Advertising Platform Privacy Policy.

MOBKOI LTD

Last Updated October 2025

Mobkoi Limited (“Mobkoi”, “we”, “us” or “our”) provides digital advertising and creative services (our “Services”) to advertiser clients.

1. About Mobkoi and its Services

Mobkoi Limited (“Mobkoi”, “we”, “us” or “our”) provides digital advertising services to our advertiser clients (“Clients”). As part of our services, we purchase digital advertising space made available on websites, apps and other digital properties (“Publisher Sites”) to display our Clients’ ads on those Publisher Sites. To do this, Mobkoi processes personal data (in some jurisdictions referred to as personal information) relating to the end-users of the Publisher Sites (“End Users”).

We may update this Privacy Policy from time to time to reflect any changes or proposed changes to our use of personal data, or to comply with changes in applicable law or regulatory requirements. We encourage End Users to review this Privacy Policy periodically to keep up to date.

If you are a resident of California or certain other U.S. states, see the additional disclosures set out in the U.S. State-Specific Disclosures section.

2. About this Privacy Policy

This privacy policy (“Privacy Policy”) provides End Users with information about how and why Mobkoi processes their personal data in connection with its advertising services, and explains the rights that End Users have in respect of Mobkoi’s processing of their personal data.

This Privacy Policy also does not apply to personal data collected from users of our site at mobkoi.com and/or personal data collected in the context of our business relationships, such as the personnel of our Clients and suppliers. For details of how we collect and use personal data in connection with those purposes, please see our Website and Business Partner Privacy Policy.

3. WHO WE ARE

Mobkoi Limited is an English company with registered company number: 09045201 and whose registered office is at Mobkoi c/o Jellyfish, Level 22, The Shard, 32 London Bridge St, SE1 9SG.

Mobkoi Limited has affiliates and/or offices in other jurisdictions, but Mobkoi Limited is the data controller responsible for the processing of End User personal data in connection with our services.

Mobkoi participates and complies with the IAB Europe Transparency & Consent Framework (“IAB TCF” or “Framework”), which is an advertising industry framework consisting of technical specifications and policies to which members must adhere. Mobkoi’s Framework identification number is 898.

4. How to contact us

If you have any questions about our processing of your personal data or have trouble accessing this Privacy Policy, you can contact us by:

• Sending an email to contact@mobkoi.com;
• Sending us postal mail to: Mobkoi Limited (C/O Jellyfish) Level 22, The Shard, 32 London Bridge Street, London, England, SE1 9 SG

The individual with primary responsibility for directing the policies and procedures under this Privacy Policy is Guillaume Le Pape, who may be contacted through the means above.

5. HOW AND WHY WE PROCESS PERSONAL DATA

To display ads on Publisher Sites
We use a tag (piece of code) and other tracking technologies on Publisher Sites to collect the following personal data from the End Users of Publisher Sites, which we use to display our Client's advertisements (“Content”) as part of our services:

• IP address;
• technical information about the device used (for example the browser type, device make and model, operating system and screen size); and
• details of the Publisher Site (including the URL) and the advertising space that is available.

We may collect and process unique identifiers as follows:

• we may set a cookie in the browser, which is a small text file that contains an identifier that is unique to the End User and the Publisher Site; and
• for mobile apps, we collect device advertising identifiers, such as an Android Advertising Identifier provided by Google Play services or an Identifier for Advertisers (IDFA) provided by Apple (subject to preferences that you select on your device via its operating system).
• for other devices such as connected TVs, we may also collect other similar identifiers provided by the operating systems.

These identifiers enable you to be uniquely identified each time you visit the Publisher Site.

We use the above information, and share it with third-party Advertising Partners (described in the Our Advertising Partners section) to deliver our Client’s Content to you. In particular:

• We work with other Advertising Partners who assist in the technical delivery of our Client’s Content. To do this, we also serve those Advertising Partners’ tags on the Publisher’s Site, which results in you seeing the Content.  
• We provide the above data to Advertising Partners that are also involved in the purchase of advertising space for our Clients. These Advertising Partners may match the identifiers described above with identifiers that they hold, to assist with the selection of ads as described below.

To select ads based on contextual information
We or our Advertising Partners may use the information referred to above to select what advertisement to show to you, based on contextual information, such as the type of Publisher Site that you are visiting and your approximate location (e.g. the city) derived from your IP address.

For example, if the Publisher Site is a car website and we determine that you are accessing the car website from London, we may use this information to display an advertisement for a car dealer that wants to target individuals located in London.

To help our Advertising Partners select ads that are personalised to you
Mobkoi does not create profiles of your interests (or other personal aspects), and Mobkoi does not use profiles to decide which advertisements to target to you.

However, Mobkoi works with Advertising Partners that are also involved in the purchase of advertising space for our Clients. Some of these Advertising Partners may create profiles about your possible interests or other aspects (like age and gender) and use those profiles to choose which of our Clients’ advertisements may be of most interest to you. This is known as ‘interest-based’, ‘behavioural’ or ‘personalised’ advertising.

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 to verify the location of End Users that receive our Clients’ Content.We also embed third party tags in the Content which collect information from your device to:

(i) verify that the Content has been delivered to you;
(ii) measure the effectiveness of the Content; and
(iii) protect us and our Clients against fraudulent activity. We work with Advertising Partners who assist us in carrying these activities.

Service development and improvement
We use the personal data described above to develop and improve the advertising services that we provide to our Clients, including to improve features and functionalities and to improve the technical performance of advertisements that we deliver (for example, to reduce the time it takes for an ad to display or to optimise ads for mobile devices).

7. OUR ADVERTISING PARTNERS

We work with various third party advertising partners that assist us or our Clients in relation to the activities described in this Privacy Policy (“Advertising Partners”) including the Advertising Partners listed below.

Where we work with Publishers that target End Users who reside in the EEA and/or the UK, the Advertising Partners that we work with participate in the IAB TCF and will be disclosed to End Users via the consent management platform displayed on each Publisher Sites.

Advertising Partners are responsible for processing End User personal data in accordance with preferences that End Users communicate via those consent management platforms. This Privacy Policy does not apply to our Advertising Partners’ processing of your personal data. For information about our Advertising Partners’ processing of your personal data, please review the privacy policies that are made available to you on the relevant Publisher Site.

The Advertising Partners that we currently work with, and the activities that they perform as described in this Privacy Policy, are as follows:

Aryel - https://aryel.io/  
Celtra, Inc. - https://celtra.com/privacy-policy/
Comcast International France SAS and its affiliate, FreeWheel Media Inc. - https://www.freewheel.com/privacy-policy
Xandr, Inc - https://about.ads.microsoft.com/en-us/solutions/xandr/platform-privacy-policy  
EquativSelect - https://equativ.com/end-users-privacy-policy/
Double Verify - https://doubleverify.com/privacy-policy/  
Integral Ad Science - https://integralads.com/ias-privacy-data-management/policies/
Lumen Research - https://lumen-research.com/privacy/   
XPLN - xpln.ai

8. disclosure

We disclose the personal data we collect for the purposes described in this Privacy Policy. The categories of persons to whom we disclose information include:

• Service providers. We work with service providers that collect and process personal data on our behalf. Service providers perform services for us such as data analytics, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers from processing personal data they collect on our behalf for purposes other than performing services for us, although we may permit them to use non-personal data for any purpose to the extent permitted by applicable law.
• Advertising Partners and other third parties. Some of the third parties we work with independently control the purposes and means of processing personal data. For example, we disclose personal data to Advertising Partners, Publishers, and fraud prevention providers. For these third parties, we encourage you to familiarize yourself with and consult their policies and terms of use.
• Clients. We disclose personal data to our Clients in connection with the services we provide to them.
• Affiliates. We disclose personal data to our affiliates and related entities, including where they act as our service providers subject to this Privacy Policy or use the personal data in accordance with their own privacy policies.
• Recipients in a merger or acquisition. We disclose personal data in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Recipients for security and enforcement. We disclose personal data to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose personal data to protect the rights, property, life, health, security and safety of us, the service or anyone else.

9. TRANSFERS OUTSIDE THE UK AND THE EEA

We may transfer personal data from the UK or EEA to countries outside the UK and the EEA. Some of these countries may not have data protection laws that protect personal data to the same standard as data protection laws of the UK and the EEA, for example they may not give you the same rights and there may not be a data protection supervisory authority to help you if you have any concerns.

When transferring your personal data from the UK or the EEA, we will comply with our legal and regulatory obligations, including putting appropriate safeguards in place to ensure an adequate level of protection and taking reasonable steps to ensure the security of your personal data. We usually require on the following safeguards.

Adequacy decisions
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 and/or the UK Government, or any other relevant government body. This may include transfers to organisations that participate in the Data Privacy Framework listed here.

Contractual safeguards
We may transfer your personal data using standard contracts approved by the European Commission and/or the UK Government, or any other relevant governmental body to safeguard personal data. The contracts that we usually rely on are referred to as “Standard Contractual Clauses” or “SCCs”, although we may from time to time use other approved mechanisms. To find out more about the SCCs we use, please see here (EU) and here (UK). You can also contact us using the contact details set out in the How to Contact Us section.

If you have any questions about these mechanisms, please contact us using the details set out in the How to Contact Us section.

10. children

Our services are not directed toward children under 13. If you are a parent or guardian and believe we have collected personal data from children, contact us using the contact details set out in the How to Contact Us section.

11. Security

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect personal data about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please note that transmission via the internet is not completely secure and we cannot guarantee the security of personal data about you

12. how long we keep your personal data

We do not retain your personal data.

13. your rights

This section applies to individuals who reside in the EEA or the UK.

You have certain rights in relation to the personal data we hold about you.

These rights include the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority.

Generally, you may exercise these rights free of charge and without detriment, except where entitled under applicable law Mobkoi reserves the right to charge a reasonable fee or refuse to act on a request.

In addition, in accordance with applicable law, to help protect the privacy of End Users, we may take steps to verify your identity or request declaration from you before fulfilling any request by you to exercise these rights.

If you would like to exercise any of these rights, please contact us using the details set out in the How to Contact Us section. However, as stated above, please note that we do not retain or store the personal data described in this Privacy Policy and, therefore, certain rights may not be applicable.

14. concerns or complaints

If you have a question or 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.

If you are in the UK, you also have a right to lodge a complaint with our supervisory authority, the UK Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk.

In addition, if you are in the EEA you can 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

15. U.S. STATE-SPECIFIC DISCLOSURES

California.
Notice at Collection
For residents of California, at or before the time of collection of your personal information, you have the right to receive notice of our data practices. Our data practices are as follows:

• Collection. The categories of personal information we have collected in the past 12 months and the categories sources from which the personal information is collected are set out in the How and Why We Process Personal Data section above, which we have further set out below using California-specific terms.
o Device identifiers, including your device’s IP address and Ad Id.
o Device information, including your device’s operating software and browser (e.g., type, version, and configuration), internet service provider, and regional and language settings.
o Internet activity, including information about your browsing history and interactions, such as the features you use, pages you visit, advertisements you view, purchases you make or consider, time of day you browse, and referring and exiting pages.
o Non-precise location data, such as location derived from an IP address or data that indicates a city or postal code level.
o Inferences drawn from any of the above information identified in this section.

• Purpose. The specific business and commercial purposes for collecting and using personal information are set out in the How and Why We Process Personal Data section above.

• Disclosure. The categories of persons to whom personal information is disclosed, including service providers for business purposes, are set out in the Disclosure section above. We disclose the categories of personal information listed above to service providers for business purposes.

• Sales and Shares. Some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under California law. A “sale” is broadly defined to include a disclosure for something of value, and a “share” is broadly defined to include a disclosure for cross-context behavioural advertising. We collect, sell, or share the following categories of personal data for commercial purposes: device identifiers, device information, internet activity, non-precise location data, and inferences drawn from any of the above. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioural advertising. We do not knowingly sell or share the personal information of minors under 16 years old who are California residents. We do not respond to “Do Not Track” signals.

• Sensitive Data. We do not sell or share sensitive personal information.

• Retention. The criteria used to determine the period of time we retain your personal information is set out in the How long we keep your personal data  section above.

Requests
You have the right to exercise choice over your personal information as follows:

• Verifiable Requests: You have the right to:
o Know what personal information we have collected about you, specifically have the right to know the categories of sources from which personal information was collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of personal information that we sold, shared, or disclosed for a business purpose, the categories of third parties to whom we disclosed personal information, and the specific pieces of personal information we have collected about you;
o Correct inaccurate personal information we maintain about you; and
o Delete personal information that we have collected from you.  

• These rights are verifiable rights, meaning that we need to verify your identity before fulfilling them. To exercise any of these rights, submit a request through our form here (specifying the rights you wish to exercise). We will confirm receipt of and respond to your request consistent with applicable law. To verify your identity, we may require you to confirm receipt of an email sent to an email address that matches our records, provide us with details relating to your history with us, or provide additional information. If we cannot verify your identity, we may deny your request in accordance with applicable law.

• Sales and Shares: You have the right to opt-out of us selling or sharing your personal information to third parties. To exercise this right, click here to manage your technology preferences or turn on a recognized opt-out preference signal, such as Global Privacy Control, in your browser or extension. Please note that when you opt-out through either of the above methods we do not know who you are within our systems, and your opt-out will apply only to information collected through tracking technologies on the specific browser from which you opt-out. If you delete or reset your cookies, or use a different browser or device, you will need to reconfigure your settings. If you want the opt-out to apply to information we have about you in our systems, such as your email address, please also submit a request through our form here (specifying the right you wish to exercise).

Your rights are subject to exceptions and our retention practices. You have the right not to be discriminated against for exercising any of your rights. To the extent permitted by law, rights requests must be exercised through the applicable designated method listed above. You may make a rights request using an authorized agent. Except for rights requests made by opt-out preference signal, we will require written and signed proof of the agent’s permission to do so and we may verify your identity directly with you.

Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Jersey, New Hampshire, Oregon, Tennessee, Texas, Utah, and Virginia.

Data Practices

For residents of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia, our practices regarding the collection, use, disclosure, and retention of your personal data are set out in the main Privacy Policy above.

Some of our disclosures of personal data may be considered a “sale” under applicable law, which is often defined to include a disclosure for something of value. We also may process your personal data for purposes of targeted advertising. We do not process personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.

Requests

You have the right to exercise choice over your personal data as follows:

• Verifiable Requests: You have the right to:
o Confirm whether or not we are processing your personal data, and in some regions, confirm the categories of personal data we have processed;
o Access your personal data;
o Correct inaccuracies in your personal data;
o Delete your personal data;
o Obtain a copy of your personal data that you previously provided to us in a portable and readily usable format

• If you are a Minnesota or Oregon resident, you also have the right to obtain a list of the specific third parties to which we have disclosed personal data.

• If you are a Delaware or Maryland resident, you also have the right to obtain a list of categories of third parties to which we have disclosed your personal data.

• These rights are verifiable rights, meaning that we need to verify your identity before fulfilling them. To exercise any of these rights, submit a request through our form here (specifying the rights you wish to exercise). We will confirm receipt of and respond to your request consistent with applicable law. To verify your identity, we may require you to confirm receipt of an email sent to an email address that matches our records, provide us with details relating to your history with us, or provide additional information. If we cannot verify your identity, we may deny your request in accordance with applicable law.

• Sales and Targeted Advertising: You have the right to opt-out of us selling your personal data or processing your personal data for purposes of targeted advertising. To exercise this right, click here to manage your technology preferences or turn on a recognized opt-out preference signal, such as Global Privacy Control, in your browser or extension. Please note that when you opt-out through either of the above methods we do not know who you are within our systems, and your opt-out will apply only to information collected through tracking technologies on the specific browser from which you opt-out. If you delete or reset your cookies, or use a different browser or device, you will need to reconfigure your settings. If you want the opt-out to apply to information we have about you in our systems, such as your email address, please also submit a request through our form here (specifying the right you wish to exercise).

• Consent: You have the right to revoke consent previously given to us for the processing of your personal data. To revoke consent, write us at the email or postal address set out in the How to Contact Us section above (specifying the consent you wish to withdraw). If you withdraw consent, you may not be able to receive certain services related to that consent.

Your rights are subject to exceptions and our retention practices. You have the right not to be discriminated against for exercising any of your rights. To the extent permitted by law, rights requests must be exercised through the applicable designated method listed above. You may make a rights request using an authorized agent. Except for rights requests made by opt-out preference signal, we will require written and signed proof of the agent’s permission to do so and we may verify your identity directly with you.

You have the right to appeal our decision in response to your request. To appeal, please write us at the email or postal address set out in the How to Contact Us section above and specify what you wish to appeal. We will review and respond to your appeal in accordance with applicable law. If we deny your appeal, you may submit a complaint to your Attorney

General as follows:

• For Colorado residents: https://coag.gov/file-complaint/
• For Connecticut residents: https://www.dir.ct.gov/ag/complaint/
• For Delaware residents: https://attorneygeneral.delaware.gov/fraud/cmu/complaint/
• For Iowa residents: https://www.iowaattorneygeneral.gov/for-consumers/file-a-consumer-complaint/complaint-form
• For Maryland residents: https://www.marylandattorneygeneral.gov/Pages/CPD/Complaint.aspx.
• For Minnesota residents: https://www.ag.state.mn.us/Office/Forms/ConsumerAssistanceRequestForm.pdf
• For Montana residents: https://dojmt.gov/office-of-consumer-protection/consumer-complaints/
• For Nebraska residents: https://www.nebraska.gov/apps-ago-complaints/
• For New Hampshire residents: https://www.doj.nh.gov/citizens/consumer-protection-antitrust-bureau/consumer-complaints
• For New Jersey residents: https://www.njconsumeraffairs.gov/Pages/Consumer-Complaints.aspx
• For Oregon residents: https://justice.oregon.gov/consumercomplaints/  
• For Tennessee residents, https://www.tn.gov/attorneygeneral/working-for-tennessee/consumer/file-a-complaint.html
• For Texas residents: https://oag.my.salesforce-sites.com/CPDOnlineForm
• For Utah residents: https://attorneygeneral.utah.gov/contact/complaint-form/
• For Virginia residents: https://www.oag.state.va.us/consumercomplaintform

Nevada

Nevada residents have the right to opt-out of sale of their information. To make a request, please write us at the email or postal address set out in the How to Contact Us section above and specify that you are making a “Nevada Opt-Out of Sale Request.” Your rights are subject to exceptions and our retention practices.