Adopted: May 18, 2018; Updated: October 19, 2018

PubMatic, Inc. and its subsidiaries, including, as of the date of this notice, PubMatic Limited, PubMatic GmbH, PubMatic India Private Limited, パブマティック株式会社 (PubMatic KK), PubMatic Pte. Ltd. and 据翼软件科技有限公司 (PubMatic Software (Shanghai) Limited) (“we,” “our” or “PubMatic”) are committed to respecting your data protection rights under applicable privacy laws (we refer to any such rights as “data subject rights”).

As stated in our Privacy Policy, although we may collect personally identifiable information that you provide to us when you visit www.pubmatic.com/ (for example, if you request information through the “Contact Us” section of our website), our automated advertising technology, and the related software tools that we provide to our publisher and advertiser clients, do not collect information that directly identifies you as an individual (such as your name or your address). Instead, our technology collects only certain digital identifiers that may identify your device or your Internet browser (referred to as “Digital Identifiers”). Because of this, in order for us to help you exercise your data subject rights, we need you to provide us with additional information, as explained below, so that we can locate any records we hold about you. We will use this additional information only for the purpose of processing your data subject rights requests.

YOUR RIGHTS EXPLAINED

Residents of some countries, including those in the European Economic Area, have data subject rights available to them under applicable data protection laws. These rights may include the right to request access to, or to request erasure or portability of, your personal information.  You may also have a right to object to, or request that we restrict, processing of your personal information.  Where such rights apply, we will comply with requests to exercise these rights in accordance with applicable data protection laws.

If you make a request to access personal information we hold about you (also known as an “access request”), we will provide the Digital Identifiers of your browser(s) and/or device(s) that we may store. Additionally, we may also provide you with certain other information that we may have stored and associated with your Digital Identifiers.

Please note, however, that we have a very short retention period for most files with Digital Identifiers that we store or process. As a result, we may not be able to provide you with any records at all in response to an access request. In such cases, however, we will inform you that we have not been able to locate any records associated with your Digital Identifiers.

Important Note: We have a responsibility to verify your identity before we respond to an access request.  This is to make sure that we provide a copy of your personal information only to the person who is entitled to it — you.  Because of this, it is our policy not to accept requests submitted by third parties (including automated robots), and to require certain documentation from you to verify that you are authorized to make the access request. If you wish to make an access request, we kindly ask that you contact us directly and follow the instructions below.

HOW TO MAKE A DATA SUBJECT RIGHTS REQUEST

If you wish to make a data subject rights request, please follow the steps described below:

Step 1: Locate Your Digital Identifiers

In order for us to locate relevant records, we will need you to provide us with your Digital Identifiers. You can find your Digital Identifiers as follows:

  • Web Browsing

As described in our Privacy Policy, our Website Cookie Policy (which applies when you visit www.pubmatic.com/) and our Platform Cookie Policy (which applies in connection with our advertising technology platform), our technology operates by using text files called “cookies” that are placed on your device. See the applicable policy for more information about the cookies we use, and how to manage cookies and other similar technologies. Some of the cookies we use include a Digital Identifier. To locate these Digital Identifiers, you can search through your cookies for the cookies named in our cookie policies (which are set from the pubmatic.com domain). The text in each of these cookies is a separate Digital Identifier.

Please keep in mind that different cookies are placed on each browser and device that you use to access the Internet. As a result, if you use multiple browsers (for example, Google Chrome and Mozilla Firefox) and devices (for example, a laptop computer and a mobile phone), you will need to locate the applicable cookies for each browser and device.

  • Mobile Devices

Additionally, certain mobile devices (for example, mobile phones or tablets using the iOS or Android operating systems) generate a persistent “Advertising Identifier” per device, which, among other things, can be used by third parties for purposes of providing you with targeted advertising. On iOS devices, your Advertising Identifier may be referred to as an “IDFA,” “IFA,” or an “ID for Advertising.” On Android devices, your Advertising Identifier may be referred to as an “Advertising ID.” Please follow instructions from your mobile device manufacturer on how to locate your specific Advertising Identifiers.

Step 2: Verify Your Digital Identifiers

In order to make sure that we are responding only to the person who is authorized to make the access request, we also will need some supporting proof to demonstrate that you are indeed connected to the Digital Identifiers you located in Step 1. For Digital Identifiers stored in cookies, please take a screenshot of each cookie, taking care to make sure that the screenshot shows both the name of the cookie and the full Digital Identifier. For Digital Identifiers located on a mobile device, please take a screenshot of a screen that displays the Digital Identifier. Additionally, please fill out, sign and include in your request the Authorization Verification Form that we have prepared, which attests that the Digital Identifiers you have located are indeed associated with you. By signing the form, you declare, under penalty of perjury, that all statements made on the form are true, and you must also have a witness sign and date the form. By the signing the form, the witness declares, under penalty of perjury, that your signature on the form is genuine. In addition, you and the witness must each provide a copy of one identifying document, such as a passport or driver’s license. The names on the document copies must match the printed names on the Authorization Verification Form. We require these steps to help us verify that you, as the data subject of the personal information you have requested, are authorized to request and receive such personal information.

Step 3: Contact Us

Once you have located your Digital Identifiers and can provide us with verification of those Digital Identifiers as instructed above, please contact us with details of the data subject rights you wish to exercise. The easiest way to do so is to email us at privacy@pubmatic.com.  Your completed Authorization Verification Form and required documentation must be attached to the email as PDF files.  Please make sure to include the following information in your email:

  • Your full name
  • The country in which you are located at the time you are making your request
  • The data subject rights you wish to exercise
  • A full list of your Digital Identifiers
  • Supporting proof, as described in Step 2
  • A signed Authorization Verification Form (with witness signature), linked in Step 2
  • The identity documents described in Step 2.

You can also make a data subject rights request by postal mail, by sending a written request with all of the above-listed information to one of the following addresses:

For Residents Outside the European Economic Area:

PubMatic, Inc.
c/o Legal Department
305 Main Street, First Floor
Redwood City, California 94063, U.S.A.

For Residents Inside the European Economic Area:

PubMatic Limited
Level 2
82 Dean Street
London, W1D 3SP, U.K.

Important note: The data controller of European Economic Area residents’ personal information is PubMatic, Inc., at the above address.