we update this Privacy Notice?
We regularly review and update this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Website.
This Privacy Notice was last updated on: 11/08/2023
Additional Information for California Residents
This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, 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 Privacy Notice.
We do not sell your Personal Data. However, 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
Category H – Audio, electronic, visual, thermal, olfactory, or similar information.
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 know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.
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.
Under the CCPA, you have the right to opt out of any sale of your personal data. 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.
You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.
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.
SERVICE SPECIFIC INFORMATION
In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.
PubGalaxy is hosted and uses Amazon Web Services to provide its Services to its clients. All the above mentioned data is being stored in Amazon Web Services. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.
If you contact us for customer support by using our email address, we will process your email address, and the content of your request in order to provide you with support. The request history helps us to solve a newer request and is stored to defend possible future legal claims. We process this data on the basis of performance of contract to provide you with customer support and store this data on the basis of our legitimate interest, to improve our services, and to be able to defend possible future legal claims.
Our Platform helps our publishers to monetize their advertising spaces, buy and sell online ads through programmatic advertising. We use Google Ad manager to manage our Platform. In order to show you personalised ads and only if you have provided your consent at Publisher side, we will share your Personal Data (your IP address, advertising identifiers and the information that you have provided your consent for personalised ads) with SSPs, third-party advertisers and ad networks. You can adjust your preferences at any time in your privacy settings. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific. We also use this information to measure how effective our Services are.
Publisher Identifier Features
To ensure our advertising processes are stable and suitable for long-term use, make sure that ads you view on Digital Properties of Publisher are more in line with your expectations and interests, we rely on privacy-first authentication solutions provided by our third-party partners. When you provide an identifier on the Digital Property of Publisher (such as providing your email address either to register, log-in or subscribe to features including newsletters), based on your consent, our script that we provide to our Publishers collects this identifier in a hashed and pseudonymous form. This enables us and our third-party partners that are part of this process to identify you by using information that is directly collected from the Publisher without the involvement of third-party cookies and without using any personally identifiable information as an identifier. This identifier is then shared with third parties for advertising-related purposes. While this is the general setup, the technical integration and process of sharing of identifiers differ between third-party partners involved.
When we use Amazon Publisher Audiences for this, based on your consent, your identifier entered on the Digital Property of Publisher is collected and hashed. The hashed record is then shared with Amazon which is able to transform the hashed information into a unique identifier. Publishers are able to use this unique identifier while monetizing their advertising spaces.
Google’s Publisher Provided Identifier (PPID) is an audience management solution that enables us to assign identifiers. Unlike the general setup, PPID does not require an identifier provided by you, but when it is present (such as entering your email address on the Digital Property of Publisher), we can use it to assign an identifier to you. We will always check for a valid consent to associate you with a PPID, that is a hashed alphanumeric identifier. We upload PPIDs to Google Ad Manager. Via Google Ad Manager, this unique identifier string can be made available to programmatic advertising partners.
You have the right to withdraw your consent or opt-out to the processing of your personal data at any time. Please visit https://youradchoices.com to learn more and opt-in or opt-out.