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PUBMATIC PRIVACY POLICY

Last Updated: August 7, 2015; Effective: September 1, 2015

We are concerned about privacy issues and want you to be familiar with how we collect, use and share information we receive about our clients and users and the options available to you. If you have any questions, you may contact us (see the "Contacting Us" section below.)

We are concerned about privacy issues and want you to be familiar with how we collect, use and share information we receive about our clients and users and the options available to you. If you have any questions, you may contact us (see the "Contacting Us" section below.)

PubMatic, Inc. and its subsidiaries, including, as of the date of this Privacy Policy, PubMatic Limited, PubMatic GmbH, PubMatic India Private Limited, パブマティック株式会社 (PubMatic KK), PubMatic Pte. Ltd., PUBM Serviços de Publicidade Digital Ltda and 据翼软件科技有限公司 ("we," "our," "PubMatic") offer marketing automation for publishers via a strategic selling platform, which enables publishers to optimize their digital assets while protecting their brands. Our platform is designed to help our publisher clients 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. As a user you may encounter an ad from one of our media buyer clients by viewing the content on a website or application owned or operated by one of our publisher clients.

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy covers the information that we may collect or receive across the Internet and other digital formats:

  1. from users who (i) visit www.pubmatic.com and other websites operated by us, including PubMatic’s client interfaces (the "Websites"), (ii) use our software applications (the "Apps"), (iii) use our social media pages (collectively, our "Social Media Pages"), and (iv) receive email messages that we send to you (collectively, the Websites, Apps and Social Media Pages, the "PubMatic Pages"); and
  2. through our technologies used by our publisher clients, media buyer clients 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"). In this second context, we act as processors for the clients who serve as the data controllers for the information that we obtain from them.

This Privacy Policy does not cover our privacy practices related to information submitted to the Careers section of the Websites. If you submit information to PubMatic’s Careers section of the Websites, please refer to PubMatic’s Careers Privacy Policy.

We may change this policy from time to time. Please consult the Privacy Policy regularly for updates. See "Updates to This Privacy Policy," below, for more information.

Opt Out: to go directly to our opt-out for interest-based advertising, click here: http://www.pubmatic.com/opt-out/

Choice and Access: to go directly to our section on Choices and Access regarding your Personally Identifiable Information, click here.

PERSONALLY IDENTIFIABLE INFORMATION

Collection of Personally Identifiable Information from the PubMatic Pages

"Personally Identifiable Information" is information that identifies you as an individual, including: name, postal address, telephone number and email address. We and our third party service providers may collect Personally Identifiable Information from you from the PubMatic Pages. For example, we collect your Personally Identifiable Information when you request information about the Services through our client user interfaces or the "Contact Us" section of our Websites or the "Featured Content" section of our Websites where you can download reports and white papers.

Use of Personally Identifiable Information

We and our third-party service providers may use Personally Identifiable Information collected from the PubMatic Pages:

  • 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, and
  • 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.

Disclosure of Personally Identifiable Information

Your Personally Identifiable Information collected from the PubMatic Pages may be disclosed:

  • among our affiliates (identified in the second paragraph of this Privacy Policy) for the purposes described in this Privacy Policy. PubMatic, Inc., is the party responsible for the management of the Personally Identifiable Information jointly used by it and its affiliates,
  • to our third-party service providers who provide services such as lead management, campaign measurement and other services,
  • directly 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 Personally Identifiable 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), and
  • 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.

Retention of Personally Identifiable Information

We will retain your Personally 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.

OTHER INFORMATION

Collection of Other Information

"Other Information" is any information that is linked or reasonably linkable to a particular computer or device, but does not reveal your specific identity or directly identify an individual, such as: browser and device information; time spent on the Services, pages visited, language preferences, date and time an ad was served, clicks on ads, and other anonymous traffic data; your precise location; unique identifier, including mobile device identifier or statistical identifier; demographic information, including physical information; information provided by you; and aggregated information.

We and our third party service providers may collect Other Information in a variety of ways, including through: your browser or device; your mobile device identifier; the use of statistical identifiers (which collect and use certain characteristics of your device to help us identify it over time); your use of the Apps; the use of pixel tags and other similar technologies; your IP address; the aggregation of information; and cookies (cookies are pieces of information stored directly on the computer that you are using).

Our publisher clients may also collect information about you that they choose to pass 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 allow one software program to access and make use of another software program. The information our publisher clients may share includes network type of a user's device, year of birth, ethnicity (where permitted by law), gender, and precise geolocation (where permitted by law). Some publisher clients may provide precise geolocation information collected on certain platforms. We will not use precise geolocation information for Interest-Based Advertising without your opt-in consent.

Use of Other Information

We may use Other Information from the Services:

  • to operate, improve, analyze and manage the Services,
  • to ensure the Services function properly,
  • for advertising purposes, such as using an identifier for interest-based advertising and ad delivery and reporting across websites, online services, and apps over time, including optimization of location of ad placement, ad performance, reach and frequency metrics, fraud prevention, billing, logging the number and type of ads served on a particular day on a device,
  • to track the actions of users of the Services, measure and report on the success of marketing campaigns via pixel tags (also known as web beacons and clear GIFs),
  • to identify and probabilistically recognize the same device at a later point in time for purposes of sending advertising or content to that device in mobile apps (using statistical identifiers),
  • to calculate usage levels of the Services, helping diagnose server problems and administer the Services via your IP Address (a number automatically assigned to the computer or device that you are using by your Internet Service Provider),
  • to provide you with personalized location-based services and content through the use of your device’s physical location (where permitted by law),
  • to track delivery of an ad impression,
  • to track your use of the Services to improve the design and functionality of the Services,
  • to supplement Other Information with additional information we receive from third parties such as advertising segments to allow us to target ads to you that may be of interest to you,
  • for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Services, and
  • 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.

We may partner with certain third parties to collect Other Information to engage in analysis, auditing, research, and reporting, as well as to deliver advertising that we believe may interest you based on your activity on our website and other websites over time. These third parties may set and access cookies on your computer or other device and may also use web logs or web beacons. For more information about these practices and how to opt out, please see PubMatic’s Website Cookie Policy.

At this time, we do not honor "Do Not Track" headers and similar mechanisms.

We will not use data we collect for the purpose of determining employment eligibility, credit eligibility, health care eligibility, or insurance eligibility and underwriting and pricing.

We will not collect or use sensitive data, such as Social Security Numbers or Government identifiers, insurance plan numbers, financial account numbers; information about past, present, or potential future health or medical conditions or treatments, including genetic, genomic, and family medical history; and sexual orientation unless we have obtained your prior consent.

We may receive the following non-sensitive health-related advertising segments that we use to target ads to you that may be of interest to you: diet and fitness; doctors; health care professionals; health conscious; health and medicine; health and well-being; interest in health insurance; and pregnancy.

Disclosure of Other Information

We may disclose Other Information:

  • among our affiliates (identified in the second paragraph of this Privacy Policy) for the purposes described in this Privacy Policy,
  • to our client publishers to allow them to analyze the effectiveness and performance of our services and to offer targeted ad inventory to our media buyer clients,
  • to our media buyer clients to allow them to make decisions regarding buying advertising inventory on our publisher clients' websites, other websites, and applications, and to analyze the effectiveness and performance of their advertising campaigns via our services, including sharing your device’s physical information to enable our media buyer clients to provide you with more personalized content and to study the effectiveness of advertising campaigns,
  • to our third-party service providers who provide services that enhance our services, and
  • 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.

In some instances, we may combine Other Information with Personally Identifiable Information (such as combining your name with your geographical location). If we combine any Other Information with Personally Identifiable Information, the combined information will be treated by us as Personally Identifiable Information as long as it is combined. We will not use PII merged with previously-collected Other Information for Interest-based advertising purposes without your opt-in consent.

Retention of Other Information

We retain Other 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 for the specific ad impression to which the geolocation relates, after which the geolocation information is aggregated with other geolocation data for use by us for analytical purposes. If we de-identify Other Information we collect in connection with targeted advertising purposes, we may retain that information, in an aggregated format, indefinitely. In such cases, we commit to not re-identifying the information.

CHOICES AND ACCESS

Choice and Access regarding Personally Identifiable Information

If you would like to review, correct, update, suppress, or delete Personally Identifiable Information that has been previously provided to us by you or you would like to request a copy of your Personally Identifiable Information held by us, you may contact us at privacy@pubmatic.com.

In your request, please make clear what Personally Identifiable Information you would like to have changed, whether you would like to have your Personally Identifiable Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personally Identifiable Information that you have provided to us.

For your protection, we may only implement requests with respect to the Personally Identifiable 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 also give you many choices regarding our use and disclosure of your Personally Identifiable 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 or by clicking on the opt-out link within the email message that you receive from us.
  • Our sharing of your Personally Identifiable Information with affiliates for their direct marketing purposes: If you would prefer that we do not share your Personally Identifiable 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.

Please also note that if you do opt-out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to the Services from time to time.

Opting Out of Interest-Based Advertising from Cookies

To opt out of receiving interest-based advertising (including retargeting) from PubMatic’s services through the use of cookies in your current browser and for more information on what it means to opt-out, please go to http://www.pubmatic.com/opt-out/.

See PubMatic’s Platform Cookie Policy and Website Cookie Policy for more information on how PubMatic uses cookies and other similar technologies.

For more 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 of Conduct, and we adhere to the Self-Regulatory Principles for Online Behavioral Advertising and the Application of Self-Regulatory Principles to the Mobile Environment published by the Digital Advertising Alliance (DAA). If you go to http://www.networkadvertising.org/managing/opt_out.asp, http://www.aboutads.info/choices/, or www.youronlinechoices.eu, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services or applications.

Some of our publisher 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 companies for these opt-out links if you no longer wish to receive targeted advertising from a particular company, or multiple companies.

Opting Out of Interest-Based Advertising in Mobile Applications

Our customers may display interest-based advertising to you in mobile applications, based on your use of mobile applications over time and across non-affiliated apps. To learn more about these practices and how to opt out, please visit http://www.aboutads.info/appchoices.

Opting Out of Statistical Identification in Mobile Apps and on Mobile Web Pages:

We offer mobile, in-app and mobile web page statistical identification opt-outs. Please go to http://www.pubmatic.com/opt-out/ to opt out from such statistical identification and for more information on what it means to opt-out.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personally Identifiable 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.

THIRD PARTIES

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 Personally Identifiable Information you disclose to other organizations through or in connection with the Services.

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.

SECURITY OF PERSONALLY IDENTIFIABLE INFORMATION

We seek to use reasonable organizational, technical and administrative measures to protect Personally Identifiable 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.

USE OF SERVICES BY MINORS

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

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, unless otherwise specified. 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, First Floor
Redwood City, California 94063, USA

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