# Moloco Advertising Services Privacy Notice This Privacy Notice applies to the processing of personal information by Moloco, Inc. and its affiliates and subsidiaries (“ **Moloco**,” “ **we**,” “ **us**,” or “ **our**”) through our advertising services including, but not limited to, our Moloco Ads, Moloco Commerce Media, Moloco Streaming Monetization, and the Moloco software development kit ( **“SDK**”) offerings (collectively, the “ **Advertising Services**”). This Privacy Notice does not apply to the personal information that we process solely as a “processor” or “service provider” on behalf of our customers pursuant to a written agreement we have entered into with them (“ **Customer Data**”). Any questions or requests relating to Customer Data should be directed to our customers. ### UPDATES TO THIS PRIVACY NOTICE We may update this Privacy Notice from time to time at our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and we may also send other communications. ### ABOUT THE ADVERTISING SERVICES The Advertising Services aim to assist digital publishers and buyers of digital advertising inventory (for example, advertisements displayed on digital services) to achieve their mobile marketing goals through methods like monetization, user acquisition, and targeting. ### PERSONAL INFORMATION WE COLLECT Below are the types of personal information collected by the Advertising Services: 1. **Device and Browser Information** If you interact with the Advertising Services (for example, by visiting a digital service that displays ads from Moloco, or by using a digital service which contains the Moloco SDK or pixel or through an API or other similar technologies), we may collect personal information including: - Identifiers such as iOS IDFA, Android Advertising ID, and Amazon Advertising ID; - Device properties such as settings, model, operating system, and size; - Usage information such as installations and sessions from the apps and sites you use; - Information about the digital service you use to interact with the Advertising Services; - Location information such as city and/or country level information, imprecise location information inferred from IP address, and time zone; - Network information such as IP address and connection details; - Advertising and tracking preferences; and - Details collected in connection with Moloco’s display of advertisements. 2. **Personal Information Provided by Others** We may collect personal information from others such as Moloco customers and other third parties, including: - User and other IDs; - Email addresses and phone numbers; - Demographic information such as age range and gender; - User activity scores and interaction, engagement, and predictive metrics; - Events and activities, such as browsing behavior (for example, views and searches), records of products purchased or considered (for example, added to cart and checkout), contextual data, or other custom events; and - Subscription, registration, or installation status. ### HOW WE USE PERSONAL INFORMATION 1. **Provide Advertising Services** We use personal information to: - Tailor and serve ads on behalf of customers; - Combine information we collect with information we derive, through analytical techniques, to provide the Advertising Services; and - Measure advertising performance and optimize advertising campaigns. 2. **Improve our Advertising Services and Develop New Products and Services** We use personal information to improve the Advertising Services and to develop new products and services, such as: - Developing, training, and fine-tuning models, algorithms, and artificial intelligence technologies; - Improving, upgrading, or enhancing the Advertising Services; and - Creating and supplementing advertising profiles. 3. **Operate Our Business** We use personal information to operate our business, such as: - Pursuing our legitimate interests such as direct marketing to potential and existing customers, fraud prevention, frequency capping, research and development (including marketing research), and network and information security; - Carrying out analytics; - Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information unless doing so is permitted or required by applicable laws; - Enforcing, or exercising our rights under, our agreements, policies, and applicable laws; and - Carrying out activities that are required or appropriate to comply with our legal obligations. 4. **With Your Consent or Direction** We may use personal information: (i) for other purposes that are clearly disclosed to you at the time you provide the personal information, (ii) with your consent, or (iii) as otherwise directed by you. ### HOW WE DISCLOSE PERSONAL INFORMATION We disclose personal information to third parties for a variety of business purposes, including to provide the Advertising Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. 1. **Disclosures to Provide the Advertising Services** - **Service Providers**. We may disclose personal information to third-party service providers that assist us with the provision of the Advertising Services. This includes service providers that provide us with hosting, analytics, marketing services, AI or machine learning services, consent management platforms, IT support, and related services. - **Third-Party Services**. We may disclose personal information to third-party applications, platforms, services, products, or technologies (each a “ **Third-Party Service**”). For example, Third-Party Services include, but are not limited to, supply-side platforms, demand-side platforms, and ad mediation platforms. Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services. - **Affiliates**. We may disclose your personal information to our corporate affiliates. 2. **Disclosures to Protect Us or Others** We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity. 3. **Disclosure in the Event of Merger, Sale, or Other Asset Transfers** If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction. ### YOUR PRIVACY CHOICES AND RIGHTS You may be able to limit Moloco’s processing of your personal information via the Advertising Services by adjusting your preferences as your device or application/browser permits or by contacting us as set forth in “Contact Us” section below. You may limit ad tracking on some mobile applications by following the instructions for [Android](https://support.google.com/googleplay/android-developer/answer/6048248?hl=en), [iOS](https://support.apple.com/en-us/HT202074) and [others](https://www.networkadvertising.org/mobile-choice/). For details about how to manage your preferences on some Internet connected TVs, read the instructions found [here](https://www.networkadvertising.org/internet-connected-tv-choices/). For the most effective and up-to-date “limit ad tracking” methods, you should consult instructions provided by your device manufacturer or application/browser provider. ### INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION All personal information processed by us may be transferred, processed, and stored anywhere in the world, including the United States or other countries, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country. ### RETENTION OF PERSONAL INFORMATION We store the personal information we collect as described in this Privacy Notice for as long as necessary to fulfill the purpose(s) for which it was collected by Moloco, or as long as necessary to pursue Moloco’s business purposes. ### CONTACT US Depending on where you are located, one or more of the following Moloco entities may be the controller of the personal information processed under this Privacy Notice: - Moloco, Inc. - Moloco (Beijing) Information Technology Co., Ltd - Moloco Singapore Pte. Ltd. - Moloco Co., Ltd. - Moloco Technology Services Ltd. - Moloco GK - Moloco UK Limited - Moloco Germany GmbH - Moloco Technology India Private Limited If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: Attn: Privacy Group Moloco, Inc. 135 Commonwealth Dr., Menlo Park, CA 94025. [privacy@moloco.com](mailto:privacy@moloco.com) ### ANNEX A – SUPPLEMENTAL CCPA PRIVACY NOTICE This Supplemental CCPA Privacy Notice supplements our Privacy Notice and only applies to our processing of personal information that is subject to the CCPA. **NOTICE AT COLLECTION** At or before the time of collection, California residents have a right to receive notice of our privacy practices. California residents can find this information below. - **Personal Information Collected**. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, and/or Shared” for a list of personal information which may be collected. - **Uses of Personal Information**. See the section of this Supplemental CCPA Privacy Notice titled “Uses of Personal Information” for a list of the purposes for which we use personal information. **CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED** We collect personal information that our customers provide to us, personal information we collect automatically when operating the Advertising Services, and personal information from third-party sources. **OVERVIEW OF PERSONAL INFORMATION COLLECTED, DISCLOSED, AND/OR SHARED** The CCPA provides California residents with the right to know what categories of personal information Moloco, in its capacity as a “business”, has collected about them.