AdBozor is a digital advertising group that provides customers with an advertising and monetizing platform and software (the “Services”). In order to provide our Services to customers, we collect and use certain information about user activity and preferences. As such, we know that our users (“you”, “your”) care about their personal information and how it is used and shared, and we take your privacy very seriously. Taking the importance of your privacy into consideration, we have created and enacted this privacy policy to help you understand our privacy practices.

KEY POINTS

• Adbozor is the data controller of personal information processed through our interaction with you or processed in order to serve you with ads.

• We obtain and process information about end users who are targeted with our customers’ ads, customer and supplier personnel and users of our website.

• We may send you marketing updates about our services, however you can unsubscribe at any time.

• We may share information with third party service providers, our affiliates and partners, our group companies and where required by law.

• You have a number of rights that you may exercise in relation to our use of your personal information

I. WHAT DOES THIS PRIVACY POLICY COVER?

The privacy practices and policies that we outline in this privacy policy will apply to the way that we use your information. Generally speaking, you will fall into one of four categories:

• “Site Visitor”: accessing or browsing the www.adbozor.uz site (the “Site”);

• “Customer”: requesting the provision of Services from us;

• “Partner”: providing services to us, to allow us to provide Services to our Customers:

• “Targeted End User”: using websites and mobile apps provided to you by our Customers (acting as an “End User”).

This privacy policy applies to the Site and our Services. This privacy policy describes how Adbozor collects, uses, shares and stores information that identifies you (“personal information”) as well as your choices regarding the use, access and correction of your personal information. Please note that this policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

This Privacy Policy covers the following:

• Who we are

• The information we collect and how we use and store your personal information

• Cookies

• International transfers

• How we share your personal information and who we share it with

• Security

• Data retention

• Your rights and your options for opting out of these practices

• Changes to the privacy policy

• Children’s privacy

• How to contact us

II. WHO WE ARE

Adbozor is the data controller of the personal information that we collect from you. You can contact us in relation to this privacy policy by email at [email protected]

III. THE INFORMATION WE COLLECT AND HOW WE USE AND STORE YOUR PERSONAL INFORMATION

The type of personal information that we process falls into three categories:

• Information we collect from Customers and Partners in connection with the provision of our Services

• Information we collect and use when Targeted End Users interact with our Customers’ websites and mobile applications and which we need to provide our Services

• Information that Site Visitors provide to us via the Site

A. Information We Collect from Customers and Partners

If you are one of our Customers or Partners (or a representative of one of our Customers or Partners), we collect the following information from you, and process it for the following purposes

Personal Information	Purpose
Name; Email; Account login details (such as user ID, password); Payment Information; Data related to the use of your user account/profile, including: (a) technical information such as IP address, device type, country from which you access, browser type and version, browser plug-in types and versions, operating system; and (b) information about your use such as page clicks, time and length of visits, pages visited, traffic data, weblogs and other communication data.	To allow you to set up and use a user account and profile
	To fulfil your requests for certain products and Services
	To analyze how Customers utilize the Services
	To receive services from you or the business you represent (where you or your business is a Partner)
	To send you marketing communications (with consent where required by applicable laws) unless you have told us that you would rather not hear from us
	To keep a record of your consent and to manage your data subject rights requests
	To determine the effectiveness of our Services and communications
	Preserving and sharing information with others including law enforcement, responding to legal requests and establishing, exercising or defending our legal rights
	To follow applicable laws and regulations

Customers and Partners wishing to opt out of receiving information from Adbozor can click “UNSUBSCRIBE” in marketing emails.

We also collect certain types of information automatically through the use of Cookies as outlined below and other similar tracking technologies. These tracking technologies enable us to personalize the Services to Customers.

B. Information We Collect and Use About Targeted End Users When They Interact with Our Customers’ Websites and Mobile Applications

If you are a Targeted End User, we collect certain device information provided by our advertising exchange Partners or our Customers which we process it for the following purposes

Personal Information	Purpose
Generic geographic location consisting of IP address and explicit geographical categorization such as country or zip code and then granular latitude and longitude coordinates Carrier; Device make, manufacturer, operating system and language settings; Name of application interactive with Adbozor Services; Internet Protocol Address; Device ID; Browser type; Internet service provider (ISP); Android ID or Identifier for Advertisers (IDFA); Connection speed; App usage data; Referring / exit pages; Files viewed on our Site (e.g. HTML pages, graphic, etc.); Date / time stamp; Clickstream data	Using limited data to select advertising: Advertising presented to you on a Customer’s app can be based on limited data, such as the app you are using, your non-precise location, your device type or which content you are (or have been) interacting with (for example, to limit the number of times an ad is presented to you).
	Creating profiles for personalized advertising: Information about your activity on a Customer’s app (such as forms you submit, content you look at) can be stored and combined with other information about you (for example, information from your previous activity on a Customer’s app and other websites or apps) or similar users. This is then used to build or improve a profile about you (that might include possible interests and personal aspects). Your profile can be used (also later) to present advertising that appears more relevant based on your possible interests by this and other entities.
	Using profiles to select personalized advertising: Advertising presented to you on a Customer’s app can be based on your advertising profiles, which can reflect your activity on that app or other websites or apps (like the forms you submit, content you look at), possible interests and personal aspects.
	Measuring advertising performance: Information regarding which advertising is presented to you and how you interact with it can be used to determine how well an advert has worked for you or other users and whether the goals of the advertising were reached. For instance, whether you saw an ad, whether you clicked on it, whether it led you to buy a product or download an app, etc. This is very helpful to understand the relevance of advertising campaigns.
	Understanding audiences through statistics or combinations of data from different sources: Reports can be generated based on the combination of data sets (like user profiles, statistics, market research, analytics data) regarding your interactions and those of other users with advertising or (non-advertising) content to identify common characteristics (for instance, to determine which target audiences are more receptive to an ad campaign or to certain contents).
	Developing and improving services: Information about your activity a Customer’s app, such as your interaction with ads or content, can be very helpful to improve products and services and to build new products and services based on user interactions, the type of audience, etc.
	Ensuring security, preventing and detecting fraud, and fix errors: Your data can be used to monitor for and prevent unusual and possibly fraudulent activity (for example, regarding advertising, ad clicks by bots), and ensure systems and processes work properly and securely. It can also be used to correct any problems you, the publisher or the advertiser may encounter in the delivery of content and ads and in your interaction with them.
	Delivering and presenting advertising and content: Certain information (like an IP address or device capabilities) is used to ensure the technical compatibility of the content or advertising, and to facilitate the transmission of the content or ad to your device.
	Preserving and sharing information with others including law enforcement, responding to legal requests and establishing, exercising or defending our legal rights
	To follow applicable laws and regulations

In pursuit of the above purposes, we do the following:

• Match and combine data from other data sources: Information about your activity on a Customer’s service may be matched and combined with other information relating to you and originating from various sources (for instance your activity on a separate online service, your use of a loyalty card in-store, or your answers to a survey), in support of the purposes explained in this notice;

• Link different devices: In support of the purposes explained in this notice, your device might be considered as likely linked to other devices that belong to you or your household (for instance because you are logged in to the same service on both your phone and your computer, or because you may use the same Internet connection on both devices);

• Identify devices based on information transmitted automatically: Your device might be distinguished from other devices based on information it automatically sends when accessing the Internet (for instance, the IP address of your Internet connection or the type of browser you are using) in support of the purposes exposed in this notice;

• Actively scan device characteristics for identification: With your acceptance, certain characteristics specific to your device might be requested and used to distinguish it from other devices (such as the installed fonts or plugins, the resolution of your screen) in support of the purposes explained in this notice.

Our Privacy Principles for the use of data about Targeted End Users

• Adbozor’s systems aggregate events/data at granularities that cover many users, as opposed to a specific user, unless the user consents.

• Adbozor does not tie together events/data across apps in a user-specific way, without the user’s consent.

• Instead, Adbozor only ties events/data from a given specific user within the context of a given app.

• This allows Adbozor to understand the conversion rates from one event to another within an app, but not track the activities of a user across different apps.

• Adbozor does not record or store personal information that the user cannot easily revoke, such as email address, physical address, photographs or phone number to personalize our advertising. Adbozor relies upon device Ids and user IDs to uniquely identify a user, and Adbozor solely relies upon the user’s consent in allowing Adbozor to access this information.

• Adbozor does not export per-user data outside of Adbozor, except for validation purposes to a company that already has access to that data

C. Information You Provide to Us via Our Site

When you visit our Site, we collect the following information from you, and process it for the following purposes

Personal Information	Purpose
Name; Email; Data related to your use of the Site, including: (a) technical information such as IP address, device type, country from which you access, browser type and version, browser plug-in types and versions, operating system; and (b) information about your use such as page clicks, time and length of visits, pages visited, traffic data, location data, weblogs and other communication data. Any other information that you actively provide to us via our Site	To provide access to our Site
	To deal with and respond to your enquiries
	To analyze how our Site is used
	For the purposes set out in the “Cookies and Tracking Technologies” section below
	To send you marketing communications (with consent where required by applicable laws), unless you have told us that you would rather not hear from us
	To keep a record of your consent and to manage your data subject rights requests
	To determine the effectiveness of our Site and communications
	Preserving and sharing information with others including law enforcement, responding to legal requests and establishing, exercising or defending our legal rights
	To follow applicable laws and regulations

User Data Supplementation

We may receive information about you from other sources as required in connection with our legitimate interests, including publicly available databases or third parties from whom we have purchased data (including marketing data). We combine this data with information we already have about you to help us to update, expand and analyze our records, identify new Customers, deliver our marketing services and provide more tailored advertising, products and Services.  If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Cookies and Tracking Technologies

Adbozor and our partners use cookies or similar technologies to analyze trends, administer the Site, track users’ movements around our Site, and to gather demographic information about our user base as a whole.

You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Site or Services.

Information Related to Data Collected through the Service

If you are using our platform, the use of information collected through our service shall be limited to the purpose of providing the Service for which you have engaged Adbozor.

Adbozor collects information under the direction of its Customers, and has no direct relationship with the individuals whose personal information it processes. If you are a Targeted End Users of one of our Customers and would no longer like to be contacted by one of our Customers that use our service, please contact the Customer that you interact with directly.  We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Customers.

We will retain personal information we process on behalf of our Customers for as long as needed to provide services to our Customer. Adbozor will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

IV. INTERNATIONAL TRANSFERS

Your personal information may be collected, transferred to, and processed in, countries other than the country in which you are located, including Uzbekistan where we or our group companies or service providers (among others) maintain facilities. Our group affiliates and our third party service providers and partners operate around the world. We take steps designed to ensure that the data we collect under this privacy policy is processed as described in this privacy policy and according to applicable law.

We have implemented appropriate safeguards to ensure that the recipient of your personal information offers an adequate level of protection, including by entering into the standard contractual clauses for the transfer of personal information.

V. HOW WE SHARE YOUR PERSONAL INFORMATION AND WHO WE SHARE IT WITH

· Sharing of Information We Collect
We neither rent nor sell your personal information in personally identifiable form to anyone. However, we do share your personal information with third parties as described in Section III and in this Section.

· Affiliated Businesses and Third Party Websites We Do Not Control
In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through the Services (either alone or jointly with us). You will be able to recognize when an affiliated business is associated with such a transaction or service, and we will share your personal information with that affiliated business only to the extent that it is necessary and related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies. This privacy policy applies only to personal information that we collect through the Site and Services.

· Service Providers
We employ third party companies and people, for example cloud service providers (“Third Party Service Providers”), to perform tasks e.g., provide computer and network infrastructure services on our behalf or as advertising exchange partners and we may need to share your information with them to provide products or Services to you. We only share your personal information with Third Party Service Providers to the extent necessary for them to assist us and they do not have any right to use your personal information we share with them beyond what is necessary to assist us.

· Group companies
We may provide your personal information to our subsidiaries or affiliated companies for the purpose of processing personal information on our behalf to provide the Site and the Services to you. These parties are required to process such information based on our instructions and in accordance with this privacy policy. They do not have any independent right to share this information.

· Compliance with laws and legal proceedings
We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

· Merger or Acquisition
If Adbozor or any of its subsidiaries are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

VI. SECURITY

The security of your personal information is important to us.  Whilst we take appropriate technical and organizational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.

VII. DATA RETENTION

If you have provided us with personal information for the purposes of holding an account with us, we will retain your information (including personal information) for as long as your account is active or as needed to provide you Services.

VIII. YOUR RIGHTS

· Data Subject Rights
You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at [email protected] at any time. You have the following rights:

1. Right of access.  You have a right of access to any personal information we hold about you.  You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used.

2. Right to correct/ update your information. You have a right to request a correction/ update to any of your personal information which is out of date or incorrect.

3. Right to delete your information.  You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us by email.

4. Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us by email.  

5. Right to object to processing of your personal information.  You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.  

6. If we have collected and process your personal 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 personal information conducted in reliance on lawful processing grounds other than consent.

This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.  

If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make.

IX. CHILDREN’S PRIVACY

We do not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register for the Services (as that term is defined in our Terms of Use). If you are under 16, please do not attempt to use the Site or register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 may provide any personal information to us or use the Site or the Services. In the event that we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible unless your parent or guardian has provided us with their consent for your use of our Site or Services. If you believe that we might have any information from or about a child under 16, please contact us at [email protected]

X. CHANGES TO THIS PRIVACY POLICY

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

XI. HOW TO CONTACT US

If you have complaints about our Site or Services, please contact us at: [email protected].