WaardeX Privacy Policy

Effective date: May 25, 2018

WaardeX OÜ (“WaardeX,” “we,” “our,” or “us”) provides this privacy policy to explain how we collect, use, and share information. This privacy policy (“Policy”) covers WaardeX’ handling of two types of information:
1. Information we receive about end users (“End Users”) of third-party mobile applications (“apps”) that use our Software Development Kit (“SDK”), our banner or video advertising tags, other collection interfaces (collectively, “APIs”), the WaardeX Demand Platform, or the WaardeX Publisher Platform (collectively, the “WaardeX Ad Services”), and
2. Information we receive through our corporate website at www.waardex.com or any other website on which this Policy is posted, as well as information we get through other corporate services and web portals we make available to clients and business partners (“WaardeX Websites”). We describe the information received through the WaardeX Websites in Section 5 below, titled “Privacy Practices for the WaardeX Websites.”
We encourage consumers to learn about how information (including information we collect) can be used to market to them, and how to exercise their choices to permit or limit such marketing. We describe ways consumers can exercise that choice or opt out of marketing in Section 4 below, titled “Consumer Control and Opt-Out Options.”

1. Introduction and Background
WaardeX provides advertising services that facilitate transactions among advertisers, app developers, publishers of mobile websites and/or apps, and ad exchanges (collectively, “Clients”), and service providers and other data partners (collectively “Partners”). We do this by making available the WaardeX Ad Services and other tools to Clients. Clients use the WaardeX Ad Services and other tools to deliver advertising to End Users, and we in turn provide our services to help Clients (and their own customers) to deliver ads that are of interest to End Users. We explain what SDKs and APIs are in Section 3 below, titled “Cookies, Pixel Tags, and SDKs,” which also explains how cookies and similar technologies (which we also use to provide the WaardeX Ad Services) work.

2. Privacy Practices for the WaardeX Ad Services
a. Information Collected Through the WaardeX Ad Services
Through the WaardeX Ad Services, we may (but do not necessarily, or always) collect a variety of information about End Users (whether through our SDK or through other partnerships and tools such as Client-facing APIs), including:
• IP addresses, from which geographic location may be inferred, as well as system configuration information such as information about End Users’ operating system;
• Precise geolocation information (generally an End User’s latitude and longitude data);
• Mobile advertising identifiers, such as iOS IDFAs and Android Advertising IDs (collectively, “Mobile IDs”). These Mobile IDs may be associated with other information we collect through the WaardeX Ad Services, from third parties, or through any other services we offer;
• Apps that you have installed, mobile websites that you have interacted with, and how you interact with them, including whether and how you interact with ads (including time-stamp information);
• Device type and other device information (e.g., whether you are using a smartphone or tablet, and related information);
• Network provider;
• Mobile browser (e.g., Firefox, Safari, and Chrome);
• Carrier user ID (a number uniquely allocated to you by your network provider); and
• Other unique identifiers that may be associated with an End Users’ device, including identifiers provided by Clients or their service providers.
We may combine and merge the various types of information collected from the WaardeX Ad Services, and may also enhance it (or permit our Clients to enhance it) with information collected from third parties. We refer to all of the above information as the “Service Information.”
b. How We Use the Information Collected Through the WaardeX Ad Services
We use the Service Information to provide a variety of services to our Clients related to advertising and marketing, including services we may describe elsewhere on WaardeX Websites. This includes use of the Service Information for purposes such as to:
• Provide and improve the WaardeX Ad Services. This includes, for example, providing customer, technical, and operational support for these features, detecting and protecting against errors, fraud, or other criminal activity, and resolving disputes and enforcing our terms and conditions and other rights we may have. This may also include analyzing, customizing, and improving the features of the WaardeX Ad Services;
• Provide information and analytics to Clients about the use of app features provided through the WaardeX Ad Services, or help Clients create or enhance user profiles for marketing or analytics purposes;
• Create inferences about End Users categorized into “Audience Segments” or to help Clients do so. For example, if the information we collect indicates that an End User likes apps (or clicks on ads) about travel, we may categorize the End User of that device as someone who is interested in travel;
• Develop and use data models that try to predict End Users’ potential future behavior and interests on a per-device basis or across devices;
• Analyze ad performance, for example, by attributing End Users’ app installations or mobile web visits to ad campaigns;
• Resolve identities across multiple devices, such as to match IP addresses to link an End User across, for example, mobile browsers, mobile devices, tablets, set top boxes, or other devices; and
• Combine the Service Information to perform (including by working with Clients and Partners) any of the above functions, or other advertising, marketing, or analytics services. Or, we may aggregate and create data models to do this, by creating algorithms in order to predict common interests among End Users.
We, or our Clients, may deploy online cookies to track End Users across mobile websites and/or apps, or to associate End Users and these cookies with Mobile IDs. We, or our Clients, may perform such functions to resolve End Users’ identities across mobile devices and to better or more accurately target relevant ads to End Users (such as to a brand’s customers). We may also append or combine certain elements of the Service Information to other information provided by third-party data providers, to learn more about End Users or to provide advertising and analytics services. You can learn more about cookies and similar technologies, such as web beacons and SDKs, in Section 3 below, titled “Cookies, Pixel Tags, and SDKs.”
c. How We Share Information We Collect Through the WaardeX Ad Services
Generally, we share the Service Information with Clients and Partners in order to provide the WaardeX Ad Services. For example, we share the Service Information with:
• Clients and their marketing and service providers, so they may provide targeted content and advertising to End Users on mobile websites and/or apps;
• Other third parties that target advertising. This may include, for example, platforms that work directly with marketers (sometimes called demand-side platforms), analytics companies, data management platforms that help marketers maintain and use data, proximity solution providers, and other advertising technology providers. These companies may, for example, provide targeted content and advertising to End Users and others on third-party mobile websites and/or apps or other advertising media (such as email, direct mail, and display media);
• Clients and their marketing and service providers, to help measure the effectiveness of marketing or analyze their End Users’ likely interests or demographics;
• Partners to enhance consumer privacy, hash information, or send advertising offers by email or display advertising (which may be linked to a cookie as described above); and
• Third-party platforms to help advertisers identify common users across different mobile devices and/or mobile browsers.
Even when you no longer access our SDK, we may continue to use and share your information as described in this Policy.
The processes we described above often involve cookies or similar technologies, which may be associated with other information about End Users, such as End Users’ interests, demographics, or transactions. This is generally known as “interest-based advertising.” We encourage individuals who are interested in controlling or learning about this type of advertising to go to Section 4 below, titled “Consumer Control and Opt-Out Options,” or go to the Digital Advertising Alliance’s (DAA’s) website at www.aboutads.info.
We may also share Service Information with third parties:
• Pursuant to a request or authorization by an End User or Client;
• If the disclosure is provided to: (a) comply in good faith with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas, including for purposes of national security and law enforcement; (b) enforce our terms and conditions or other agreements; or (c) protect our, or any other person’s or entity’s, interests, rights, property, or safety, or in connection with an investigation of suspected or actual unlawful activity;
• Where the information is aggregated or de-identified; and
• As part of a business purchase, sale, merger, consolidation, investment, change in control, transfer of all or substantially all of our assets, reorganization or liquidation, bankruptcy, or in connection with steps taken in anticipation of such an event (e.g. due diligence).

3. Cookies, Pixel Tags, and SDKs
a. Cookies and Pixel Tags
Cookies are small data files containing a string of characters, such as unique browser identifiers. Cookies are stored on your computer or other device and act as unique tags that identify your browser. Our servers may deploy a cookie on your browser when you visit the WaardeX Websites. Our Clients and Partners may do likewise on the WaardeX Websites, our Clients’ and Partners’ websites, and elsewhere. WaardeX may use both session cookies and persistent cookies. Persistent cookies, unlike session cookies, remain after you close your browser, and may be used by your browser on subsequent visits to any given website. Using persistent cookies, a site operator (or a third party they work with) can “remember” what you have previously done on a website and personalize the site, or ads you see, for you. This technology may also provide a site operator or third party (or us, when you visit the WaardeX Websites) with information regarding your IP address, browser type, the web pages that you visit just before or after visiting a website, the web pages viewed, and the dates and times of your visits.
A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access a web page with a pixel tag, the pixel tag may generate a generic notice of the visit, and permit us, or our Clients or Partners, to set or read cookies. Pixel tags are used in combination with cookies to track the activity on a website by a particular browser on a particular device. If you disable cookies, pixel tags simply detect a given website visit.
We, alone or with our Clients and Partners, may use cookies to, for example, “remember” you, track trends, and collect information about how you use our Clients’ or Partners’ websites or interact with advertising. We, and our Clients and Partners, use cookies to provide relevant content to you and replace non-relevant ads with ads that better match your interests. If you wish to opt out of interest-based mobile advertising, please see Section 4 below, titled “Consumer Control and Opt-Out Options.” Please note that disabling cookies may prevent you from accessing some of the WaardeX Websites’ functionalities and offerings, and those of other websites you visit.
b. Mobile Device Identifiers and SDKs
We, or our Clients or Partners, may use or work with mobile SDKs (including our own SDK(s), which are described in more detail in this Policy) to collect information, such as Mobile IDs, and information related to how mobile devices and their users interact with our WaardeX Ad Services and those using our WaardeX Ad Services. The SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services to be implemented. Sometimes, we obtain data through other (generally, simpler) interfaces that deliver similar data to us, which are commonly referred to (and which we refer to) as APIs. We may use these technologies, for example, to analyze or measure certain advertising through apps and browsers based on information associated with your mobile device. If you would like to opt out from having ads tailored to you in this way on your mobile device, please follow the instructions in Section 4 below, titled “Consumer Control and Opt-Out Options.”
Our Clients or Partners may use the above technologies (sometimes, in combination with each other or other data such as IP addresses or hashed or de-identified data files) to coordinate identifiers across platforms, browsers, or devices, in order to more efficiently analyze or target advertising.

4. Consumer Control and Opt-Out Options
In most cases, consumers have control over whether or not they would like to receive relevant ads and marketing email from our Clients.
a. Opting Out of Online Interest-Based Advertising
You can opt out of many of the platforms and service providers we work with that support online interest-based advertising by visiting the Digital Advertising Alliance’s consumer education and opt-out page at http://www.aboutads.info (or the European Interactive Digital Advertising Alliance’s opt-out page at http://www.youronlinechoices.eu if you are located in the European Union). This type of opt out is cookie-based, which means that if you replace or upgrade your browser, or delete your cookies, you will need to opt out again. Opting out in this way will not prevent you from receiving ads; rather, the ads you see will be less customized to you.
Although we do not ourselves deliver interest-based advertising on browsers, we or companies that we work with may sometimes use them for “cross device” advertising. For instance, they may use the mobile identifiers that we collect and share to try to connect user identities across different platforms, channels and devices — such as by using a common IP address to “match” a use on a mobile device to a use on a browser. The above opt-out methods will in most cases opt your device out of browser-based online advertising. If you would prefer not to have WaardeX serve you relevant ads, you may opt-out here : OPT OUT
b. Opting Out of Cross-App Advertising on Mobile Devices
You can opt out of having your Mobile IDs used for certain types of interest-based mobile advertising (also called “cross-app advertising”), including those performed by WaardeX, by accessing the settings on your Apple or Android mobile device, as follows:
• Apple Devices: If you have an Apple device, you can opt out of most cross-app advertising by updating to iOS 6.0 or higher and enabling “Limit Ad Tracking.”
◦ iOS 7 and Higher: Go to Settings → Privacy → Advertising, and toggle “Limit Ad Tracking” to ‘ON.’
◦ iOS 6: Go to Settings → General → About → Advertising, and toggle “Limit Ad Tracking” to ‘ON.’
• Android Devices: If you have an Android device, you can opt out of most cross-app advertising by going to Google Settings → Ads, and selecting the option to opt out of interest-based ads.
Please note that these platforms control how these settings work, so the above instructions may change, and the precise language may be different on certain (particularly, on older) devices. Likewise, if your device uses other platforms not described above, please check the settings for those devices.
c. Additional Choices
Advertisers may also provide ways for you to opt out from, or limit their collection of, certain information from and about you. Please refer to the privacy policies for retailers, apps, and mobile websites to learn more about their privacy practices.
You may opt out from receiving promotional emails from us, such as emails to inform you about events and new services, by following the “unsubscribe” instructions in any promotional email you receive, or by contacting us at [email protected]
Please note, however, that we may still send you non-promotional emails relating to your relationship with us.

5. Privacy Practices for the WaardeX Websites
a. Information We Collect Through the WaardeX Websites
The WaardeX Websites provide information regarding WaardeX and our products and services. Through the WaardeX Websites, we collect information you voluntarily disclose to us, and we may also obtain automatically-collected information.
i. Information You Disclose to Us
When registering for an account, expressing an interest in obtaining additional information about WaardeX or our products and services, or otherwise contacting us through the WaardeX Websites, we collect information you voluntarily disclose to us, such as your name, mailing address, email address, telephone number, credit card number, and other billing information. You may also provide us with certain information about your business or other individuals.
ii. Automatically-Collected Information
When you visit the WaardeX Websites, we may use cookies and pixel tags that we associate with unique identifiers to keep track of visitor interactions and personalize your experience on the WaardeX Websites. For more information, please see Section 3 above, titled “Cookies, Pixel Tags, and SDKs.”
We may also use third-party services, such as Google Analytics, that gather information such as your IP address, browser type, the web page from which you came to the WaardeX Websites, and the times of your visit. In addition, as you browse the WaardeX Websites, advertising cookies may be placed on your computer so that we can “remember” your interests. Our display advertising partners may then help us retarget ads to you on other sites based on your interactions with the WaardeX Websites. To opt out of such interest-based mobile advertising, please see Section 4 above, titled “Consumer Control and Opt-Out Options.” Opting out in this way will not prevent you from receiving ads; rather, the ads you see will be less customized to you.
b. How We Use Information We Collect Through the WaardeX Websites
In addition to the uses described elsewhere in this Policy, we use the information we collect through the WaardeX Websites (alone or in combination) to provide, market, improve, and operate the WaardeX Websites, WaardeX Ad Services, and any other products or services we have or may develop. This includes use of the information to:
• Fulfill your requests;
• Send information about our products and services, including marketing communications;
• Respond to your questions, concerns, or customer service inquiries;
• Create aggregated or de-identified information;
• Comply with applicable laws, prevent fraud, mitigate risk, and perform similar purposes;
• Understand usage trends and preferences;
• Analyze, improve, and provide products and services;
• Customize the content and advertising you see on the WaardeX Websites, across the Internet, and elsewhere; and/or
• Perform other purposes at your request.
c. How We Share Information We Collect Through the WaardeX Websites
We may share the information we collect through the WaardeX Websites in the following situations:
• With your consent, including through this Policy;
• With our affiliates;
• With third parties that help us to operate our business and provide our services, such as entities that provide us with technical, customer, billing, administrative, event planning, marketing, or operational services;
• As part of a business purchase, sale, merger, consolidation, investment, change in control, transfer of all or substantially all of our assets, reorganization or liquidation, bankruptcy, or in connection with steps taken in anticipation of such an event (e.g. due diligence);
• When required by law or in response to lawful process, such as a subpoena, or to cooperate in good faith with a request from a government or law enforcement agency or official, including for purposes of national security and law enforcement;
• If we believe sharing the information may prevent physical, financial or other harm, injury, or loss; or
• If we believe sharing the information is necessary to protect our, or any other person’s or entity’s, interests, rights, property, or safety, or in connection with an investigation of suspected or actual unlawful activity.
With respect to aggregated or de-identified information, we may share such information without restriction.

6. Data Access and Retention
Generally speaking, we retain the information collected from the WaardeX Websites and WaardeX Ad Services for as long as necessary to achieve our objectives as detailed in this Policy, and to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you are a resident of the European Economic Area (EEA), Switzerland, or the United Kingdom (UK), you may obtain a copy of the information we have about you, and correct or amend such information, by contacting us at [email protected] . You may read more about this and other rights in Section 12 below.

7. Data Security
We have administrative, technical, and physical safeguards in place in our physical facilities and in our computer systems, databases, and communications networks that are designed to protect the information from loss, misuse, or alteration. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your information.
To assist with data security, you understand that YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF ANY ACCOUNT CREDENTIALS THAT CAN BE USED TO ACCESS ANY ACCOUNT WITH WaardeX. ANY ACTIONS TAKEN USING YOUR ACCOUNT CREDENTIALS ARE YOUR SOLE RESPONSIBILITY.

8. Third-Party Websites and Apps
This Policy only applies to the WaardeX Websites and the WaardeX Ad Services. We are not responsible for the privacy practices or disclosures of websites, developers, or apps that access or use the WaardeX Websites or WaardeX Ad Services. Likewise, when you access the WaardeX Websites, you may be directed to other websites that are also beyond our control. We encourage you to read the applicable privacy policies and terms and conditions of such third parties and websites, and the industry tools that we have referenced in this Policy.

9. Users from Outside the United States
The WaardeX Websites and WaardeX Ad Services are provided, supported, and hosted in the United States, and their operation is governed by United States law. If you are using the WaardeX Websites or WaardeX Ad Services from outside the United States, be aware that your Information may be transferred to, stored, and processed in the United States and other countries where our facilities are located. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using the WaardeX Websites or WaardeX Ad Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share your information as described in this Policy.
Please see Section 12 below, titled “The EU General Data Protection Regulation (GDPR)” for additional information we provide for the benefit of residents of the EEA, Switzerland, and the UK.

10. California Do-Not-Track Statement
We do not currently recognize or respond to browser-initiated Do-Not-Track signals, as there is currently no industry-wide consensus as to uniform Do-Not-Track standards, implementations, or solutions. Please review Section 4 above, titled “Consumer Control and Opt-Out Options,” for information about your marketing choices.

11. Privacy Shield
WaardeX certifies that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. Consistent with these Principles, where WaardeX uses service providers to process personal data of EU or Swiss residents, WaardeX shall remain liable where the agent processes such personal data of EU or Swiss residents in a manner inconsistent with the Privacy Shield Principles, except where WaardeX establishes that WaardeX is not responsible for the damages caused by the agent. To learn more about the Privacy Shield, and to view the list of entities who have current certifications under the Privacy Shield, please visit this page.
If you have any questions or complaints about WaardeX’s privacy practices, you may contact WaardeX at the contact information in Section 14 below, titled “Contacting Us,” and we will work with you to resolve your issue. If you are a resident of the EU or Switzerland, you may also contact your appropriate European Data Protection Authority or the Swiss Federal Data Protection and Information Commissioner, respectively, with questions or complaints about our privacy practices.
If you are a resident of the EU or Switzerland and are dissatisfied with the manner in which we have addressed your concerns about our privacy practices, you may seek further assistance from our designated Privacy Shield independent recourse mechanism.
Claims shall be arbitrated free of charge by our arbitration provider, though each party shall be responsible for its own attorneys’ fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles.

12. The EU General Data Protection Regulation (GDPR)
As of May 25, 2018, a new data privacy law known as the EU General Data Protection Regulation (the “GDPR”) will be in effect through the EEA, Switzerland, and the UK. The GDPR requires WaardeX and those using our services to provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used under the GDPR that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, Mobile IDs, precise location data, and biometric data.
To comply with the GDPR, we provide the below representations and information, which are specific to persons located in the EEA, Switzerland, or the UK.
a. Legal Grounds for Processing Personal Data
The GDPR requires us to tell you about the legal ground we are relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out in Sections 1 and 2 above (and Section 5 as to the WaardeX Websites) will typically be because:
• You provided your consent. In order to store and gain access to information stored on your device, we rely on your consent. For this “cookie consent” (which applies not only to “cookies” but also to Mobile IDs), we rely on mobile app developers, website owners and oblige them contractually to pass on only legally obtained data. We do so to fulfill our obligations under the ePrivacy Directive. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to such consent and its withdrawal;
• The processing is in our legitimate interest. In some cases, we rely on legitimate interest as a legal basis for processing Personal Data, in order to provide our and/or other data controllers’ services. Such processing goes beyond the original collection of Mobile IDs. A legitimate interest we rely on, for instance, is the tailoring of promotional communications within mobile apps and services, which is beneficial to End Users and is an integral part of the ecosystem by which freely available content is funded through advertising revenue. This also may include providing analysis of and reporting about ad campaigns. We also rely on legitimate interest when we use Personal Data to maintain the security of our services, such as to detect fraud or to ensure that bugs are detected and fixed;
• Contractual relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our customer records and contact information);
• Legal obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.
b. Transfers of Personal Data
As WaardeX works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside of the EEA, Switzerland, or the UK, and which have no data protection laws or laws that are less strict in comparison to those in Europe.
When we transfer Personal Data outside of the EEA, Switzerland, or the UK, we take steps to ensure appropriate safeguards are in place to protect your Personal Data. For example, WaardeX self-certifies to protect Personal Data from the EEA, Switzerland, and the UK in accordance with established data privacy principles. You can learn more about WaardeX’s Privacy Shield certification in Section 11 above, titled “Privacy Shield.” Please contact us at the contact information below for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.
c. Personal Data Retention
As a general matter, we retain your Personal Data for as long as necessary to provide our WaardeX Ad Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. We generally render Mobile IDs inactive within 13 months, provided that we may retain them if we have a legal or significant operational need to do so, such as for auditing, corporate record-keeping, compliance accounting, or bug-fixes.
If you are a Client of ours and thus have an account with us, we will typically retain your Personal Data for a period of 3 years after you have requested that your account be closed, or such account has been inactive.
d. Your Rights as a Data Subject
The GDPR provides you with certain rights in respect to Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting).
• Right to Access: If you wish to exercise your right to access Personal Data we process as a data controller, you may do so by requesting access through the e-mail address [email protected] When we receive your request, we will provide you with current, step-by-step instructions to follow in order to obtain access. We will then assess requests to exercise data access rights on a case-by-case basis; in doing so, we consider the difficulty of verifying whether a mobile identifier and data we have linked to it truly and solely belongs to the data subject making the request, as well as the potential adverse effects on disclosure of personal data to the wrong individual. Because such improper disclosure would likely adversely affect the privacy rights and freedoms of the data subject, we may limit the Personal Data we make available. Please note that we will only grant requests submitted via email for Personal Data for which we are a data controller, as explained further below. Where we act as a data processor for one of our Clients, we will refer your request to that Client. Please identify the Client your request refers to (if possible), to simplify this process.
• Right to Correct: If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below.
• Right to Object to Processing or to Withdraw Consent: By using the device-based “opt-out” signals described in Section 4(b) above, you may withdraw consent for processing on which we rely on consent. If you do so, we will cease processing your Personal Data for purposes of our services within 30 days or less. We either collect these opt-out signals ourselves or receive them from the mobile apps \ websites we work with.
• Right to Erasure. You also have the right to obtain the erasure of Personal Data concerning you that we hold as a data controller. The above opt-out process satisfies this right. When an End User opts-out through device settings, and we receive this signal from our Clients, the Personal Data we use to provide our services will be deleted within 30 days (if you have an Android device) or permanently rendered disconnected to your device (if you have an iOS device). We will also manually delete your Personal Data, subject our identity verification process mentioned above, if you prefer that we do so; please contact us at [email protected] for further instructions on exercising this right manually. Please note, however, that we may retain copies of certain Personal Data on inactive or back-up files, for our own internal and necessary purposes, such as auditing, accounting and billing, legal, or bug detection. We will retain your Personal Data for the period necessary to fulfill any important purposes that we have in retaining it, principally regarding legal, auditing, accounting, and billing obligations.
• Right to Lodge Complaints. You have the right to lodge a complaint with a supervisory authority. However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.
e. WaardeX as a Data Controller and a Data Processor
EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, we encourage you to direct your inquiry to the relevant data controller, since data controllers hold primary responsibility for your Personal Data.
WaardeX may act as either a data controller or a data processor in handling your Personal Data, depending on the precise circumstances. For instance, for Personal Data that we use internally and independently to create our own data tools and operate the WaardeX Ad Services, and for Personal Data that we collect about our Clients, we are a data controller. But when we handle Personal Data strictly on behalf of our Clients or Partners in order to provide our services to them, we are a data processor. Thus, for instance, if you have questions about data that is used primarily by a mobile app on which our technology is embedded – or companies that serve ads that use our technology – you should contact those companies regarding questions about the Personal Data they handle and control.

The controller of data is our technology provider Adkernel LLC, you can read their policy and opt-out to remove your data here https://adkernel.com/privacy-policy/

f. Questions or Concerns
If you are a resident of the EEA, Switzerland, or the UK and have concerns regarding this Section 12, you may contact our privacy officer by email at [email protected] or mailing the following address:
WaardeX OÜ, Randla tn 13-201, Tallinn, 10315, Estonia
Attn: Privacy Officer

13. Changes to This Privacy Policy
We may occasionally update this Policy to reflect changes to our privacy practices. The amended Policy will be displayed on the WaardeX Websites. Please check our Policy regularly to ensure you have read the latest version and to stay informed of our privacy practices. Your continued access to and use of the WaardeX Websites and WaardeX Ad Services constitute your acknowledgement of this Policy and any updates.

14. Contacting Us
If you have any general questions regarding this Policy, you may contact us by email at [email protected] or mailing the following address:
WaardeX OÜ. Randla tn 13-201, Tallinn, 10315, Estonia