Cognio is a mobile advertising platform. We help advertisers, agencies, publishers, and developers (which we’ll call “Customers”) get the best results. This Policy covers how we handle your info when you’re using our services, checking out our website (https://www.thecognio.com/), or if you’re just curious and reach out. This Policy applies to:

• Folks just browsing our Site or asking us questions.
• Our Customers and their team (like contractors or other contacts).
• People using apps and websites that our customers utilize (“End Users”).

We’ll be talking to all these folks as “you” or “user.”

Personal data is any piece of info that can point to who you are. We collect some data from you and your end-users because we’re legally required to, or because we have a working agreement with you. If you don’t hand this data over, it might mess with our ability to fulfill those agreements.

We respect your privacy, especially on our website (https://www.thecognio.com) and any related pages. This section explains the cookies we use and why we use them. You can tweak your settings whenever you like, but keep in mind that blocking cookies might mess with some features.

What are they? Cookies are small text files that are downloaded to your device when you visit a site. They help remember stuff about you and your preferences, which can make your visits much smoother. Most sites contain stuff from several sources, which means that you might get cookies from a bunch of different places.

What We Use: We use first-party cookies, which are set up by us and us only:
Necessary Cookies: These are the real MVPs of our website. They allow you to log in and generally ensure that everything works smoothly. They don’t keep track of who you are personally.
Analytical Cookies: These help us understand who visits our site, what they do, and how they use it, so we can make it better for everybody.

Cookie Updates: If there is a notable change to this Policy, we’ll let you know through a pop-up on our website. You can always review it here: https://www.thecognio.com/

Contact: For questions, feel free to contact our team through our website at: https://www.thecognio.com/. This Cookies Notice was updated as of April 2024.

If you’d rather not see ads from Cognio, you can opt out of our data collection stuff.

Web Browsers: Just fiddle with your browser settings. This will depend on your particular browser. Disabling or deleting cookies may reduce functionality.

Mobile Devices: Head to your “Settings,” then to “Google,” then “Ads,” and switch on “Opt out of Ads Personalization.”
You can always contact us if you need help. Please note we are not responsible for our customer’s privacy policies.

We use your and your end-user’s personal data for various purposes:

• Authentication: To make sure it’s really you and keep your account safe.
• Contract Stuff: To handle our agreements and meet our obligations to you.
• Service Provision: To deliver the services you need, like advertising or user validation.
• Website Improvements: To keep making our services and websites better.
• Communications: To give you updates about our terms, and services, and answer your questions.
• Personalized Ads: To figure out what kind of ads you’re interested in and to keep our advertising relevant. We will ask for permission first where required.
• Legal Protection: To exercise our legal rights, like stopping intellectual property theft.

We need a legal reason to use your personal data, and that usually falls into one of these categories:

• Your Permission: If you give us your okay.
• Contract Obligations: To provide services you’ve asked us for.
• Legal Compliance: To follow any legal requirements, like confirming your identity.
• Legitimate Interests: To develop new services, keep our platform secure, offer non-personalized advertising, or improve user experience.

We take your privacy seriously when we use your info for “legitimate interests”. We may also ask for your consent before using certain data for direct marketing or other purposes when the law requires it. You can remove your permission at any time. Please verify that you have your end-user’s permission for using their data.

We share your personal data using the usual methods of encryption and security:

• With our advertising partners so they can show you the best ads.
• With our related companies and partners for processing, storing, or analyzing your data, but always in line with this Policy.
• When we must by law.
• If there are any company changes like a merger or an acquisition. We’ll make sure they handle your data in the right way.

Your info could be sent and stored in other countries outside of your own, such as Singapore, even if it has different data protection standards. We make sure this is done safely with proper legal safeguards in place. If you want more details, hit us up!

We do our best to keep your data secure using all the tech we can. We’ll keep your data as long as we need it, or as long as the law requires. We might need to keep data to defend against legal claims or deal with any other complaints.

You and your end-users have some rights over your data:

• See your data and how we use it.
• Fix incorrect data.
• Ask us to delete your data.
• Limit how we use your data.
• Object to certain data usage.
• Get a copy of your data for a third party.
• Withdraw your consent anytime.

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.

If you or your end-users want to do any of these things, give us a shout.

Our services are not for kids, and we don’t intentionally collect info from kids under 13 (or the legally required consent age in your area). If we find out we’ve accidentally collected this information, we’ll delete it ASAP. Please make sure children don’t use our services.

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.
We 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).

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.

We might update this policy from time to time. We’ll let you know if we make any important changes. If any change to our policy significantly affects you, we will ensure you have the chance to exercise your rights or even stop using our services.

If you have any questions or worries about how we use your data, contact us at commercial@thecognio.com. We’re dedicated to sorting out any issues, but if we can’t agree, you might have the right to complain to your local data protection authority.