Privacy Policy (UPDATED)

LAST UPDATED: JUNE 19, 2014

PubMatic, Inc. and its subsidiaries, including, as of the date of this Privacy Policy, PubMatic Limited, PubMatic GmbH, PubMatic India Private Limited, PubMatic KK and PubMatic Pte. Ltd. ("we," "our," "PubMatic") offer a strategic selling platform to premium publishers, which enables them to optimize their digital assets while protecting their brands. 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 media buyers. Ads that you see come from those media buyers, and usually the ad comes from an ad server with the same domain as the media buyer. Generally, a user will encounter an ad from one of our media buyers by viewing the content on a website or application owned or operated by one of our publishers.

We are concerned about privacy issues and want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through www.pubmatic.com and the other websites operated by us from which you are accessing this Privacy Policy (the "Websites"), through the software applications made available by us for use on or through computers and mobile devices (the "Apps"), through our social media pages and apps (collectively, our "Social Media Pages") as well as through HTMLformatted email messages that we send to you that link to this Privacy Policy and through our technologies used by our publishers, media buyers and third parties that we use to gather and process information on their behalf (collectively, including the Websites, the Apps and our Social Media Pages, the "Services"). By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

PERSONAL INFORMATION

Personal Information We May Collect

"Personal Information" is information that identifies you as an individual, including:

  • Name
  • Postal address
  • Telephone number
  • Email address
  • Profile picture

How We May Collect Personal Information

We and our third-party service providers may collect Personal Information in a variety of ways, including:

  • Our Websites, Apps and Social Media Pages: We may collect Personal Information through our Websites, Apps and Social Media Pages, e.g., when you request information about the Services through the "contact us” section of our website. We also may collect Personal Information in the Career section of the Website from those who submit a resume to PubMatic for recruiting purposes. Please see our Careers Privacy Policy for more information.
  • Offline: We may collect Personal Information from you offline, such as when you contact us by telephone or postal mail.
  • From Other Sources: We may receive your Personal Information from other sources, such as public databases; joint marketing partners; social media platforms; and other third parties.

How We May Use Personal Information

We and our third-party service providers may use Personal Information:

  • To respond to your inquiries and fulfill your requests.
  • To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
  • To send you marketing communications that we believe may be of interest to you.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed:

  • Among our affiliates (identified in the first paragraph of this Privacy Policy) for the purposes described in this Privacy Policy. PubMatic, Inc. is the party responsible for the management of the jointly-used Personal Information.
  • To our third-party service providers who provide services such as lead management, campaign measurement and other services.
  • By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public information, and may be available to users of the Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Services.
  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

Other Information We May Collect

"Other Information" is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

  • Browser and device information;
  • Mobile device identifier;
  • Information collected through cookies, pixel tags and other technologies;
  • Demographic information, including physical information
  • Information provided by you; and
  • Aggregated information.

We and our service providers may use Other Information to extract further related parameters, for example, we may extract information including but not limited to city, state, country and zip code and Designated Market Area ("DMA") from your IP address.

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

  • Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
  • Mobile device identifier: If the Website and / or Services are being used on a mobile device, we may also collect and use the device's unique device identifier or a unique identifier that we assign to the device. We use the identifier for purposes of cross-app advertising (as described below), as well as to deliver ads and provide advertising related services, such as providing a specific advertisement based on a particular time of day, statistical reporting in connection with the activity in an application, analytics and analysis, optimization of location of ad placement, ad performance, reach and frequency metrics (e.g., frequency capping), security and fraud prevention, billing, and logging the number and type of ads served on a particular day to a particular application or device. In addition, we may collect and analyze certain characteristics of an individual device and browser combination, in order to identify and probabilistically recognize the same device at a later point in time.
  • Through your use of the App: When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates. 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.
  • IP Address: Your "IP Address" is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use and disclose IP Addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
  • Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals or by receiving such information directly from our publishers. We may use your device's physical location to provide you with personalized location-based services and content. We may also share your device's physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners and media buyers to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device's location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners and media buyers may not be able to provide you with the applicable personalized services and content.
  • From you: Information such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Services.
  • By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services, (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

We Collect Other Information Using Cookies

We and our third party service providers may also collect Other Information using cookies.

Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, date and time an ad was served, clicks on ads, and other anonymous traffic data. We also use cookies and other files to track your use of the Services and other websites. We may supplement this information with information that we receive from a third party about advertising segments that might interest you, and we may share the supplemented information with our media buyers, who use it to target advertisements to you. If you do not want us to collect information from you through the use of cookies, please follow the instructions under "Opting Out of Cookies," below.

We and our service providers also use the information collected through cookies for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Services.

We can recognize your computer to assist your use of the Services. We also gather statistical information about the usage of the Services in order to continually improve the design and functionality, understand how the Services are used and to assist us with resolving questions regarding the Services.

We also use cookies in order to track when we deliver an advertising impression so that we can correctly credit it to a media buyer and invoice that media buyer. We may also use cookies in online advertising to track responses to our advertisements.

We will not collect or use sensitive information unless we have obtained your prior consent. Sensitive 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 (makeup, skincare, hair care, lotions, perfumes, etc.), items related to personal fitness, and dietary supplements. The health-related advertising segments that we use are: diet and fitness; doctors; health care professionals; health conscious; health and medicine; health and well-being; interest in health insurance; and pregnancy.

Opting Out of Cookies

For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

We are a member of the Network Advertising Initiative (NAI) and adhere to the NAI Code. If you do not want information collected by us through the use of cookies, 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. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer and you may need to log in every time you visit the applicable Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

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/.

Many of our media buyers and data providers are members of the Network Advertising Initiative (NAI) and/or participate in the Digital Advertising Alliance (DAA), both of which provide opt-out mechanisms for their respective members or participants. If you go to http://www.networkadvertising.org/managing/opt_out.asp or http://www.aboutads.info/choices/, you can learn how to exercise choice regarding the collection of information about your online activities over time and across third-party websites or online services.

Some 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 from a particular partner, or multiple partners.

Cross-App Advertising

We may deliver advertising to you while you are on your mobile device, based on information that we collect through applications on your device that are owned or operated by different parties. We are able to recognize your device on different applications through the unique identifier that we assign to your device. We may also use your physical location to deliver such advertising to you. We may share the information that we collect for purposes of cross-app advertising with our media buyers and service providers. We are a member of the NAI and adhere to the NAI Mobile Application Code. To learn how to exercise choice regarding the cross-app collection of information from your device, go to http://www.networkadvertising.org/managing/opt_out.asp.

Other Information Collected by Third Parties

Our clients (i.e. publishers) also collect information about you. They may choose to pass this information to us either directly through our Services or through application programming interfaces or APIs, when our services connect to their systems. APIs are 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, and occasionally uses publisher APIs to download data about users that is unique to those publishers.

The information our clients may share includes (but is not necessarily limited to) network type of a user's device, year of birth, ethnicity, gender, and precise geolocation. Some publishers may provide precise geolocation information collected on certain platforms.

Several of our media buyers also use Other Information. All media buyers may use their own data providers. In addition, media buyers' ads may link to landing pages that have their own data collection processes.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including our vendors or any other third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

You should always read the privacy policy of any website you access or social network page through which you share information carefully in order to understand their specific privacy and information usage practices.

How We May Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it as described in "How We May Collect Other Information" section above, as well as for all the purposes for which we use and disclose Personal Information.

We may disclose other information to publishers to allow them to analyze the effectiveness and performance of our service and to offer targeted ad incentory to our media buyers, and to media buyers to allow them to make decisions regarding buying advertising inventory on our publishers' websites and other websites and to analyze the effectiveness and performance of their advertising campaigns via our services.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contacting Us" section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

  • Receiving electronic communications from us: If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt-out of receiving these marketing related emails by contacting us at privacy@pubmatic.com.
  • Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you would prefer that we do not share your Personal Information on a going forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by contacting us at privacy@pubmatic.com.

We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

How you can access, change or suppress your Personal Information

If you would like to review, correct, update, suppress, or delete Personal Information that has been previously provided to us by you, you may contact us at privacy@pubmatic.com.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes. There may also be residual information that will remain within our databases and other records, which will not be removed.

RETENTION PERIOD

We retain the information we collect for purposes of serving targeted advertisements to you (including the segment information that we receive from third parties) for up to 90 days, unless we have not received any segment data for a user for 30 days, in which case the data for that user is no longer retained at that point in time. We retain impression information for up to six months. We retain raw ad server logs for our mobile ad server business for up to 9 months. We use precise geolocation solely for the specific ad impression to which the geolocation relates, after which the geolocation is aggregated with other geolocation data for use by us for analytical purposes. If we aggregate the information we collect in connection with the information we collect for targeting advertising purposes, we may retain that aggregated information indefinitely.

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

USE OF SERVICES BY MINORS

PubMatic's advertising products and the Services are not intended for nor directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Services.

CROSS-BORDER TRANSFER

The Services are controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities and/or employees, or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country of residence.

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 information received from affiliates and corporate customers in 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.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. Please take a look at the "LAST UPDATED" legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy or PubMatic's privacy practices, please contact us by email at privacy@pubmatic.com, or by mail at:

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

Please note that email communications are not always secure; so please do not include sensitive information in your emails to us.