AD Glob Media and Tapsomnia, a division of AD Glob Media, (collectively, "BTM") provide advertising technology services that allow publishers to display ads in their platform or products, and for advertisers to reach audiences that may be interested in their products or services. BTM's suite of advertising technology includes the BTM Application Programming Interfaces, Tapsomnia Exchanges and Software Development Kit, the BTM network, and the BTM websites (collectively, the "BTM Services").

We work with Publisher Supply Partners, Advertising Demand Partners, Data Partners, and Fraud and Measurement Partners (collectively, "BTM Partners") in order to provide the BTM Services. BTM Partners are each independent controllers of your data.

This Privacy Policy explains how BTM collects, uses, shares, or otherwise processes personal data.

• Section 1 describes how we process personal data about you when you interact with BTM Services, and how you can exercise control over our processing of your personal data.
• Section 2 describes how we process personal data about you if you visit BlueTrackMedia.com.
• Section 3 describes how we process personal data about you if you are a Publisher Supply Partner or Advertising Demand Partner that uses the BTM Services.

The last section covers other important information that applies to all our personal data processing activities, and explains how you can reach us with thoughts or questions about this Privacy Policy.

Section 1: Personal Data We Process to Serve Advertising

Personal Data We Collect About You

The primary focus of data collection by BTM Services is to prevent fraud. The BTM Services do not collect information such as your name, address, or email address. The data collected includes the following, but not limited to:

• Device identifiers such as your IP address.
• Information that a Publisher Supply Partner has collected about you and shared with BTM, such as geo-location data or iOS Identifier for Advertising (IDFA) or Android Advertising ID.
• Information about your device, such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, mobile browser (e.g., Chrome, Safari), and screen size.
• Information about ads clicked on, the app where the click originated, your network connection type, and whether you downloaded the advertiser's app.

How We Use the Personal Data We Collect About You

We use the personal data we collect about you through apps that have integrated the BTM Services for the following purposes:

• Serving Ads: Allowing Publisher Supply Partners to offer advertising inventory in their apps, and Advertising Demand Partners to bid on and fill that inventory with ads.
• Geo-Targeting: Allowing BTM and Advertising Demand Partners to serve ads based on your current or prior location, including through location-based targeting segments created by Data Partners.
• Ad Reporting and Conversions: Reporting to Advertising Demand Partners information about when and how you have been exposed to their ads or clicked on their ads, and reporting to Publisher Supply Partners information about when and how ads were shown on their properties and were clicked on.
• Frequency Capping: Preventing you from seeing the same ad or type of ad too many times.
• Fraud Detection and Prevention: Identifying invalid clicks (or ad queries) and protecting BTM and Advertising Demand Partners from fraudulent behavior. in order to help with anti-fraud, quality, and security efforts to ensure the safety, security, privacy, and accuracy of the BTM Services and the broader advertising ecosystem.
• Providing and Operating Our Services: Auditing, researching, and analyzing data in order to maintain, protect, and improve our Services, and to ensure that our technologies function properly.

How We Share the Limited Personal Data We Collect About You

We share limited personal data with partners for the following purposes:

• We share aggregate information with Advertising Demand Partners and Publisher Supply Partners to help them combat fraud and measure the effectiveness and value of our Services. For example, we provide Advertising Demand Partners with reports showing how many users clicked on their ads. We also provide Publisher Supply Partners with reports about the performance of their traffic.

Controlling the Processing of Your Personal Data

We give you control over the types of personal data we collect from you and how we process that personal data to personalize you.

European Economic Area, the United Kingdom and Switzerland

Consent: If you are located in the European Economic Area, the United Kingdom, or Switzerland, Publisher Supply Partners who would like us to serve you personalized ads must first obtain your consent so that they can process your peronal data, and share with BTM and partners, for this purpose. If you provide your consent, we may collect, use, share, and otherwise process all of the personal data described above for the purposes described above.

If you decide that you do not want a personalized advertising experience, we will not process your personal data for this purpose. However, we will still serve you contextual advertising.

Withdrawal of Consent:Publisher Supply Partners may provide a way for you to withdraw your consent directly from within an app. If you withdraw your consent from within an app, we will no longer collect, use, share, or otherwise process personal data from that app to personalize your advertising experience.

Unless we have another legal basis for storing your personal data, we will also delete or de-identify the personal data we have stored about you within 30 days when you use one of these methods to withdraw consent. We will also inform our current BTM Partners if you withdraw your consent so that they, as independent controllers of your personal data, can also respect your choice to withdraw consent.

Even if you do not consent to a personalized advertising experience, or you later withdraw such consent, we will still process your personal data when necessary to comply with law or to support our legitimate interests, as described below.

Legal Necessity: We will process personal data as necessary to comply with law. For example, we will collect your IP address to perform a lookup of your country so that we know whether you are located in the European Economic Area, the United Kingdom, or Switzerland.

Legitimate Interests: We will process personal data as necessary to support our legitimate interests, but we will protect your privacy in doing so. For example, even if you do not consent to a personalized advertising experience, we will still:

• Receive and send your IP address to our service providers for purposes of detecting invalid clicks and other fraudulent activity on BTM. In order to protect your privacy, we contractually prohibit our service providers from using this data for any other purpose, and we do not share your full IP address with any other BTM Partners.

Accessing, Restricting, and Rectifying Personal Data We Collect About You Through Apps, and Objecting to Our Use of Such Personal Data

BTM collects the minimum amount of personal data about you that is necessary to provide the BTM Services. As a result, we do not have sufficient information available to provide secure, authenticated access to the personal data that we store about you or to confirm that specific personal data relates to you. However, as noted above, if you live in the European Economic Area, the United Kingdom, or Switzerland, you can contact us to request we delete personal data.

Deletion

Unless we have another legal basis for storing your personal data, if you are located in the European Economic Area, the United Kingdom, or Switzerland, we will delete or de-identify the personal data we have stored about you within 30 days of proof of identity.

Privacy Practices of BTM Partners

BTM requires BTM Partners, who are each independent controllers of your personal data, to comply with all applicable laws and regulations, to comply with the BTM Publisher Supply Partner Policies and Advertising Demand Partner Policies, and to provide you with sufficient notice of their processing of your personal data.

When you consent to BTM’s processing of your personal data, you are also consenting to the processing of your personal data by the BTM Partners with whom we share your data. If you withdraw your consent (if you are located in the European Economic Area, the United Kingdom, or Switzerland) or opt-out (if you are located in the United States or another country), we will also inform our current BTM Partners with whom we have shared your data of your withdrawal or opt-out so that they, as independent controllers of your personal data, can also respect your choice. BTM Partners may also have separate legal bases for collecting, using, retaining, and sharing your personal data.

We encourage you to read BTM Partners' policies to understand their privacy practices, the legal bases for their processing of your personal data, and any additional options that they provide for exercising control over such processing.

Section 2: Personal Data We Process If You Visit BlueTrackMedia.com

Personal Data We Collect When You Visit BlueTrackMedia.com

When you visit BlueTrackMedia.com, our servers automatically record certain personal data in our log files. This web log information includes your IP address, browser type, operating system, the referring web page, pages visited, and cookie information. Like many websites, we use web log information, along with cookies, pixels, and similar technologies, to operate our websites, better understand how they are used, resolve technical problems, and enhance your experience on our sites.

Cookies are small files that websites place on your computer as you browse the web. A pixel is a small amount of code on a web page and is often used in connection with cookies. Most web browsers automatically accept cookies. In many cases you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. However, some features of our sites, such as those made available to Publisher Supply Partners and Advertising Demand Partners, may not function properly if you disable cookies.

Personal Data We Share When You Visit BlueTrackMedia.com

We use a variety of third-party services, such as Google Analytics, to help operate and understand the use of our websites. We may share personal data, such as cookie information, with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures.

Section 3: Personal Data We Process If You Are a Publisher or Advertising Demand Partner

Personal Data We Collect From Publisher and Advertising Demand Partners

To become a Publisher Supply Partner or Advertising Demand Partner, you will be asked to provide certain personal data, including your name, email address, physical address, phone number, and company name. You may be asked to provide additional personal data such as a username and password to register for a BTM account. This information is used to send information and updates on the status of your account for these BTM Services. To opt out of receiving email, please update your subscription settings in the BTM Services platform where you have the account.

If you are a Publisher Supply Partner, you also will be asked to provide personal data so that we can fulfill payment to you.

We will also collect web log information when you use our publisher and advertising demand portals on BlueTrackMedia.com, as explained in Section 2.

Accessing or Rectifying Your Personal Data as a Publisher Supply Partner or Advertising Demand Partner

We provide you with account tools to access, correct, or modify personal data you have provided to us in association with your Publisher Supply Partner or Advertising Demand Partner account.

Personal Data We Share and Disclose About Our Publisher Supply Partners and Advertising Demand Partners

We may disclose personal data about you when necessary to provide the BTM Services, such as for account inquiries or verification, or to enable participation in certain features of our mobile advertising exchange. We may also share information within our corporate family to provide, understand, or improve their or our services.

Other Important Information

Law, Harm, and the Public Interest

Notwithstanding anything to the contrary in this Privacy Policy or controls we may otherwise offer you, we may preserve or disclose information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the rights or safety of any person; to address fraud, security or technical issues; or to protect the rights or property of BTM or BTM Partners.

Change of Ownership

In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal data may be sold or transferred as part of that transaction. This Privacy Policy will apply to your personal data as transferred to the new entity.

Additional Information or Assistance

Thoughts or questions about this Privacy Policy? Please, let us know by contacting us at legal@adglobmedia.com or writing to us at the appropriate address below.

The data controller responsible for your personal data is AD Glob Media, LLC with an address of:

AD Glob Media, LLC
Attn: Privacy Policy Inquiry
1500 Market Street, Suite 3500
Philadelphia, PA 19102

Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our processing of your personal data and will always be at https://www.bluetrackmedia.com/privacy-policy.html. If we make a change to this policy that, in our sole discretion, is material, we will notify you via a banner on this website or, if you are a Publisher Supply Partner or Advertising Demand Partner, an email to the email address associated with your account. By continuing to access or use the BTM Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

Effective: May 25, 2018

Consent to Data Processing and Transfer

When you use or interact with any of the BTM Services, including by using websites or applications that have integrated the BTM Services, you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. This includes any information you choose to provide that is deemed sensitive under applicable law.

Irrespective of which country you live in, you authorize us to use your information in, and as a result to transfer it to and store it in, the United States and any other country where we, our service providers, and our BTM Customers operate. Privacy and data protection laws in some of these countries may vary from the laws in the country where you live.

Contact Us

If you have questions about this policy, or inquiries or requests regarding your information, please contact us at legal@adglobmedia.com.