PubMatic Platform Privacy Policy

This page is about the privacy practices on PubMatic’s Advertising Platform and the personal information it uses to
deliver advertising and perform related activities.

Last Updated: November 21, 2024

PubMatic is an advertising technology company that provides a variety of online advertising-related services (see “Who We Are“). Any reference
to“you”, “your”, “user(s)”, “individual(s)”, “data subject(s)”, implies the “End
User(s)”
who accesses websites, apps, or other digital properties that are being monetized through our Ad
Services (defined below) so that we may deliver advertising and perform related activities (see “About Us and Our Services”). We
want you to be familiar with how we collect, use, and share personal information and how you can exercise the privacy
rights and choices available to you. This privacy policy (“Policy” or the “Platform Privacy
Policy”
) covers the personal information that we may process about you. If you are interested in our
corporate and website privacy policy, which governs the personal information PubMatic collects about individuals when
they visit, use, or interact with: (i) www.pubmatic.com and other websites operated by us, including PubMatic’s Client
interfaces (the “Websites”); (ii) our social media pages (our “Social Media Pages”);
and (iii) our events, sales and marketing activities (collectively, “PubMatic Properties”), please
review our Website Privacy Policy. If you are
interested in our applicant privacy practices, please review our Careers Privacy Policy.

Your Privacy Choices
Please visit https://pubmatic.com/legal/opt-out/ to go directly to the
interest-based advertising opt-outs we offer.

TABLE OF CONTENTS: We recognize that reading and understanding privacy
practices can be difficult and time-consuming. While we recommend that you read this document in its entirety, to make
this process easier for you, we have taken steps to simplify it and provide the following quick links to make it easier
to navigate.

  1. WHO WE ARE
  2. ABOUT US AND OUR AD SERVICES
  3. PUBMATIC’S AD SERVICES & PRIVACY
    1. AT A GLANCE
    2. PUBMATIC’S AD SERVICES & PRIVACY – FULL POLICY
      1. USER INFORMATION WE COLLECT
      2. HOW WE USE THE USER INFORMATION
    3. HOW WE DISCLOSE USER INFORMATION
  4. YOUR CHOICES AND DATA PROTECTION RIGHTS
    1. YOUR PRIVACY CHOICES
    2. YOUR DATA RIGHTS
  5. ADDITIONAL INFORMATION FOR RESIDENTS SUBJECT TO STATE PRIVACY
    LAWS
  6. ADDITIONAL INFORMATION FOR DATA SUBJECTS IN THE EEA, UK, AND
    SWITZERLAND

    1. INTERNATIONAL DATA TRANSFERS
    2. DATA PRIVACY FRAMEWORK
  7. RETENTION OF USER INFORMATION
  8. SECURITY
  9. UPDATES TO THIS POLICY
  10. CONTACTING US

  1. WHO WE ARE
    Any reference to “PubMatic” “we”, “us” or
    our” means PubMatic, Inc. and its global subsidiaries including, as of the effective
    date of this Platform Privacy Policy, PubMatic Limited, PubMatic GmbH, PubMatic India Private Limited,
    パブ 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.

    To get in touch with us, please see the “Contacting Us
    section of this document.

  2. ABOUT US AND OUR AD SERVICES
    PubMatic provides technology via our advertising platform (the “Platform”) and related
    advertising tools (collectively the “Ad Services”) that allow Publishers to make space
    on their websites, mobile apps, internet-connected or over-the-top TV (known as ‘CTV’ and ‘OTT TV,’
    respectively), or other digital properties available to show ads in order to generate revenue (what the
    advertising industry refers to as a ‘Supply Side Platform’ or ‘SSP’) and buyers to purchase the
    available space to display ads on these digital properties. In this Policy, we refer to those involved
    in selling ad space collectively as “Publishers”, those looking to buy ad space
    collectively as “Media Buyers” (including, for example advertisers, ad agencies,
    Demand-Side partners) and Media Buyers and Publishers together as “Clients.” Our Ad
    Services help Clients display relevant online advertising to the End Users who interact with Publishers’
    digital properties and engage in planning and measurement to understand how these ads perform. This
    Policy applies only when we act as a “data controller” and not when we are a processor or service
    provider acting on behalf of our Clients.
  3. PUBMATIC’S AD SERVICES & PRIVACY
    1. AT A GLANCE
      This section serves as a summary of our personal information handling practices and does not replace our
      full Policy found below.

      Please note the following terms that are used in this summary:

      • Pseudonymous user data – personal data that can no longer be attributed to a
        specific data subject without further technical processing or the use of additional data.
      • ID syncing – the matching of two or more unique identifiers linked to the same
        individual.
      • Cookies and online identifiers – cookies are small text files that are stored
        on a user’s browser; online identifiers are often used in lieu of cookies. Similar technologies
        such as pixels and web beacons, device fingerprinting technologies, local storage, and eTags
        (collectively, ”Cookies”) also allow access to, or storage of, information on a
        user’s browser or device. These technologies enable various online functionalities (including
        recognizing and tracking browsing behavior).
      What We Do:
      • Provide Advertising technology for managing digital advertising campaigns
        and for monetizing
        digital properties.
      User Information We Collect: Pseudonymous User Information such as:

      • Unique online and device identifiers
      • Mobile device advertising identifiers
      • IP addresses
      • Browser and device information
      • Web browsing history from advertising impressions
      • Information about an individual’s engagement with ads
      • Information about an individual’s behavior on Digital Properties
      Data We May Receive From Partners For Use in Connection With Our Ad
      Services:
      User Information such as:

      • Demographic data
      • Geolocation Information, including precise geolocation data
      • Obfuscated user identifiers such as hashed email addresses
      • Pseudonymous personal information (see “User Information We
        Collect
        ” above)
      • ID Syncing data
      How The Ad Services Collect Data: Some of the ways our Ad Services collect User Information:

      • from Publishers passing us information so that we can help them monetize ad
        inventory space
        on their digital properties
      • from Clients uploading data onto our platform
      • from Clients using our technology (including Cookies) to gather data
      • through the process of serving ads (including how you interact with an ad)
      Data Our Ad Services Do Not Collect: PubMatic’s Ad Services do not collect directly identifiable personal information,
      including, for
      example:

      • PubMatic does not collect your email address
      • PubMatic does not collect your physical address
      • PubMatic does not collect your phone number
      • PubMatic does not collect your social security number
      • PubMatic does not collect your name
      How We Use the Data We Collect: The Ad Services processes the User Information we collect for advertising purposes,
      including:

      • Personalizing ads
      • Delivering ads
      • Limiting the number of times you see an ad (called “frequency capping”)
      • Measuring the effectiveness of ads and ad campaigns
      • Reporting on ad campaigns to our Clients
      • Maintaining records or transactions, user actions and conversions
      • Attributing purchases or other actions taken by a user to ads
      • Associating devices or identifiers that may be related to each other
      • Preventing malicious or fraudulent activity
      • Improving our Ad Services
      • Location based advertising
      • Service support and diagnostics
      • Administration of our business
      How We Disclose the Data We Collect: We disclose User Information that we collect to:

      • Media Buyers, as a way of informing them about the potential audience for
        their ads if they
        purchase a Publisher’s advertising inventory
      • Clients, to help them improve the effectiveness of their – and their
        client’s – ads
      • Service providers, Vendors, and Subprocessors
      • Where we think we’re required to by law or where we have determined that we
        need to in order to defend or bring a legal claim.
    2. PUBMATIC’S AD SERVICES &
      PRIVACY – FULL POLICY

      1. USER INFORMATION WE COLLECT
        When you visit or use a digital property that uses our technology, we (and our Clients) use and
        deploy Cookies to automatically collect certain information about you and your computer or other
        devices, such as your mobile device, CTV, or OTT TV device. While none of this technology
        provides us with directly identifiable information (meaning, it doesn’t include your name, clear
        text email address, phone number), it may be considered “personal data” or
        personal information” in some jurisdictions. Altogether, the personal data or
        personal information discussed in this policy shall be “User Information.

        PubMatic collects or assigns pseudonymous identifiers (“Online Identifiers”) to
        your browser or other devices to enable our Ad Services to determine within a reasonable level
        of confidence that a browser or device is the same with which our Ad Services have previously
        interacted. These identifiers include:

        • cookie IDs (a unique ID randomly assigned by PubMatic to a browser);
        • unique online IDs (“UUID”) created by identity providers and used by
          our Clients;
        • mobile advertising IDs (a unique ID assigned by the mobile operating system (e.g., Apple
          ID for Advertising
          or Android Advertising ID)); or
        • CTV or OTT TV device identifier for advertising (a unique ID assigned by the OTT or CTV
          publisher).

        If we (or our Media Buyers) can identify a browser or device, it increases the value of that
        advertisement to provide more content for you to enjoy.

        To opt out of our use of such technologies for interest-based advertising purposes, please
        follow the instructions for opting out, as described in “Your Opt-Out Choices” below.
        See PubMatic’s Platform Cookie and
        Other Similar Technologies Policy
        for more information on how PubMatic uses cookies and
        other similar technologies.

        Our Ad Services may also automatically collect the following information and associate it with
        one of the identifiers described above (also User Information:

        • Browser and Device Information, such as the IP address you use to
          connect to an online service; device type and model; manufacturer; operating system type
          and version (e.g. iOS or Android); web browser type and version (e.g., Chrome or
          Safari); user-agent; carrier name; time zone; network connection type (e.g., Wi-Fi or
          cellular); and information about our Publisher’s apps and versions currently active on a
          device.
        • Information about an End User’s behavior on our Publishers digital properties
          (“Behavioral Information“), such as information about how you
          interact with the pages of those digital properties, session start/stop time, and
          precise geolocation (including latitude and longitude coordinates, but only if the
          Publisher’s digital property has enabled location services on the device and the End
          User has granted the Publisher permission to collect and share this information for
          advertising purposes).
        • Information about ads serviced, viewed, or clicked on, such as the type
          of ad, where the ad was served, whether the End User interacted with the ad, the number
          of times an End User has seen the ad, and whether the End User visited the Media Buyer’s
          website or relevant app store and/or purchased or installed the product or service
          advertised (“Ad Interaction“).
        • Information about your location, which we may derive from the
          approximate location of your device via your IP address (“Geolocation
          Information”).

        User Information we receive from third parties

        We may also combine, merge and/or augment the User Information we collect about you with
        information received from Publishers and other Clients (such as our data providers) and may
        include:

        • Demographic or interest data, obfuscated user identifiers such as UUIDs, hashed email
          addresses and/or hashed phone numbers, and content viewed (“Partner Provided
          Information
          “). We do not intentionally collect or process sensitive User
          Information (e.g., social security numbers) and attempt to prohibit our Clients and
          partners from passing any such information to PubMatic.
        • Precise geolocation information collected through Digital Properties. We will not use
          precise geolocation information for interest-based advertising without your opt-in
          consent (“Geolocation”). We use this Geolocation to derive regions for
          ad performance reporting.
        • We work with Clients to help create or obtain groupings of End Users by one or more
          attributes (e.g., ‘cycling enthusiast’) for advertising purposes (“Audience
          Segments”)
          .
      2. HOW WE USE THE USER INFORMATION
        We process and/or disclose User Information for various business purposes, including to provide
        the Ad Services and to operate our business. This section will describe those purposes in detail
        and includes our data processing practices.

        Numerous states within the United States have enacted consumer privacy laws that grant their
        residents certain rights and require additional disclosures (“State Privacy
        Laws
        ”). If you are a resident of one of these states, this section applies to you.

        Likewise, those located in the EEA or UK are also afforded various rights, including additional
        disclosures (“UK & Europe Privacy Laws”). Under UK & Europe Privacy
        Laws, we have established a legal basis for processing your personal information. In most
        instances, consent is the basis for PubMatic’s processing of User Information. If you do not
        consent with respect to PubMatic’s SSP, PubMatic may still solicit bids for advertising to be
        displayed to you but will not process your personal information.

        In some circumstances we may rely on our legitimate interest to collect and use your personal
        information, except where such interests are overridden by your data protection interests or
        fundamental rights and freedoms. For example, we may use any of the data described in this
        Policy for the secondary purpose of detecting, preventing or otherwise addressing fraud,
        security, or technical issues, as well as to protect against harm to our rights, property, or
        safety, or that of the public. This is necessary for us to pursue our, your and our partners’
        legitimate interests. If you have questions about or need further information concerning the
        legal basis on which we collect and use your personal information, please contact us using the
        contact details provided under the “Contacting Us” heading below.

        Please note that we take appropriate measures to ensure that any processing of User Information
        is done in accordance with applicable privacy laws and regulations, and with care for protecting
        your privacy and User Information.

        Serve and Deliver Ads (Ad Services). Generally, we process User Information to
        provide our products and services (including the Ad Services) as described in this Platform
        Privacy Policy. This is what allows Publishers to offer advertising inventory in their Digital
        Properties and Media Buyers to bid on and fill that inventory with relevant ads, as well as to
        determine inventory value and to inform bid decisions (i.e., whether to purchase an ad
        impression or not, for creating segments for End Users matching, targeting of lookalike
        audiences or retargeting users). For example, when a Publisher has potential ad inventory to
        offer, we will send a “bid request” to Media Buyers which includes the information detailed in
        this privacy policy so that Media Buyers can determine if they want to purchase the ad
        impression.

        Ad Reporting. Provide information and reports to Media Buyers about when and
        how End Users have been exposed to their ads, clicked on their ads, or visited their Digital
        Property (including whether an advertised app has been installed). This information is used to
        analyze an advertising campaign’s performance.

        Frequency Capping. Using information from our Ad Services to prevent seeing the
        same ad too many times.

        Targeted Advertising. The method by which we predict likely commercial
        interests (e.g., sports or travel) based on activities across websites, mobile apps, and other
        Digital Properties over time. We will also supplement User Information with additional
        information we receive from third parties, such as third-party advertising segments or
        audiences, to allow us to customize and more effectively tailor the ads we display to End Users
        and to optimize the display of ads (including limiting exposure to less relevant ads).

        Location Based Advertising. Location-based advertising, services, and content
        delivered in real-time using your device’s physical location (where permitted by law).

        ID Syncs. We may disclose cookie values to other advertising technology
        platforms so that they may match their identifier to our identifier.

        Fraud Detection & Prevention (Security). Identify invalid ad impressions,
        clicks, installs, or ad queries, protect us and our Publishers from fraudulent behavior, and
        protect the security of the Ad Services.

        Business Operations & Improving the Ad Services. These purposes include
        several processing activities supporting our ability to run the business for our Clients, such
        as to:

        • Facilitate navigation, display information more effectively, and to personalize your
          experience while using the Ad Services, as well as auditing, researching, and analyzing
          information to provide, protect, manage, and improve our Ad Services, develop new
          services, and ensure that our technologies function properly.
        • Calculate Ad Services usage levels, help diagnose server problems and administer the Ad
          Services.
        • Operate our business, such as billing, support, accounting, improving our internal
          operations, securing our systems, detecting fraudulent or illegal activity, and meeting
          our legal obligations.
        • We may disclose User Information to our service providers that store or process the User
          Information in furtherance of the services we offer via our Ad Services and on our
          behalf.

        The following table illustrates the categories of User Information processed for each business
        purpose, the lawful basis under which we process User Information, and the categories of
        recipients of User Information where we engage third parties to augment our ability to provide
        the Ad Services.

        Purpose of Use
        Serve & Deliver Ads (Ad Services) Ad Reporting Frequency Capping Targeted Advertising Location Based Advertising ID Syncs Fraud Detection & Prevention (Security) Business Operations & Improving the Ad Services
        Categories of Personal Data
        Online Identifiers x x x x
        Demographic Information x x x
        Browser and Device Information x x x x x x x x
        Behavioral Information x x x x x
        Ad Interaction x x x x x
        Partner Provided Information x x x
        Geolocation Information & Geolocation x x x x
        Audience Segments x x x
        Lawful Basis (UK / EEA) Consent Consent Legitimate Interest Consent Consent Consent Legitimate Interest Legitimate Interest
        Categories of Recipients
        Affiliates x x x x x x x x
        Clients x x x x x
        Attribution & Analytics Partners x x x x
        Service Providers/

        Sub processors & Consultants

        x x x x x x x x

        We may disclose User Information in accordance with applicable laws, both within and outside of
        an individual’s country of residence for specific situations which include:

        • Where we need to comply with legal obligations or respond to requests from public and
          government authorities, even if they are outside your country of residence.
        • To enforce our terms and conditions, protect our operations or the operations of our
          affiliates, safeguard our rights, privacy, safety, or property, as well as the rights,
          privacy, safety, or property of our affiliates, you, or others;
        • When necessary to establish or exercise our legal rights or defend against legal claims;
          and
        • In connection with a corporate merger, consolidation, sale of assets, bankruptcy, or
          other corporate change.

        Cross-device and Cross-app targeting

        Cross-device and cross-app targeting are strategies employed in digital advertising to
        effectively connect and interact with individuals across multiple devices and different mobile
        applications. These strategies aim to enhance the advertising experience by delivering more
        relevant and personalized ads to you, regardless of the devices or mobile apps you use.

        Our Publishers, Media Buyers, and Clients may use information that we share with them to
        establish connections among related devices (such as smartphones, tablets, and computers) for
        targeted advertising, analytics, and reporting purposes. They may create a match between your
        devices if you log into the same online service on multiple devices or web browsers, or if your
        devices share similar attributes that support an inference that they are used by you or someone
        in your household. For example, Media Buyers may deliver ads on a tablet based on activities you
        engaged in on your smartphone. To opt out of cross-device targeting practices, please follow the
        instructions located at “Opting Out of Cross-Device Targeting.”

        Our Publishers and Clients also may use information about your activity across multiple,
        unaffiliated third-party mobile applications for targeted advertising, analytics, and reporting
        purposes. For example, if you use a travel app, these third parties may display travel-related
        ads to you on other, unrelated apps.

        To opt out of cross-app targeting practices, please follow the instructions located at
        Opting Out of Interest-Based Advertising for Mobile Advertising Identifiers
        in the “Your Privacy Choices” section of the Opt Out webpage.

    3. HOW WE DISCLOSE USER
      INFORMATION

      Because of the role that PubMatic plays in the advertising ecosystem, many of the use cases described
      above involve a transfer of data to third parties – often to a Publisher or a Media Buyer. For example,
      when a Publisher works with us to fill an ad on one of their digital properties, we share information
      with Media Buyers so that they can determine whether they want to show an ad on that property, how much
      they want to spend on that ad impression, and what ad to show. More detail on these disclosures is
      provided below. For the purposes described in this Policy, we share your User Information with the
      following categories of recipients:

      • Our affiliates: We may disclose your information to our affiliates (see “Who We Are“) who provide data
        processing and business administration support for the purposes described in this Policy.
        PubMatic, Inc., is the party responsible for the management of your User Information jointly
        used by it and its affiliates.
      • Third party service providers and partners: We may disclose your information to
        our third party service providers and partners who provide data processing services to support
        the delivery of our Ad Services, or who have a key function in the online advertising ecosystem
        and with whom it is necessary for PubMatic to exchange information in order to deliver the Ad
        Services, in each case for purposes described in this Policy.

      The following table lists the main categories third party service providers we engage to process
      your User Information and partners with whom information is exchanged, the nature of the services or
      role they provide, and the types of User Information they receive in order to provide these services
      / fulfill their role.

      Category of Service Provider or Partner Nature of Services / Information Sharing User Information
      Publishers We may disclose data collected through our Ad Services to our Publishers to allow
      them to analyse the effectiveness and performance of our Ad Services and to offer
      targeted ad inventory to our Media Buyer Clients.
      Browser and Device Information; Behavioral Information; Ad Interaction; Geolocation;
      Audience Segments; ID Sync Data
      Media Buyers We may share data we collect in connection with our Ad Services with our Media Buyer
      Clients for purposes relevant to our business relationships with them, such as for
      billing purposes, dispute resolution, or fraud prevention. This data is also allows
      them to make decisions regarding buying advertising inventory on Publishers’ Digital
      Properties and other websites and applications; to analyze the effectiveness and
      performance of their advertising campaigns via our services; and to enable our Media
      Buyer Clients to provide you with more personalized content.
      Browser and Device Information; Behavioral Information; Ad Interaction; Partner
      Provided Information; Geolocation; Audience Segments; ID Sync Data; Business
      Administration Information.
      Other Clients We may share certain data we collect in connection with our Ad Services with brands,
      agencies and other interested third parties to help them better identify and
      validate commercial opportunities, promote transparency, and protect against fraud.
      Browser and Device Information; Behavioral Information; Ad Interaction; Publisher
      Provided Information; Geolocation; Audience Segments; ID Sync Data
      Attribution and Analytics Partners We may share data (such as cookie ID, mobile device ID, or other unique identifier)
      with our (or our Publisher or Media Buyer’s) attribution and analytics partners to
      validate and measure the success and effectiveness of ads delivered via the
      Platform.
      Browser and Device Information; Behavioral Information; Ad Interaction; Partner
      Provided Information; Geolocation; Audience Segments; ID Sync Data
      IT service providers IT service providers work on behalf of or with us to allow us to operate the Ad
      Services, and typically provide services such as data storage, data processing
      services, hosting services, and technical support.
      Browser and Device Information; Behavioral Information; Ad Interaction; Publisher
      Provided Information; Geolocation; Audience Segments; ID Sync Data
      Professional service providers Professional service providers may be persons, companies or professional firms
      providing us with advice and consulting in areas such as lead management, campaign
      management, legal services, accountancy services, and fraud prevention.
      Potentially all data types.
      • Other third parties:
        • Buyers of some or part of our business: We may share your information
          with a third party in the event of a contemplated or actual reorganization, merger,
          sale, joint venture, assignment, transfer, or other disposition of all or any portion of
          our business, assets, or stock (including in connection with any bankruptcy or similar
          proceedings).
        • For legal purposes: We may share your information as we believe to be
          necessary or appropriate: (a) under applicable law, including laws outside your country
          of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to
          respond to requests from public and government authorities including public and
          government authorities outside your country of residence; (d) to enforce our terms and
          conditions; (e) to protect our operations or those of any of our affiliates; (f) to
          protect our rights, privacy, safety or property, and/or that of our affiliates, you or
          others; and (g) to allow us to establish or exercise our legal rights or defend against
          legal claims.
        • With consent: We may disclose an individual’s information to others
          with the individual’s consent to such disclosure.
  4. YOUR PRIVACY CHOICES AND DATA RIGHTS
    1. Your Privacy Choices

      Cookies
      To opt out of receiving advertising targeted to your interests (including retargeting) from our Ad
      Services through the use of cookies in your current browser, and for more information on what it means
      to opt out, please go to https://pubmatic.com/legal/opt-out/. Your opt-out
      choice will be linked to your browser only; therefore, you will need to renew your opt-out choice if you
      use a new device or browser, or if you clear your browser’s cookies. See PubMatic’s Ad Services or “Platform Cookie Policy”
      for more information on how PubMatic uses cookies and other similar technologies.
      Mobile Apps
      Your device may also include a feature that allows you to opt in to or out of having certain information
      collected through mobile apps used for targeted advertising purposes.

      Connected TVs
      Our Clients and partners may display interest-based advertising on CTVs (also known as smart TVs or
      connected devices), based on your use of CTVs over time and across non-affiliated CTV apps. To learn
      more about these practices and how to opt out, please review your connect TV’s settings menu and visit
      https://thenai.org/opt-out/connected-tv-choices/.

      Industry Opt Outs
      We are a member of the Network Advertising Initiative (NAI). We also adhere to the Digital Advertising
      Alliance’s (DAA) Self-Regulatory Principles for Online Behavioral Advertising and Multi-Site Data, the
      Application of Self-Regulatory Principles to the Mobile Environment, and the Application of the DAA
      Principles of Transparency and Control to Data Used Across Devices.

      PubMatic also adheres to the Interactive Advertising Bureau (“IAB”) Code of Conduct, and actively
      participates in the IAB Europe Transparency & Consent Framework (TCF 2). We comply with IAB’s
      Specifications and Policies under vendor identification number 76.

      Please visit optout. networkadvertising.org, or optout.aboutads.info to learn how to exercise choice
      regarding the collection of information about your online activities over time and across multiple
      third-party websites, online services, devices, or applications for interest-based advertising purposes.

      Some of our Publishers have their own opt-out mechanisms that are linked from their sites, which you
      should review if you no longer wish to receive targeted advertising from a particular company.

    2. Your Data Rights
      Individuals may be entitled to exercise certain data subject rights available under applicable laws.
      These rights may include the right to request access to User Information we hold. Individuals may also
      have the right to object to, or request that we restrict, processing of User Information, such as
      profiling we perform for the purpose of interest-based advertising. Individuals may also have the right
      to ask that User Information be corrected, erased, or transferred to another party. Where we have asked
      for consent to process data, consent may be withdrawn.

      To make a request to exercise your data rights with respect to your User Information, please visit our
      DSR Notice Page. We will take
      steps to verify your request, such as by asking you to provide confirmation that you control the device
      to which the request relates. We reserve the right to confirm your residence to accurately process your
      request and will need to confirm your identity to process your requests to exercise your right to
      know/access, delete, and correct. This is a security measure to, for example, help ensure we do not
      disclose information to a person who is not entitled to receive it. The identity verification process
      may vary depending on how you submit your request. We will only ask for information that we process to
      verify your identity, such as a cookie ID or mobile advertising ID.

      Appeals

      If we deny your request, you may have the right to appeal our decision by contacting us at
      pubmaticprivacy[at]pubmatic[.]com. If you have concerns about the result of an appeal, you may contact
      the attorney general in the state where you reside.

      Authorized Agents

      If you are submitting a rights request as an authorized agent, you are required to submit proof of your
      identity, and proof of authorization to make the request, such as a valid power of attorney or signed
      permission from the individual who is the subject of the request. In some cases, we may ask the
      individual to confirm they have given you permission to make the request. Please be advised that we
      cannot process your request if you do not provide us
      with sufficient detail to allow us to understand and respond to it. If you are an authorized agent
      seeking to make a request for an individual, please visit our DSR Notice Page.

      Nondiscrimination

      We will not discriminate against you for exercising your privacy rights.

  5. ADDITIONAL INFORMATION FOR RESIDENTS SUBJECT TO STATE PRIVACY
    LAWS

    Depending on your state of residence, you may have the right to request access to, or deletion or correction of,
    your User Information. To make such a request with respect to your User Information, please visit our DSR Notice Page. We will take steps to
    verify your request, such as by asking you to provide confirmation that you control the device to which the
    request relates.

    Personal Information that May Be “Shared,” “Sold,” or processed for “Targeted Advertising” & Your
    Opt-Out Rights under State Privacy Laws

    As described in this Platform Privacy Policy, we process information to personalize and deliver ads, and for
    other ads-related purposes, including to build interest segments. Some of these activities may be considered
    “sales” or
    “sharing” of your personal information or using your information for purposes of “targeted advertising” under
    certain State Privacy Laws. We do not knowingly sell or share personal information about consumers under the age
    of 18.

    If you reside in California, you may also opt out of web-based sales and sharing via our browser cookie by
    visiting the digital properties of our Clients with a legally-recognized opt-out preference signal enabled, such
    as the
    Global Privacy Control.

    Categories of Personal Information Categories of Recipients
    • Identifiers (such as cookie IDs and device and advertising IDs)
    • Demographic information (such as age and gender)
    • Commercial information (such as apps you download, purchases you make, and other
      conversion
      activities)
    • Internet or other electronic network activity information (such as Publishers’
      digital
      properties that you visit and ads you click on)
    • Geolocation information, (such as inferred location based on IP address or other
      types of
      information that may include precise geolocation information)
    • Inferences (such as interests associated with a cookie ID based on Publisher digital
      properties you visit)
    • Our Clients
    • Third party data partners
    • Other Publishers and advertising intermediaries

    Please visit CCPA Privacy Policy
    to review our CPRA and Data Broker Metrics

  6. ADDITIONAL INFORMATION FOR DATA SUBJECTS IN THE EEA, UK, AND SWITZERLAND
    Depending on your location, you may have data subject rights (“DSR”s) described in the
    Your Data Rights” section above; these rights are applicable, for example, to individuals
    located in the European Economic Area (“EEA”), United Kingdom (“UK”) and
    Switzerland. In order to exercise your rights under applicable laws, please visit our DSR Notice Page, which includes
    instructions for how to submit a request and details regarding our process for responding to requests.

    If we have collected and processed your User Information with your consent, then you can withdraw your
    consent
    at any time. Withdrawing your consent will not affect the lawfulness of any processing we
    conducted prior to your withdrawal, nor will it affect processing of your User Information conducted in reliance
    on lawful processing grounds other than consent.

    If you are located in the EEA or the UK, you may also have the right to complain to a Data Protection
    Authority
    about our collection and use of your User Information. For more information, please
    contact your local Data Protection Authority.

    Please note that because most of the personal information we store can only identify a particular browser or
    device, and cannot directly identify you personally, you may need to provide us with additional information to
    enable us to identify the User Information we hold about you and ensure that we accurately fulfill your request
    and do not infringe on the privacy rights of other individuals.

     

    1. INTERNATIONAL DATA TRANSERS
      In connection with the PubMatic Properties and Ad Services, your User Information may be transferred to,
      and processed by PubMatic, its service providers, and partners in countries other than the country in
      which you are resident, including in the United States, India, and other locations where we have offices
      or employees (please see our Locations page for
      a full list) or engage service providers or our partners. These countries may have data protection laws
      that are different from the laws of your country of residence and may not provide the same level of
      protection as your jurisdiction. Regardless of where your data is located, PubMatic shall process your
      User Information in accordance with this Platform Privacy Policy.

      If you are located in the EEA, UK or Switzerland, we will protect your User Information when it is
      transferred outside of your jurisdiction by (i) processing it in compliance with the Data-Privacy
      Framework (as applicable, defined below); (ii) processing it in a territory that provides an adequate
      level of protection for User Informationbased on the receiving country’s data protection laws; or (iii)
      to the extent that the Data Privacy Framework is unavailable and the recipient country has not been
      deemed to provide adequate protection, implementing appropriate safeguards to protect your User
      Information, such as requiring the recipient to comply with the EU Standard Contractual Clauses, or
      another lawful and approved transfer mechanism. Where we transfer User Information originating in the
      EEA, UK or Switzerland pursuant to a contract incorporating the EU Standard Contractual Clauses or
      another lawful and approved transfer mechanism, you may request a copy of such transfer mechanism
      (subject to the removal of confidential or commercially sensitive information).

    2. DATA-PRIVACY FRAMEWORK
      PubMatic, Inc. complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK
      Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S.
      DPF”
      ) as set forth by the U.S. Department of Commerce (together, referred to herein as the
      Data Privacy Framework”). PubMatic, Inc. has certified to the U.S. Department of
      Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with
      regards to the processing of User Information received from the European Union in reliance on the
      EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S.
      DPF. PubMatic, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S.
      Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regards to the processing of User
      Information received from Switzerland in reliance on the Swiss-U.S. DPF. Further, PubMatic is
      responsible for the processing of personal data it receives, under the EU-U.S. DPF, and subsequently
      transfers to a third party acting as an agent on its behalf. PubMatic complies with EU-U.S. DPF
      Principles for all onward transfers of personal data from the EU, including the onward transfer
      liability provisions. If there is any conflict between the terms in this Platform Privacy Policy and the
      EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the applicable Principles shall govern. To
      learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit
      https://www.dataprivacyframework.gov/

      The Federal Trade Commission has jurisdiction over PubMatic, Inc’s compliance with the Data Privacy
      Framework. In certain situations, we may be required to disclose User Information in response to lawful
      requests by public authorities, including to meet national security or law enforcement requirements.

      In compliance with the Data Privacy Framework, PubMatic, Inc. commits to refer unresolved complaints
      concerning our handling of User Information received in reliance on EU-U.S. DPF, the UK Extension to the
      EU-U.S. DPF, and the Swiss-U.S. DPF with our Data Protection Officer at dpo[at]pubmatic[.]com.
      Additionally, PubMatic commits to refer unresolved complaints concerning our handling of personal data
      received in reliance on EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to our
      U.S.-based third-party dispute resolution provider (free of charge), TRUSTe. If you do not receive
      timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your
      DPF Principles-related complaint to your satisfaction, please visit at https://feedback-form.truste.com/watchdog/request for
      more information or to file a complaint. The services of TRUSTe are provided at no cost to you.

      If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, if we have
      not addressed your DPF Principles-related complaint to your satisfaction, or we are not able to resolve
      the issue, individuals have the right to lodge a complaint with their local data privacy authority. For
      contact details of local Data Protection Authorities, please visit the European Data Protection Board
      member list (https://www.edpb.europa.eu/about-edpb/about-edpb/members_en)
      or the UK data protection regulator (https://ico.org.uk/global/contact-us/).

      PubMatic GmbH acts as our EU Representative. If you wish to exercise your rights under the EU General
      Data Protection Regulation (EU GDPR) or have any queries in relation to your rights or general privacy
      matters, please write to: Attn: EEA Representative, PubMatic GmbH, Barbara Strozzilaan 101, 1083 HN
      Amsterdam Netherlands.

      Under certain conditions, more fully described on the DPF website, https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2
      you may be entitled to invoke binding arbitration when other dispute resolution procedures have been
      exhausted.

  7. RETENTION OF USER INFORMATION
    We will retain User Information for as long as necessary to fulfill the purpose of collection, including for the
    purposes of satisfying any business, legal, regulatory, accounting, or reporting requirements; to establish and
    defend legal claims; for fraud prevention purposes; or as long as required to meet our legal obligations. To
    determine the appropriate retention period for User Information, we consider the volume, nature, and sensitivity
    of the data, the potential risk of harm from unauthorized use or disclosure of that data, the purposes for which
    we process the data and whether we can achieve those purposes through other means, along with any applicable
    legal requirements.

    The following represents the retention periods of User Information, by data type. For clarity, we will revise
    these periods as required or permitted by law.

    USER INFORMATION RETENTION PERIOD
    Pseudonymous and/or obfuscated identifiers (e.g., Cookies, unique online IDs, mobile device
    advertising IDs, CTV/OTT ID, IP address, browser and/or device information, hashed emails,
    ID Syncing data); and Geolocation data)
    20 days
    Information linked to pseudonymous identifiers (e.g., web browsing history from advertising
    impressions; ad engagement statistics; digital property engagement analytics; and
    demographic data)
    120 days
    Personal data created through our processing (e.g., audience segmentation) 90 days
  8. SECURITY
    We use reasonable organizational, technical, administrative, and physical safeguards to protect the User
    Information we collect and process. The measures we use are designed to provide a level of security appropriate
    to the risk of processing User Information If you have reason to believe that your interaction with us is no
    longer secure (for example, if you feel that the security of any account you might have with us has been
    compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting
    Us” section below.
  9. UPDATES TO THIS POLICY
    We will review and update this Policy periodically and will note the date of its most recent revision at the top
    of this Policy. If we make material changes to this Policy, we will post the revised Policy on our website and
    may take additional measures to inform you about such changes prior to such changes taking effect. We encourage
    you to review this Policy frequently.
  10. CONTACTING US
    If you have any questions about this Platform Privacy Policy or PubMatic’s privacy practices, please contact us
    by email at pubmaticprivacy[at]pubmatic[.]com, or by mail using the details provided below.

    Please note that email communications are not always secure, so please do not include sensitive information in
    your emails to us.

    Residents outside the European Economic Area (EEA):

    PubMatic, Inc. c/o Privacy

    601 Marshall Street

    Redwood City, California 94063, USA

    European Economic Area (EEA), and Swiss Residents:

    Attn: EEA Representative

    PubMatic GmbH

    Barbara Strozzilaan 101

    1083 HN Amsterdam, Netherlands

    UK Residents:

    Attn: UK Representative

    PubMatic Limited

    18 – 22 Stoney Lane

    Yardley, Birmingham B25 8YP, England

    To comply with our obligations under EU/ UK data protection legislation, we have appointed a Data Protection
    Officer
    (DPO). Our DPO is contactable at dpo[at]pubmatic[.]com or by mail using the details provided above. Who is the
    controller of my data? For the purposes of EU/UK data protection legislation, PubMatic, Inc is the controller of
    your User Information.