Privacy Center

At Pulsebridge, we are dedicated to safeguarding your privacy. This Privacy Policy (“Policy”) outlines how we collect, utilize, and protect the personal data of you and your end-users when you engage with our services and the Pulsebridge product, including applications within our data analytics and advertising ecosystem. We also detail your rights concerning your personal data. This Policy is available in multiple languages; however, in cases of discrepancies, the English version will prevail where legally permissible.

GENERAL INFORMATION

Pulsebridge, referred to as “we,” “our,” or “us,” provides a mobile retargeting platform, offering diverse digital and programmatic advertising solutions to advertisers, agencies, publishers, and application developers (“Customers”). This Policy describes how we handle Personal Information through Pulsebridge’s advertising solutions and our website, https://pulsebridge.co/ (“Site”). This Policy applies to the following:

Individuals using our Clients’ websites or apps (“End Users”). (collectively, “you”, “user”).

Visitors who interact with the Site or contact us with inquiries.

Customers and their designated contacts.

1.Our Services

Pulsebridge DSP operates as a Demand-Side Platform (DSP), providing advanced digital advertising solutions through optimized technologies. Our real-time bidding (RTB) system enables personalized ad delivery. We do not directly interact with end-users visiting our Customers’ websites or apps. The Personal Information collected by Pulsebridge facilitates our RTB technology, enabling advertisers to bid for ad placements when a page loads, an app is used, or any other digital media source is accessed. Information we collect includes data provided to our customers and device information, as defined in this Policy.

2. Personal Data Collection

Personal data refers to any information that can identify an individual. We collect personal data from you and your end-users as mandated by law or as necessary for our contractual obligations. Failure to provide this information may hinder our ability to meet these obligations.

We may collect the following categories of personal data:

  • Account Information: Data you provide when registering or using our services, such as your name, nationality, nickname, phone number, email, and password.
  • Automatic Collection: Information gathered automatically, including your IP address and network type.
  • Cookie Information: We use cookies, pixels, and similar technologies to operate our Site, understand usage patterns, troubleshoot technical issues, and improve your experience. We employ necessary cookies for core website functionality and analytical cookies to improve the site. You can manage your preferences through browser settings and our cookie banner. Disabling cookies may limit some website features.

We may collect the following categories of personal data from your end-users:

  • Location Information: Latitude and longitude (rough location).
  • Device Identifiers: Automatically collected IDs, including device ID, Android ID, GAID, IDFA, Mac address, and other IDs assigned by Publishers, Advertisers, or our Partners.
  • Device Information: Automatically collected data such as device model, operating system, network connection type, system language, and region.
3. Cookie Usage

We respect your privacy when you visit our website and associated pages. This section outlines our cookie usage practices. You can manage your cookie preferences at any time but disabling cookies may cause some functions to not operate properly.

  • Contact Information: For inquiries, please refer to our website (https://pulsebridge.co/). This Cookies Notice was last updated in April 2024.
  • What are Cookies? Cookies are text files that contain small amounts of data and they are placed on your device when you visit a website to remember your preferences and device information. They are used to provide an enhanced experience when visiting our website. Most webpages load content from multiple sources and your browser may receive cookies from a number of sources.
  • Types of Cookies: We use first-party cookies, which are directly set and managed by our website:
    • Necessary Cookies: These are used for essential website functions such as maintaining user session states, without storing personally identifiable data.

Analytical/Performance Cookies Used to monitor user visits and behaviors on the website.

  • Cookie Notification: We will notify you of any important changes through a website pop-up before they take effect.
4. Functional Opt-Out

You can opt out of interest-based advertising delivered by Pulsebridge.

  • Mobile Devices: Limit data disclosure through your device settings by enabling “Opt out of Ads Personalization” in the “Ads” section under the “Google” settings. You can also contact us for assistance, however we are not responsible for our Customer’s privacy practices.
  • Web Browsers: Adjust your browser settings. Please note that some functionality may be lost if you disable cookies.
5. Data Usage and Legal Basis

We use your and your end-users’ personal data for:

  • Identity Verification: To confirm your identity and secure your account.
  • Contractual Obligations: To meet our contractual requirements.
  • Service Operations: To deliver requested services, such as advertising and user authentication.
  • Service Improvement: To analyze user data and improve our services.
  • Communications: To provide updates, respond to inquiries, and notify you of changes.
  • Advertising: To personalize ads and marketing content based on your and your end-users’ preferences. We seek your consent where mandated by law.
  • Legal Rights: To exercise our legal rights, including preventing violations of intellectual property rights.

The legal basis for processing your data will be one of the following:

  • Consent: Your authorization as stated in this policy or any referenced policy.
  • Fulfillment of Contract: To fulfill our contractual obligations with you.
  • Compliance with Legal obligations.
  • Legitimate Interest: To enable us to improve our services, provide a secure platform, and develop non-personalized advertising.

We implement safeguards to protect your privacy while pursuing legitimate interests, and if needed, may seek separate consent for certain data processing (e.g., direct marketing). You can withdraw this consent at any time by contacting us. Please confirm that you have obtained your end-users’ authorization for the scope of our processing their personal information.

6. Data Sharing

We may share your and your end-users’ data using encrypted techniques as needed:

  • With transaction partners and third parties during a merger or acquisition. We will ensure that such entities adhere to this Policy’s guidelines.
  • With advertisers and advertising partners for business purposes.
  • With our affiliates and other partners for processing, analysis, storage, and service delivery.
  • With legal authorities for compliance purposes and to protect our rights.
7. International Data Processing

Your data may be transferred to countries outside of your jurisdiction, including to Singapore. We provide appropriate safeguards (contractual commitments) to protect your data and to comply with applicable legal requirements. Please contact us for further details on these safeguards.

8. Security and Retention

We employ technical and organizational measures to maintain data security, ensure its integrity and confidentiality, and regularly assess these measures. We will retain data as needed for our relationship with you, or to comply with legal requirements and to investigate potential claims or resolve complaints.

9. Your Data Rights & How to Opt-Out

You and your end-users have rights over your personal data, including:

  • Access: Request data and processing information.
  • Rectify: Correct inaccuracies.
  • Erase: Request deletion.
  • Restrict: Limit processing.
  • Object: Object to certain data processing methods.
  • Transfer: Request transfer to third parties.
  • Withdraw Consent: Revoke consent for data processing.

How to Opt-Out: Since we primarily use Mobile Advertising IDs (GAID/IDFA) for ad relevance:

  • iOS Users: Go to Settings > Privacy > Advertising > Toggle “Limit Ad Tracking” on.
  • Android Users: Go to Google Settings > Ads > Toggle “Opt out of interest-based ads” on.
  • General: You may also opt-out via industry standard tools such as the NAI Opt-Out Page (networkadvertising.org/choices) or the DAA Opt-Out Page (aboutads.info/choices).

To discuss or exercise these rights, please contact us.

10. Children’s Information

Our Services are not intended for children, and we do not knowingly collect data from anyone under 13 (or the legally required consent age). We will promptly delete any data received from such individuals without parental consent. Please do not provide our services to children.

11. Privacy Notice for Users in the EEA and UK (GDPR)

1. Scope and Controller This section applies to users located in the European Economic Area (EEA) and the United Kingdom. It supplements our general Privacy Policy in accordance with the General Data Protection Regulation (GDPR) and the UK GDPR.
PULSEBRIDGE PTE. LTD. (registered in Singapore) operates as a Data Controller regarding the processing of personal data for the purpose of selecting and delivering digital advertising.

2. Legal Basis for Processing We process your personal data based on the following legal grounds:
– Consent (Art. 6(1)(a) GDPR): For the use of cookies/device identifiers and the processing of personal data for personalized advertising and measurement. We rely on the consent signals passed to us by publishers via the IAB Transparency & Consent Framework (TCF).
– Legitimate Interest (Art. 6(1)(f) GDPR): For purposes such as fraud detection, security, debugging, and technically delivering ads.

3. International Data Transfers As a company headquartered in Singapore, your personal data may be transferred to and processed in countries outside the EEA/UK. We ensure that such transfers are protected by appropriate safeguards, including:
– The existence of an adequacy decision by the European Commission (or UK authorities).
– The execution of Standard Contractual Clauses (SCCs) approved by the European Commission with our partners and service providers.

4. Data Categories and Retention We collect pseudonymized data including:
– IP addresses (truncated or masked where required).
– Device identifiers (e.g., IDFA, GAID).
– Browsing behavior and interaction data.
– Precise or imprecise location data (based on consent). We retain this data only as long as necessary for the purposes stated, typically not exceeding 13 months, after which it is anonymized or deleted.

5. Your Rights Under the GDPR, you have the right to:
– Request access to your personal data.
– Request correction or deletion of your data.
– Object to processing or restrict processing.
– Request data portability.
– Withdraw consent at any time (usually via the Consent Management Platform on the website/app where you viewed the ad).

6. IAB Transparency & Consent Framework PULSEBRIDGE PTE. LTD. participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies.

12. Privacy Notice for Users in Brazil (LGPD)

1. Applicability and Legal Basis This section applies exclusively to users located in Brazil and is intended to comply with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais – Law No. 13.709/2018 or “LGPD“).
PULSEBRIDGE PTE. LTD.acts as a Data Controller or Data Processor depending on the specific transaction within the real-time bidding (RTB) ecosystem. We process personal data based on the legal grounds of consent or legitimate interest, as permitted by the LGPD.

2. Categories of Data Collected In the context of providing digital advertising services, we may collect and process the following categories of data, which may be considered personal data under the LGPD:
– Device Identifiers: Advertising IDs (e.g., GAID, IDFA) and cookie IDs.
– Network Information: IP addresses and User Agent strings.
– Geolocation Data: Precise or approximate location data (latitude/longitude) passed in bid requests.
– Browsing and Interaction Data: Information about the apps or websites you visit and how you interact with ads served by our platform.

3. Purposes of Processing We process this data for the following specific purposes:
– Ad Selection and Delivery: To select and serve ads that are relevant to your interests (Targeted Advertising).
– Frequency Capping: To prevent you from seeing the same ad too many times.
– Measurement and Analytics: To analyze the effectiveness of ad campaigns and report to our advertisers.
– Fraud Detection and Security: To detect invalid traffic and prevent malicious activity.

4. Sharing of Data We may share data with third-party partners, including:
– Advertisers and Agencies: For attribution and reporting purposes.
– Supply-Side Platforms (SSPs) and Ad Exchanges: (e.g., Google Authorized Buyers) to facilitate the buying of ad inventory.
– Service Providers: Who assist in our technical operations.

5. Your Rights Under LGPD As a data subject in Brazil, you have the following rights regarding your personal data:
– Confirmation of the existence of processing.
– Access to the data.
– Correction of incomplete, inaccurate, or out-of-date data.
– Anonymization, blocking, or deletion of unnecessary or excessive data.
– Revocation of consent.

13. Policy Updates

We may update this Policy periodically. If we change this policy, we will notify you of the changes. Where such changes have significant impacts, we will give you prior notice so you can exercise your rights.

14. Contact Information

For questions or concerns regarding personal data usage, please reach out to us at: commercial@pulsebridge.co. We are dedicated to addressing your concerns. If you believe we have failed to assist you, you may have the right to file a complaint with your local data protection authority.