Last Updated March 2021
Mobkoi Limited (“Mobkoi”, “we”, “us” or “our”) provides digital advertising and creative services (our “Services”) to advertiser clients.
1. ABOUT MOBKOI’S SERVICES
Mobkoi Limited (“Mobkoi”, “we”, “us” or “our”) and its affiliates provide digital advertising services (our “Services”) to advertiser clients. In connection with these Services, Mobkoi and its affiliates purchase digital advertising space available on digital properties (including websites and apps) (“Publisher Sites”) that are owned and/or operated by third-party publishers (“Publishers“), and Mobkoi collects personal data from the end-users of the Publisher Sites (“End Users”) in order to display advertisements to those End Users when they visit those Publisher Sites.
4. WHO WE ARE
Mobkoi Limited an English company with registered company number: 09045201 and whose registered office is at Wework Old Street, 145 City Road, Hoxton, London, United Kingdom, EC1V 1LP. Mobkoi Limited has affiliates and/or offices in other jurisdictions, but Mobkoi Limited is the data controller responsible for End User data in connection with the Services. Mobkoi participates and complies with the rules of an advertising industry framework called the IAB Europe Transparency & Consent Framework (“IAB TCF” or “Framework”), which consists of a set of technical specifications and policies to which members must adhere. Mobkoi’s Framework identification number is 898.
5. HOW TO CONTACT US
6. HOW AND WHY WE COLLECT AND USE END USER PERSONAL DATA
To display ads to you on Publisher Sites
When you visit a Publisher Site that we have partnered with, we receive a request from the Publisher Site to display one of our advertiser client’s advertisements (“Content”) to you. We receive this request through the use of a Mobkoi tag (a piece of code) on the Publisher Site which collects your IP address, information about the device you are using (for example the operating system and/or browser that you are using) and details of the Publisher Site that you are visiting.
We use the data that we receive as part of the request to deliver the Content to you on the Publisher Site. In order to do this, we partner with two third party Advertising Partners, OpenX Software Ltd (“OpenX”) and Celtra, Inc. (“Celtra”). In particular:
• In some cases, we provide your IP address and information about the browser you are using to OpenX (who in turn provide this information to other advertising platforms that our advertiser clients work with); and
• We provide the advertiser’s Content (together with the tracking pixels referred to in the section below) to Celtra. We then serve, on the Publisher Site, a Celtra tag which results in the Content being displayed to you.
For more information about Celtra and OpenX, please see the “Our Advertising Partners” section below.
To determine what ads to show to you
In addition, in some cases, we determine your approximate location (e.g. the city that you are in) from the IP address that we receive, and we use the other information referred to above, in order to determine what advertisement will be most relevant to you. For example, if the Publisher Site is a car website and we determine that you are accessing the car website from the United Kingdom, we may use this information to display an advertisement for a UK-based car dealer.
However, please note that we do not collect information about your activity, interests, demographics or any other information in order to create a profile of you and/or to target advertisements to you based on your behaviours or interests.
Verification, measurement and fraud prevention
We determine your approximate location (e.g. the city that you are in) from the IP address that we receive in order to verify the location of the End Users that receive our advertiser’s Content.
We and our advertiser clients also embed third party tags in the Content which collect information from your device in order to: (i) verify that the Content has been delivered to you; (ii) measure the effectiveness of the Content; and (iii) protect us and our advertiser clients against fraudulent activity. The tags that we use for these purposes are operated by the following third parties:
• DoubleVerify Inc (“Double Verify”); and
• Oracle Corporation (aka Oracle Data Cloud - Moat) (“Moat”)..
Please note, our advertiser clients may use other measurement tags that are operated by other third parties.
In addition, we serve on the Publisher Sites tags that are operated by OpenX and our advertiser clients’ advertising platforms (as referred to in the section above). These tags are used by OpenX and the advertising platform for verification purposes and any other purposes disclosed in their privacy notices.
For further information about the third parties referred to in this section, please see the “Our Advertising Partners” section below.
7. WHAT IS OUR LEGAL BASIS AND WHAT CHOICE DO I HAVE?
It is in our (and our advertiser clients’) legitimate interest to process your personal data for the purposes described in the “How and why we collect End User personal data” section above. In particular, we carry out the above activities in order to effectively deliver our advertiser clients’ advertising and to reach End Users that are most likely to be interested in our advertiser clients’ products and services (in particular based on their approximate location and/or the type of Publisher Site that the End User is visiting).
We participate and comply with the IAB TCF, which is designed to ensure that End Users are provided with a choice as to the purposes for which their personal data is processed and the companies that are permitted to process their data.
Please note that our Advertising Partners may rely on a different lawful basis in respect of their processing of your personal data. For further information about our Advertising Partners, please see the “Our Advertising Partners” section below.
8. OUR ADVERTISING PARTNERS
We work with various third party advertising partners, as set out in the “How and why we collect End User personal data” section above. These third parties, and their respective privacy notices (where they are a separate controller of your personal data) are as follows:
• Celtra: https://celtra.com/privacy-policy/
• OpenX: https://www.openx.com/legal/privacy-policy/
• Double Verify: https://doubleverify.com/privacy-policy/
Please note, these advertising partners all participate in the IAB TCF. As stated in the “What is our legal basis and what choice do I have” section, where we work with Publishers that target End Users who reside in the European Economic Area and/or the United Kingdom, the IAB TCF requires (in certain circumstances) us and our Advertising Partners to process your personal data in accordance with the choices that you make.
Please note that our clients may use other measurement tags that are operated by other IAB TCF certified third parties.
9. TRANSFERS OUTSIDE THE UK AND THE EUROPEAN ECONOMIC AREA (“EEA”)
Where necessary we will transfer personal data to countries outside the UK and the EEA.
Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.
When transferring your personal data outside the UK or the EEA, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.
We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it would have in Europe. For further details, see hhttps://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
10. HOW LONG WE KEEP YOUR PERSONAL DATA
11. YOUR RIGHTS AS A DATA SUBJECT
12. CONCERNS OR COMPLAINTS
In addition to your above referenced rights, if you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or in the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk