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Privacy Policy for GENIEE SSP

Geniee, Inc. (“we”, “our”, or “us”) recognizes the importance of data protection for End Users and has established this Privacy Policy (this “Policy”) to appropriately handle personal data that we collect in connection with our advertising technology service, “GENIEE SSP” (the “Service”). The Service helps our clients (website and application publishers) manage and optimize their advertising inventory by facilitating ad transactions between them and advertisers. This Policy is in accordance with the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), the UK General Data Protection Regulation (the “UK GDPR”), and other applicable data protection laws and regulations (the “Applicable Laws”).

Any reference to “you”, “your”, “user(s)”, refers to the “End User(s)” who accesses websites, apps, or other digital properties that are being monetized through the Service so that we may deliver advertising and perform related activities.

1. Information We Collect

We will collect and process the following categories of personal data from you in relation to the Service:

• Gender;
• Age;
• E-mail address;
• IP addresses;
• Cookie IDs and other unique online and device identifiers;
• Mobile device advertising identifiers;
• Browser and device information;
• Geolocation information;
• Web browsing information derived from advertising impressions;
• Information about your engagement with ads and your behavior on digital properties, and;
• Information regarding inquiries or communication from you.

2. Purposes of Use of Personal Data and Legal Grounds for Processing

We collect and process your personal data primarily based on our legitimate interests to carry out our business, including operating and improving the Service, preventing fraudulent activities, and delivering relevant advertising. In such cases, we will balance the impact on your privacy against our relevant legitimate interest.

We may also collect and process your personal data, based on your consent or to comply with our legal obligations, depending on the specific purpose of use in connection with the Service.

We use your personal data for the following purposes:

(i)        Provision of the Service, including personalizing and delivering ads, providing location-based advertising, reporting on ad campaigns to our clients, limiting the number of times you see an ad (frequency capping), measuring the effectiveness of ads and ad campaigns, maintaining records of transactions, user actions and conversions, attributing purchases or other actions to ads, and associating devices or identifiers that may be related to each other;

(ii)       Administrative purposes, including handling administrative communications, providing various system functions, and performing related administrative tasks;

(iii)       Research and development, including conducting market research and developing new services and features aimed at improving user convenience based on analysis of website browsing history, usage patterns, and user preferences; and

(iv)       Marketing purposes, including using information for marketing and promotional activities in relation to our services.

Please note that we do not use your personal data to make decisions that produce legal effects concerning you, or similarly significantly affect you, based solely on automated processing, including profiling.

3. Disclosure of Personal Data

We may provide your personal data to the following recipients:

(i)         We may share personal data collected through the Service with our publishers to enable them to evaluate ad services effectiveness and performance, and to provide targeted advertising inventory to our media buyer clients;

(ii)        We may share personal data collected through the Service with our media buyer clients (e.g., DSPs and advertisers) to support our business relationships, including for billing, dispute resolution, and fraud prevention, assessing campaign performance, and delivering more personalized content to you;

(iii)       We may disclose personal data (including cookie ID, mobile device ID, or other unique identifier) to attribution and analytics partners associated with us, our publishers, or our media buyers for validating and measuring ad performance and effectiveness;

(iv)       We may engage third-party service providers, such as cloud service providers, customer support tool providers, and payment processors, to support the provision of the Service;

(v)       We may disclose personal data to public authorities in order to comply with applicable laws (including ordinances, court rulings, and administrative orders and recommendations);

(vi)       We may disclose personal data to our group companies. The list of our group companies is available [here].

(vii)      We may transfer personal data to third parties if we undergo or are considering a reorganization, merger, sale, joint venture, assignment, transfer, or other disposal of all or part of our business, assets, or stock (including during bankruptcy or similar proceedings); and

(viii)     We may disclose personal data to other partners or stakeholders involved in the provision and operation of the Service.

4. Sources of Personal Data

We primarily collect personal data directly from the End Users, including through cookies, device identifiers, and similar technologies when they interact with websites, applications, or other digital properties using the Service.

In certain cases, we may also obtain personal data indirectly from (i) publishers, (ii) other clients (such as our data providers), and (iii) third-party service providers listed in Section 3 (iv) above.

5. International Transfer of Personal Data

We may transfer your personal data to countries outside your country of residence (for End Users residing in the European Economic Area (EEA), outside of the EEA), including Japan (the “International Transfer”), for the purpose described in “2. Purposes of Use of Personal Data and Legal Grounds for Processing”.

When we conduct an International Transfer of your personal data, we will ensure that appropriate safeguards are in place as required by the Applicable Laws. Such safeguards may include reliance on an adequacy decision by the European Commission, the execution of the European Commission’s standard contractual clauses (SCCs), or other safeguards permitted under the Applicable Laws.

If you would like more information, such as obtaining a copy of the SCCs, etc., you may contact us as described in Section “11. Inquiries” below.

6. Retention Period and Security Measures for Personal Data

We will retain your personal data for as long as necessary to fulfill the purposes for which we collected your personal data. To determine the appropriate retention period for the personal data, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, as well as the applicable legal requirements.

In order to retain your personal data, we have implemented internal rules, an organizational structure, and appropriate supervision of employees, and have taken measures to prevent unauthorized access, etc., in order to protect against the risk of loss, destruction, alteration, or leakage of personal data.

7. Rights for Disclosure, Correction, Addition, Deletion etc., of Personal Data

You may have the following rights with respect to your own personal data, in accordance with Applicable Laws:

(i)         The right to seek access to your personal data (including copies thereof);

(ii)        The right to request correction of your personal data;

(iii)       The right to seek removal of your personal data (the right to be forgotten);

(iv)       The right to restrict (cease) the processing of your personal data; and

(v)        The right to receive your personal data in a structured, machine-readable form (the right to data portability).

These rights may be subject to limitations or exceptions under the Applicable Laws. For example, we may not be able to fulfill your request if complying with your request would infringe upon the rights of us or a third-party, or if we are legally required to retain certain information in the case of a deletion request.

If you wish to exercise these rights, you may contact us by mailing a letter to the address or sending an e-mail to the e-mail address listed in Section “11. Inquiries” below.

8. Right to Object to the Processing of Personal Data

You may have the right at any time to object to the processing of your personal data on the basis of our legitimate interests under the Applicable Laws.

If you wish to exercise this right, you may contact us as described in Section “11. Inquiries” below.

9. Right to Withdraw Consent

You have the right to withdraw your consent whenever we handle your personal data based on your consent under the Applicable Laws. Even if you withdraw your consent, the legality of any treatment on the basis of consent before the withdrawal of consent will not be affected.

If you wish to exercise this right, you may contact us as described in Section “11. Inquiries” below.

10. Right to Lodge a Complaint with a Supervisory Authority

You may have the right to lodge a complaint with a supervisory authority under the Applicable Laws. In the case of the GDPR and the UK GDPR, this includes the supervisory authority of your habitual residence, your place of work, or the place where an alleged infringement of data protection laws has occurred.

11. Inquiries

If you wish to exercise your rights or have any inquiries regarding personal data, you may contact us by sending a letter or an e-mail to the following addresses:

Geniee, Inc.

6th Floor, Sumitomo Realty & Development Shinjuku Oak Tower, 6-8-1 Nishi-Shinjuku, Shinjuku-ku, Tokyo, Japan

Contact Form: https://geniee.co.jp/inquiry/

The contact information for our representative in the EU is as follows:

TMI Avocats & Associés

40 avenue Niel, 75017, Paris, France

E-mail: Geniee_EUrep@tmi.gr.jp

The contact information for our representative in the UK is as follows:

TMI Associates London LLP

City Point, One Ropemaker Street, London EC2Y 9SS, United Kingdom

E-mail: Geniee_UKrep@tmi.gr.jp

The contact information for our Data Protection Officer is as follows:

E-mail: dpo@geniee.co.jp