1. Who we are and what we do
1.1 SignalBridge Tech Ltd, registration number HE 487847, registered office 23 Stasinou Street, 1st Floor, 2404 Engomi, Nicosia, Cyprus, Republic of Cyprus ("SignalBridge", "we") operates a programmatic advertising platform. We help advertisers select and deliver advertising in apps and on websites operated by other companies.
1.2 You do not have a direct relationship with us. You encounter us because you are using an app or website operated by one of our publishing partners, because information about the advertising opportunity has been passed to us by another advertising platform, or because you have visited the website or app of an advertiser that uses code provided by us to measure the effect of its advertising.
2. Where your information comes from
2.1 We receive information about you and your device in three ways: (a) automatically, through software code (a "software development kit" or SDK) integrated by a publisher into its app or website; (b) from other advertising platforms — supply-side platforms and ad exchanges — that transmit a request for an advertisement to us; and (c) automatically, through code provided by us which an advertiser has integrated into its own website or app in order to measure whether an action followed an advertisement shown to you.
2.2 Our publishing partners, the advertising platforms that transmit requests to us, and advertisers that integrate code provided by us into their own websites or apps, are required to provide appropriate notice and to obtain any consent required under applicable law in connection with the collection and use of information through their properties, including where information is accessed from or stored on your device, and, where a consent or preference signal is transmitted to us, to transmit it accurately. We require them by contract to comply with applicable privacy and data protection requirements.
3. What information we process
- Device and network identifiers: IP address, mobile advertising identifier (Google Advertising ID or Apple ID for Advertisers), and identifiers we assign to a device or browser.
- Device and technical characteristics: device model, operating system and version, language and time zone settings, screen resolution, connection type.
- Approximate location derived from your IP address, and precise location only where you have given separate consent.
- Information about the advertising opportunity: the app or website, the ad placement, and the page or screen context.
- Interaction information: whether an advertisement was shown, viewed, clicked, and whether an action followed on the advertiser's site or app.
- Consent and preference signals, including any IAB TCF or Global Privacy Platform string transmitted with the request.
3.1 We do not intentionally use special categories of personal data, as defined under applicable data protection laws, for advertising selection or targeting, and we ask our partners not to transmit such data to us. We do not knowingly collect information from children below the age at which consent may be given under applicable law, we do not permit our technology to be deployed on properties directed at children without our prior written approval, and we do not present profiling-based advertising where we are aware with reasonable certainty that the recipient is a minor. Where we process precise location data, we do so only where permitted by applicable law and, where required, with appropriate consent.
4. What we use it for, and our legal basis
| Purpose | Legal basis |
|---|---|
| Reading information from and storing information on your device | Your consent, obtained by the publisher through a consent management platform, as required by Article 5(3) of the ePrivacy Directive as implemented in your country |
| Selecting and delivering advertising, including personalised advertising, and measuring its performance | Your consent (Art 6(1)(a) GDPR), signalled to us by the publisher |
| Delivering non-personalised, contextual advertising where no consent signal is present | Art 6(1)(f) legitimate interests, where permitted by applicable law, without reading or storing information on your device and without building a profile |
| Capping how often you see the same advertisement | Your consent, where this requires a device identifier |
| Detecting invalid traffic, fraud and security incidents | Art 6(1)(f) legitimate interests in the integrity of the advertising ecosystem |
| Meeting our legal obligations, including responding to notices about unlawful advertising | Art 6(1)(c) legal obligation |
5. Who we share information with
- Demand-side platforms and advertisers participating in the auction for an advertising opportunity.
- Supply-side platforms and publishers, to the extent necessary to deliver and account for the advertising.
- Service providers acting on our instructions, including hosting, security scanning and fraud detection providers.
- Competent authorities, where required by law.
- Our group companies, and an actual or prospective purchaser, investor or funder in connection with a corporate transaction, subject to appropriate confidentiality protections.
6. Our role and joint controllership
6.1 Our role depends on how the information reaches us. There are three routes, and they are not the same in law.
6.2 Where a publisher has integrated our code. Where an app or website has integrated software code provided by us, we and that publisher act as joint controllers within the meaning of Article 26 GDPR for the collection of information on that app or website and its transmission to us. The essence of our arrangement is that the publisher is responsible for informing you and for obtaining any required consent, and we are responsible for enabling your rights under Articles 15 to 20 GDPR in respect of the information we hold after transmission. You may exercise your rights against either of us.
6.3 Where the information reaches us from another advertising platform. Where a request for an advertisement is transmitted to us by a supply-side platform or an ad exchange, we do not collect the information from your device and we have no direct relationship with the publisher concerned. In that case we act as an independent controller for the information we receive, and the publisher and the transmitting platform each act as controllers for their own processing. We require by contract that the platforms which transmit information to us have obtained any consent required and transmit the corresponding signal accurately, and we take reasonable steps, including contractual controls and sampling, to satisfy ourselves that they do so.
6.4 Where an advertiser has integrated our code. Where an advertiser has integrated software code provided by us into its own website or app in order to measure whether an action followed an advertisement, we and that advertiser act as joint controllers within the meaning of Article 26 GDPR for the collection of information on that website or app and its transmission to us. The essence of that arrangement is the same as under clause 6.2: the advertiser is responsible for informing you and for obtaining any required consent, and we are responsible for enabling your rights under Articles 15 to 20 GDPR in respect of the information we hold after transmission. You may exercise your rights against either of us.
6.5 In each case, we act as an independent controller for all processing we carry out after the information has reached us.
7. International transfers
7.1 Personal data is generally stored and processed on secure servers located in or near the region in which our services are provided. Personal data may also be processed or accessed from other countries, including countries which do not provide an equivalent level of protection. Where we transfer personal data outside the EEA, the UK or Switzerland, we implement appropriate safeguards as required by applicable data protection laws, including reliance on adequacy decisions, the European Commission’s Standard Contractual Clauses (as amended by the UK International Data Transfer Addendum or adapted for Switzerland where relevant), or other legally recognised transfer mechanisms. You may request further information about those safeguards, and a copy of the relevant mechanism, using the contact details in clause 9.4. The categories of recipient to which personal data may be transferred are those listed in clause 5. We maintain, in our record of processing activities, a current list of the countries to which personal data is transferred and of the transfer mechanism relied on for each, and we will provide that list on request.
8. How long we keep it
8.1 We keep the information described in clause 3 only for as long as it is needed for the purposes set out in clause 4. The criteria we use to determine that period are: the period for which the information remains useful for the purpose for which we received it; the period for which we need it in order to account to advertisers and publishers for the advertising delivered, to investigate invalid traffic and fraud and to deal with disputes; and any longer period required by law or necessary to establish, exercise or defend legal claims. Information linked to a device identifier is kept for no longer than the period for which we use it to select or measure advertising for that device, and consent and preference signals are kept for as long as we need them in order to evidence the permission on which we acted.
8.2 When we have no ongoing legitimate business or legal need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives or the law requires otherwise), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
9. Your rights and how to use them
9.1 You have the right to request access to your personal data, rectification, erasure, restriction, portability and to object to processing. Where we rely on consent you may withdraw it at any time, through the consent controls provided by the app or website you are using.
9.2 An important practical limitation. We do not know your name and we cannot identify you as a person. We hold information linked to a device identifier. Our ability to act on a request therefore depends on your giving us the relevant identifier, and on our being able to recognise the device. If you reset or delete your advertising identifier, or use a different device or browser, we will not be able to connect any earlier information to your request.
9.3 You can limit personalised advertising at any time using the settings on your device (for example "Limit Ad Tracking", "Allow Apps to Request to Track" or "Delete advertising ID"), by changing your choices in the consent controls of the app or website concerned, and, on the web, through the industry opt-out tools at youronlinechoices.eu (Europe), optout.aboutads.info and optout.networkadvertising.org (United States). Where required by applicable law, we also honour opt-out preference signals sent from your browser, such as Global Privacy Control.
9.4 To make a request, contact us at [email protected]. It helps us if you tell us the advertising identifier of the device concerned. You may also lodge a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus or with the supervisory authority where you live.
9.5 Additional rights in certain jurisdictions. Depending on where you live, you may have additional or different rights under local law, including the right to opt out of the sale or sharing of personal information or of targeted advertising, rights relating to sensitive personal information, and a right of appeal against our decision on a request. Where the law of your jurisdiction gives you such a right, we will give effect to it in accordance with that law, and you may exercise it using the contact details in clause 9.4. Where that law requires us to provide information in addition to the information set out in this notice, or requires any matter described in this notice to be dealt with differently, that law prevails to the extent of the difference and we will comply with it.
10. Contact
10.1 Legal enquiries: [email protected]. Postal address: 23 Stasinou Street, 1st Floor, 2404 Engomi, Nicosia, Cyprus, Republic of Cyprus.
11. Changes
11.1 We will update this notice when our processing changes; the date at the top shows when it was last updated. Where a change is material, we will take appropriate steps to bring it to your attention.