Platform Privacy Notice

We at Hybrid Theory Global LTD (“Hybrid Theory”, “we”, “us” or “our”) respect your privacy and recognize the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.

The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you visit the digital properties (“Digital Properties”) such as websites or apps of the publishers and clients using our partners' or our technology which helps our clients to serve online ads. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

Hybrid Theory participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Hybrid Theory's identification number within the framework is 178.

Hybrid Theory also adheres to the Self-Regulatory Principles set forth by the European Interactive Digital Advertising Alliance (EDAA). EDAA allows you to opt-out from personal ads served by us via the following link: https://www.youronlinechoices.com/

This Privacy Notice applies whenever you visit Digital Properties or use any of other services, all of which together we refer to as "Services".

You may directly see below as well to find our metrics related to requests received under the privacy legislation in California, as disclosed as part of The Delete Act of 2023.

GENERAL INFORMATION
In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.

1. Who is responsible for the processing of your Personal Data

We, Hybrid Theory, based at Epworth House, 25 City Road, London, England, EC1Y 1AA act as a data controller when we process your Personal Data within our Services. Therewithal, we carry out these Services on behalf of or jointly with our clients.

2. What types of Personal Data do we process and how do we collect it?

When you use our Services, as further explained, we collect, use, store and transfer different kinds of Personal Data directly from the end users, via partners and third-party service providers. For example, when you visit a website or app, the publisher sends its supply side partners a request. These requests are transferred to our demand side partners which provide us with your data. Also, we enrich this information via our technology to deduce additional personal data about you such as your interest segment. In addition, we also receive Personal Data from our advertiser/agency partners as you navigate through their websites once you click their ads. As a general principle, we do not collect, generate and do not ask you to provide any "special categories of Personal Data", which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

The information we collect depends on which of our Services you use and how you use them. We process the following types of your Personal Data.

2.1. Personal Data we receive or generate from your use of our Services

When we receive data from our partners, who collects it from the services provided to the users, we also process device-related information, including:

• Technical information: We collect information about your device and device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (such as IP address, IDFA or other unique identifiers provided by our service providers), browser type and version, time zone setting and location, operating system and geolocation data (based on GPS information).
• Profiling information: We enrich the personal data we receive from our partners that help us serve you ads. Based on the data we received from them, which is detailed below, we estimate your segment indicating the domains of your interest. 
• Cookie data:  As further described below, we use cookies and similar technology such as pixels or local storage for the purposes described below. The exact list of cookies, and the retention times of the data that may subsequently be processed is set out in the table below under the section “How long do we store your data”.
• Content information: We also collect information about activity on the digital content visited, such as visited webpages, searches, or links clicked.

2.2. Personal Data we collect from third parties

We obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data are provided by the following third parties, including:

• Your Consent String: Before you see our ads in a Digital Property, the relevant publisher or advertiser obtains your consent for our processing activities as well. If you provide your consent to that partner, we will receive your consent string which shall provide us your preferences on our processing activity.  
• Technical information: We collect information about your device and device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (such as IP address, IDFA or other unique identifiers provided by our service providers), browser type and version, time zone setting and location, operating system and geolocation data (based on GPS information).
• Ad information: information about whether you interacted with our ads.
• Cookie data:  Our third-parties use cookies and similar technology such as pixels or local storage for the purposes described below as well. For more information on the exact process of placing cookies, and the scope of the data please see the privacy notices of such third parties listed under the section “With whom do we share your data”.
• Content information: We also collect information about activity on the digital content visited, such as visited webpages, searches, or links clicked from our third parties.

To learn more about which data is processed, please see the section with service specific information below.

3. Do we collect data from minors?

Our services are intended to be appropriate for general audiences. Therefore, we do not intentionally collect and/or categorize personal information from children. In the event that we learn that we have collected personal data from a user under 16 years of age within the scope of the Services explained in this Privacy Notice, we will delete that data as quickly as possible. If you believe that a user might be under the age of 16, please contact our DPO in the e-mail dpo@azerion.com.

4. For what purpose do we process your data?

As a data controller, depending on which Services you are using, we may process your Personal Data for the following purposes:

4.1. Provision and improvement of our Services

• to provide our advertising services to our clients by running campaigns through our third-party providers
• to audit, research, and analyze information to provide, protect, manage, and improve our ad services, develop new services, and ensure that our technologies function properly

4.2. Personalization of your experience

• to infer insights about your profiles based on your activities across websites and devices over time, including to build interest-based advertising segments or audiences as well as to supplement the information we collect with additional information we receive from third parties to allow us to customize and more effectively tailor the ads we display to end users and to optimize the display of ads
• to serve targeted ads to you on behalf of our clients based on the information inferred as mentioned above and, on your location

4.3. Reporting

• to analyze ad performance, such as tracking views of ads on websites or app stores and/or installs of apps that have been advertised
• to provide information and reports to our clients about the performance of the ads served via DSPs (Demand Side Platforms)

4.4. Compliance with our legal or regulatory obligations

• to comply with subpoenas, warrants, or other legal process.
• to respond to requests from public and government authorities including public and government authorities outside an end user’s country of residence.
• to protect our operations or those of any of our affiliates.
• to protect our rights, privacy, safety or property, and/or that of our affiliates, end users, or others.
• to allow us to pursue available remedies or limit the damages that we may sustain.

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.

5. Do we engage in profiling activities?

If you consent to this via the consent management platform provided by the publishers allowing us to serve you personalized ads, we conduct profiling activities to show you ads that are more relevant to you. You can also go to your privacy settings on that publisher property to review and amend your privacy choices related to this type of processing at any time.

6. On which legal basis do we process your Personal Data?

As a data controller, we process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:

• Your consent: We process your Personal Data if you have provided your consent via a consent management platform available in the publisher’s or our client’s page for a specific purpose. For example, when you visit a Digital Property for the first time, your consent is asked by the relevant publisher on behalf of us, for the data processing in the context of personalized advertising. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.
• Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations. For example, for complying with your rights under the GDPR.
• Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we may process any privacy request you submit to us to be able to support our potential legal claims or transfer your Personal Data across all our group companies for administrative transfers as well as to determine the size of the user base of our services. We are also processing your Personal Data to ensure and verify that users' privacy choices can be and are respected, to demonstrate compliance with accountability principle. We kindly remind you that you have the right to object to such processing of personal data. 

Please see for additional information the section with service specific information below.

7. With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments and technical support and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of the Services provided through our partners. This Policy does not apply to those.

• Demand side partners: Demand partners are companies that integrate with our Services in order to bid for ad space of the publishers to serve personalized ads on behalf of our clients. To be able to target end users, we transmit personal data to demand partners so that they have information about the end users to bid for.
• External service providers: We share your Personal Data with or allow external service providers who perform services on our behalf, like IT services such as hosting, ad servers and targeting software providers. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
• Law enforcement, government authorities or courts: We disclose your Personal Data in the event that we reasonably suspect malicious activity or fake traffic or in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.
• Affiliates and group companies: We share information with our affiliated companies, i.e. companies within our corporate family, which are also subject to this policy. We also share your personal data with our group companies which are responsible for internal analytics for the purposes of cross-product audience measurement. Where we share your personal data with our group companies, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.
• Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Please see the section with service specific information below for more information about the third parties we may share your data with. Furthermore, you can find the third parties your Personal Data may be shared with by clicking on the following link:
Third Party Partners List

8. Where will my Personal Data be processed?

In general, if you are accessing our Services from the European Union (EU) / the European Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with regard to certain activities described in this Privacy Notice, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission's standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.

For further information on, or to receive a copy of, the adequate safeguards adopted by us for the international transfer of your Personal Data, please contact us by email at dpo@azerion.com. We will process any request in line with any local laws and our policies and procedures.

9. How do we protect your Personal Data?

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

10. How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available above.

Our cookies and relevant retention periods are as follows.

11. What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

• Access the Personal Data we hold about you, including information such as, for example, the source and categories of data, the processing purposes, the recipients (or categories thereof) and the respective retention period.
• Request an update or correction of your Personal Data so that it is always accurate.
• Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
• Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
• Restrict the processing of your Personal Data for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.
• Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.
• Object to the processing on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your Personal Data for profiling. In that case, we will stop processing your Personal Data for such purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Information Commissioner’s Officer in the UK.

12. How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our customer support via our Website or our Data Protection Officer via e-mail to dpo@azerion.com

13. How often do we update this Privacy Notice?

We regularly review and update this Privacy Notice. Please regularly check this page to stay updated with the changes of this privacy notice.

This Privacy Notice was last updated on 06.03.2023:

14. Additional Information for California Residents 

This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.  

We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:  

Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-) 

Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) 

Category D – Commercial information (such as purchase history) 

Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address) 

Category G – Geolocation data 

Category H – Audio, electronic, visual, thermal, olfactory, or similar information

The CCPA provides consumers (California residents) with specific rights regarding their personal information.  

You have the right to access specific information i.e.  you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. 

You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you. 

You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function. 

Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.  

You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.

Please see here with explanations on exercising your right to prevent us from selling your personal information and here to opt-out of such sales.

Metrics

As per section 999.317(g)(2) of the CCPA, below are the metrics of requests received by HybridTheory from January 1, 2023 to December 31, 2023: 

Additional Information for Brazil Residents

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

Additional Information for Texas Residents

The entity maintaining this website is a data broker under Texas law. To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS). Information about data broker registrants is available on the Texas SOS website.

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.

Hosting 

Hybrid Theory is hosted by external companies to provide its Services to its clients. For example, every time there is a data collection via our demand side partners, the information allowing this transfer (e.g., device information) as well as online identifiers (such as your IP address) and geo location information will be sent to the external servers. This data is used to provide and improve our service and ensure its functionality.

Profiling

Based on your consent, we infer insights from your Personal Data provided to us by our demand side partners combined with information we obtain from other service providers using our technology. Your profiles are then processed to show you relevant ads, based on your preferences and interests. You can adjust your preferences at any time in your privacy settings available in the Digital Property. If you choose not to give consent for this purpose, Hybrid Theory would not be able to show you personalized ads.

Advertising

Hybrid Theory runs advertising campaigns on behalf of the clients, with the help of external service providers to buy and sell online ads through programmatic advertising. In order to show you personalised ads based your consent on Digital Properties, your Personal Data (including your IP address, advertising identifiers and the information that you have provided your consent for personalised ads) are processed by our partners. You can adjust your preferences at any time in Digital Property’s privacy settings. If you choose not to receive personalised ads at all, our partners may still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific. We also use this information to measure how effective our Services are and report to our clients. 

Analytics

We conduct analytics on Personal Data we receive from our third party data providers and other service providers as well as we collect directly from you through our cookies and similar technologies such as pixels to improve our Services. We process this information based on your consent.