Privacy Policy (UPDATED)

Effective: October 24, 2013

ABOUT PUBMATIC & THE CONTENT OF THIS PRIVACY POLICY.

PubMatic, Inc. and its subsidiaries offer a strategic selling platform to premium publishers, which enables them to optimize their digital assets while protecting their brands. We are headquartered in the United States, with several international offices. We provide this privacy policy ("Privacy Policy") so that we may inform you about how our services gather and process information on behalf of our publishers, demand partners and other third-parties. This policy also outlines our privacy practices on our corporate Web site, www.pubmatic.com.

After reviewing the Privacy Policy, if you have any further questions, please contact us at privacy@pubmatic.com.

PubMatic's platform is designed to help publishers increase the amount of revenue they make from advertising sales by increasing the overall competition among media buyers for each advertising impression displayed through the PubMatic platform. We are a publisher-focused company, but at the same time we maintain client relationships with demand partners. Ads that you see come from those demand partners, and usually the ad comes from an ad server with the same domain as the demand partner. Generally, a user will encounter an ad from one of our demand partners by viewing the content on a website or application owned or operated by one of our publishers.

A GENERAL NOTE ON INTERNET TECHNOLOGIES AND PRIVACY

Before you review this Privacy Policy, we recommend that you familiarize yourself with the following concepts and terms so that you can best understand how PubMatic uses data about you and other Internet users to display better, more interesting advertising to you as you browse the Internet.

Ad Tags: Ad Tags are pieces of code that allow the delivery of advertisements in the dedicated ad spaces on digital assets such as websites and applications. PubMatic's Ad Tags may transmit certain anonymous information about the web site, section of the site and size of the ad that we are optimizing.

API: An application programming interface or "API" is a particular set of rules and specifications that allows one software program to access and make use of another software program. It helps facilitate the interaction between applications, similar to the way the user interface facilitates interaction between humans and computers. PubMatic uses APIs for its real-time bidding service (as defined below), and occasionally uses publisher APIs to download data about users that is unique to those publishers. This data is only Non-PII data (as defined below).

Cookies: Cookies are small text files that web servers typically send to users' computers when they visit a website. Cookies can be read or edited when the user loads a website or advertisement from the domain that wrote the cookie in the first place. Cookies are used by companies to collect and send information about a user's website visit – for example, number of visits, average time spent, pages viewed, navigation history through the website, and other statistics. This information can be used to improve a user's online experience by saving passwords, or allowing companies to track and improve website loading times, for instance. Cookies can also be used to track a user's browsing or online purchasing habits and to target advertisements to specific users. Cookies cannot be used to access any other data on a user's hard drive, to personally identify them, or to act like malware or a virus. Users who prefer not to accept cookies can set their Internet browser to notify them when they receive a cookie or to prevent cookies from being placed on their hard drive. You can read more about cookies at http://www.allaboutcookies.org/cookies/.

Online: When we use the term "online" in this Privacy Policy we are referring to a state of digital connectivity, including, without limitation, via websites (whether accessed by a desktop, laptop, smart phone, feature phone, tablet, IPTV (i.e., Internet Protocol Television) or other device), mobile applications or any other digital or mobile content.

Personally Identifiable Information: We define personally identifiable information (or "PII") as information that can be used to personally identify an end user or can be used with other sources to personally identify an end user, including first and last name, email address, home address and telephone number. Information that is collected but which does not qualify as PII is called "Non-PII," such as page viewed, referring URL, mobile carrier, phone model, age, gender and zip code.

Real-Time Bidding: Real-Time Bidding (or "RTB") is a method of buying online advertising inventory by responding in real-time to an ad call with a "bid," usually priced by cost per thousand impressions ("CPM"), to buy that single impression and thus the opportunity to display an ad to that user. RTB buyers use multiple different data sources, including third parties, to more precisely target the ads they display.

Web Beacons & Pixels: A web beacon consists of a small string of code that represents a graphic image request on a web page, a page in an application, or in an email. A graphic image can be associated with the web beacon, but is not required. When an image is present, usually the image is designed to blend into the background of the web page, application, or email in which it appears. Often a beacon will be placed by an online data collecting company without an image, so it is invisible to the user, and in the smallest discrete space possible on the screen. This is a "pixel" and is essentially an invisible web beacon. Pixels and web beacons can be used for site traffic reporting, unique visitor counts, advertising auditing and reporting, personalization, and other uses. They do this typically by writing or editing cookies on each user's computer. Therefore, like cookies, they cannot be used to log keystrokes, copy personal files from your computer, or replicate like a virus. Most pixels and web beacons, including those used by PubMatic, collect only anonymous data.

PUBMATIC'S SERVICE & THE DATA IT COLLECTS

Our Collection Practices with Respect to Personally Identifiable Information. We do not collect PII via our services and take all precautions to avoid receiving PII from our clients. Notwithstanding the foregoing, we do collect PII on our Website (www.pubmatic.com) in the Career section from those who submit a resume to PubMatic for recruiting purposes, on the section of the Website where you can request information about our services, and via our publisher and demand partner portals and user interfaces. PII may include first and last name, company name and e-mail address. We retain resumes in case there is a future match with a role we are looking to fill. If you would like us to update, correct, delete or deactivate any PII that you have provided to us, please send your request to us at privacy@pubmatic.com and we will process your request within a reasonable period of time after receipt. Your PII may be stored and processed in any country where we have facilities and/or employees and by providing any PII to us, you consent to the transfer of such PII to countries outside of your country of residence, which countries may have different data protection rules from your country of residence. We Collect Non-Personally Identifiable Information About You.

We collect Non-PII via our services, including but not limited to your IP address, date, time, and time zone of the ad request, pages viewed, browser type, the referring URL, and your computer's operating system. We may use such data to extract further related parameters, for example, we may extract city, state, country and zip code from your IP address.

We collect Non-PII from visitors to this Website through persistent cookies. The Non-PII we may collect includes pages viewed, the time/date of your visit to this Website, and the referring URL. We may use this information to improve the Website, our services and our sales efforts.

Our Clients Also Collect Information About You.

Our publishers may choose to pass Non-PII about their online users to us (including network type of a user’s device, year of birth, ethnicity, gender, geo location, etc.), either directly through our services or through APIs when our services connect to their systems, to allow us to optimize their digital assets by delivering relevant ads by our demand partners to our publishers’ users. We also contract separately with data providers to supply audience data to both our publishers and our demand partners to help them in optimizing their businesses and for ad targeting purposes. Our publishers may collect PII (for instance, from the online registration forms that they may present to the users), but they do not transmit such PII to us. They may, however, transmit non-PII collected from such registration forms. If they inadvertently transmit PII to us and we become aware of that transmission, then we will take all the necessary measures to remove it and ensure that we also do not transmit it.

Several of our demand partners also use Non-PII. For our RTB demand partners, we share the same Non-PII which we collect with those demand partners with each ad impression that we deliver. All demand partners, whether RTB-enabled or not, may use their own data providers. In addition, demand partner's ads may link to landing pages that have their own data collection processes.

In all cases, please refer to the privacy policies kept by our clients for more information on their data collection processes and policies. We are not responsible or liable for the privacy practices of our clients. These clients are responsible for informing you and obtaining your consent, to the extent applicable, with respect to data they collect from you and shared with us. You should check the privacy policies of the websites you visit and applications you download to learn about the information they collect from you, how they store that information, who they share that information with, and how they and third parties use that information.

We Use Cookies And Web Beacons In A Variety Of Ways And So Do Our Clients.

We use cookies and web beacons for a number of purposes. We use them in order to track when we deliver an advertising impression so that we can correctly credit it to a demand partner and invoice that demand partner. We distribute our pixels to demand partners who wish to set- up retargeting campaigns (also called "remarketing" or "repurposing"). These demand partners place our pixels on web pages where they are authorized to do so and then, when our ad server indicates a user with that cookie is expecting an ad, they target an ad to that user based on the user's consumer interests that the demand partner inferred from the website where the pixel was placed. We also distribute our cookies and those of certain demand partners who buy media through our RTB product in the HTML code of the ads that we display. These piggybacked pixels allow those demand partners to map their anonymous user identification number ("UID") against PubMatic's own anonymous UID so that the demand partner can associate a user profile to a particular advertising impression in order to target better the ad they choose to display to that particular user's interests. Finally, we distribute pixels through Ad Tags for those data providers we have contracted with to supply data for our audience and data management services. These pixels are dropped through the delivery of advertisements from the PubMatic services, and associate demographic, behavioral, and other audience-related data from the data provider's user profile with that user to better target future advertisements to that user.

You Can Opt Out From Having Us Collect Certain Non-PII And From Having Our Clients Collect Certain Non-PII.

PubMatic's Opt Out Mechanism

If you'd like to opt-out from having PubMatic place cookies on your computer or device to collect ad targeting Non-PII in connection with our Service, please go to http://www.pubmatic.com/opt-out/. When you opt out, we will place an opt-out cookie on your computer or device. The opt-out cookie tells us not to collect your Non-PII for ad targeting purposes. We may still set cookies for non-ad targeting purposes such as frequency capping.

Please note that if you delete, block or otherwise restrict cookies, or if you use a different computer, device or Internet browser, you may need to renew your opt-out choice. You can tell if your browser, computer and device have the opt-out cookie present by reviewing your status at http://www.pubmatic.com/opt-out/.

However, if you do not opt out as explained above, then PubMatic may collect your Non-PII and perform audience or behavioral targeting on you so that our clients can display the most-relevant ads to you.

Opting Out Through The Network Advertising Initiative

Many of our demand partners and data providers are members of the Network Advertising Initiative which provides a universal opt-out mechanism for those entities. If you go to http://www.networkadvertising.org/managing/opt_out.asp, you will find the chance to opt-out from Non-PII collection by a number of different demand partners and data providers. If you opt-out through the Network Advertising Initiative (NAI), please refer to the FAQ available on the NAI website to understand how their opt-out mechanism functions.

Independent Opt Out Mechanisms

Many of our clients have their own opt-out mechanisms that are linked from their sites or their online-posted privacy policies. You should review the privacy policies of those partners for these opt-out links if you no longer wish to receive targeted advertising.

PUBMATIC'S SECURITY & STORAGE PROCEDURES FOR YOUR DATA

PubMatic is conscious of the importance of your data to you and conscientious about protecting that data from loss, theft, or misuse. All of the user data collected by PubMatic is stored using the same security measures that we use to protect our own proprietary corporate data. Only authorized users are able to access the data we collect and store. While we cannot absolutely guarantee the security of the data we store, we do use all commercially reasonable measures to protect this information.

We retain Non-PII that represents intent and interest segments collected via our services from third party service providers at a user level for up to 90 days and impression data which contains user IP address and other Non-PII through HTTP headers for up to six months. We retain the foregoing data in order to ensure that our services are functioning properly and to evaluate ways to improve our services. In addition, we retain data on an aggregated basis indefinitely for purposes of reporting and system analytics. If you have any questions about our security practices, please send an email to us at privacy@pubmatic.com.

PUBMATIC'S INFORMATION SHARING

Unless you otherwise permit PubMatic to share the Non-PII information we have collected about you, we will only share that information with the following third parties and in the following circumstances: (i) to the appropriate authorities when we reasonably believe we are obligated to do so by law, or in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person; (ii) to a court of law, arbitration panel, or similar body to enforce or protect our rights either under law or as granted by an agreement; (iii) to the company or entity that acquires all or substantially all of PubMatic's assets, including if the acquisition occurs as the result of PubMatic's bankruptcy; (iv) to publishers to allow them to analyze the effectiveness and performance of our services; (v) to demand partners to allow them to make decisions regarding buying advertising inventory on our publishers’ websites and to analyze the effectiveness and performance of their advertising campaigns via our services; and (vi) to third parties that help us provide the services to clients, or that enter into strategic partnerships with PubMatic which allow us to expand the services for our clients.

WE MAY DISPLAY CONTENT OR ADS FROM THIRD PARTIES

The Website may contain links to and advertisements for websites operated by third parties whose privacy practices may differ from PubMatic's. While we endeavor to associate only with reputable entities, PubMatic cannot be responsible for the privacy practices of these other websites. We encourage you to check the privacy policies of all websites that you visit.

THIRD PARTY VENDORS

We also work with third party vendors to improve our Website and services. These vendors use cookies, web beacons and other technologies to collect information about your online activity (e.g., the pages you have visited at the Website) in order to help us understand user interest and improve the Website and our services. You may opt out of most vendors’ use of cookies and other technologies by visiting http://networkadvertising.org/optout_nonppii.asp. Please note that if you delete, block or otherwise restrict cookies, or if you use a different computer, device or Internet browser, you may need to renew your opt-out choice.

Our Website may also include social media features, such as the Facebook Like or Tweet this button. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. These features are hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

We are not responsible or liable for the privacy practices of our vendors. These third parties are responsible for informing you and obtaining your consent, to the extent applicable, with respect to data they collect from you and share with us. You should check the privacy policies of the websites you visit and applications you download to learn about the information these vendors collect from you, how they store that information, who they share that information with, and how they and third parties use that information.

SENSITIVE INFORMATION

We will not collect or use sensitive information unless we have obtained, directly or indirectly, your prior consent. Sensitive personal information includes information we know to be related to medical information, but we may target ads based on expressed interest in particular health-related consumer products. For example, our publisher partners could retarget website visitors who showed interest in health and beauty products, items related to personal fitness, and dietary supplements.

PUBMATIC'S SAFE HARBOR STATUS

PubMatic adheres to the U.S. -EU Safe Harbor Framework and the U.S. -Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of PII from European Union member countries and Switzerland. PubMatic has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view PubMatic's certification, please visit http://www.export.gov/safeharbor/. In addition, you may view PubMatic’s Safe Harbor Notice located on this website.

CHILDREN UNDER 13 YEARS OF AGE

PubMatic's advertising products and the service are not intended for persons under 13 years of age, and are not intentionally developed for or directed to children. We do not knowingly solicit or collect any personally identifiable information from children under the age of 13, nor do we knowingly market our products or services to children under the age of 13.

CHANGES TO PUBMATIC'S PRIVACY POLICY

We may revise this Privacy Policy at any time. Any changes and updates to the Privacy Policy will be updated directly on this page. We encourage you to visit this page periodically to review our current Privacy Policy so that you will always know what information we gather and how we may use that information.

CONTACTING US

Should you have any questions in regards to this Privacy Policy or PubMatic's privacy practices, please contact our representatives at the following email address and they will be more than happy to clarify and assist you in any way possible: privacy@pubmatic.com, or by mail at:

PubMatic, Inc.
c/o Privacy
305 Main Street, Suite 100
Redwood City, CA 94063