Privacy Policy

Introduction

Mlion Ads LTD and its affiliated entities ("Mlion," "we," "us," or "our") are committed to protecting the privacy of individuals ("you" or "users") who interact with our programmatic advertising platform and related services (collectively, the "Platform"). This Privacy Policy describes how we collect, use, store, share, and protect your information.

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy and agree to its terms. If you do not agree, please discontinue use of the Platform immediately.

1. Information We Collect

1.1 Information You Provide Directly

When you register for, access, or use the Platform, you may provide us with:

• Identity and Contact Information: Name, email address, phone number, company name, job title, billing address
• Account Credentials: Username, password, and authentication details
• Business Information: Company details, tax identification numbers, payment information
• Communications: Messages, support requests, survey responses, and feedback you submit to us
• Voluntary Submissions: Any other information you choose to share

1.2 Information Collected Automatically

When you use the Platform, we automatically collect technical and usage information, including:

• Device Data: Device type, operating system, browser type, unique device identifiers, IP address, mobile advertising IDs
• Usage Data: Pages visited, features accessed, time spent on Platform, clickstream data, referral sources
• Log Data: Access times, error logs, session data, API calls
• Location Data: Approximate geographic location derived from IP address
• Cookies and Similar Technologies: We use cookies, web beacons, pixels, and similar tracking technologies to enhance functionality, analyze usage patterns, and personalize your experience. You can control cookie preferences through your browser settings, though disabling cookies may limit certain Platform features.

1.3 Information from Third Parties

We may receive information about you from:

• Business partners and data providers
• Advertising networks and demand-side platforms
• Publicly available sources
• Third-party analytics services

2. How We Use Your Information

We process your information for the following purposes:

2.1 Service Delivery and Operations

• Providing access to and operating the Platform
• Processing transactions and managing accounts
• Authenticating users and maintaining security
• Delivering requested features and functionality

2.2 Optimization and Analytics

• Analyzing Platform performance and user behavior
• Conducting A/B testing and improving user experience
• Generating statistical insights and reports
• Optimizing ad delivery and auction performance

2.3 Communication

• Responding to inquiries and providing support
• Sending service notifications and updates
• Delivering account-related communications
• Providing marketing communications (with your consent where required)

2.4 Security and Compliance

• Detecting and preventing fraud, abuse, and security threats
• Enforcing our Terms of Service and other agreements
• Complying with legal obligations and regulatory requirements
• Protecting our rights and property

2.5 Business Operations

• Facilitating mergers, acquisitions, or asset sales
• Maintaining records and backups
• Managing insurance and risk
• Internal reporting and business analysis

3. How We Share Your Information

We may share your information in the following circumstances:

3.1 Service Providers

We engage third-party vendors to perform services on our behalf, including:

• Cloud hosting and infrastructure providers
• Payment processors
• Analytics and monitoring services
• Customer support platforms
• Email and communication services

These providers are contractually obligated to use your information only as necessary to perform their services and to maintain confidentiality.

3.2 Business Partners

We may share information with:

• Publishers and advertisers using our Platform
• Demand and supply partners in programmatic transactions
• Integration partners and technology vendors

3.3 Legal and Regulatory Disclosures

We may disclose information when required by law or to:

• Comply with legal process, court orders, or government requests
• Enforce our agreements and policies
• Protect the rights, safety, or property of Mlion, our users, or others
• Investigate fraud, security issues, or violations of law

3.4 Business Transfers

If Mlion undergoes a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the successor entity, subject to this Privacy Policy.

3.5 Aggregated and De-identified Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably identify you with partners, investors, or the public for research, analytics, or marketing purposes.

4. Data Retention

We retain your information only as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Retention periods vary based on:

• The nature of the information
• Legal and regulatory requirements
• Business and operational needs
• Dispute resolution and enforcement needs

When information is no longer needed, we securely delete or anonymize it.

5. Data Security

We implement industry-standard technical and organizational security measures to protect your information against unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication requirements
• Regular security assessments and audits
• Employee training on data protection practices

However, no method of transmission or storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

6.1 General Rights

• Access: Request copies of the information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your information, subject to legal exceptions
• Restriction: Request limitation on how we process your information
• Objection: Object to processing based on legitimate interests
• Portability: Request your information in a portable format
• Withdrawal of Consent: Withdraw consent for processing where applicable

6.2 Exercising Your Rights

To exercise any of these rights, contact us at privacy@mlion.io. We may need to verify your identity before processing your request. We will respond within the timeframe required by applicable law.

7. Region-Specific Provisions

7.1 European Economic Area (EEA) and UK

If you are located in the EEA or UK, we process your information in accordance with the General Data Protection Regulation (GDPR) and UK GDPR.

Legal Basis for Processing:

• Contractual necessity: To perform our agreement with you
• Consent: Where you have provided explicit consent
• Legitimate interests: For our business operations, provided your rights are not overridden
• Legal obligation: To comply with applicable laws

Additional Rights:

• Right to lodge a complaint with your local supervisory authority
• Right to data portability
• Right to object to automated decision-making

Data Transfers: When we transfer data outside the EEA/UK, we use appropriate safeguards such as Standard Contractual Clauses.

7.2 California, United States

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Your Rights:

• Know what personal information we collect, use, and share
• Request deletion of your personal information
• Correct inaccurate personal information
• Opt out of the "sale" or "sharing" of personal information
• Limit use of sensitive personal information (if applicable)
• Non-discrimination for exercising your rights

Sale or Sharing: We do not sell personal information for monetary consideration. However, we may share certain identifiers and technical data with advertising and analytics partners, which may constitute "sharing" under CPRA. To opt out, email privacy@mlion.io with "California Privacy Request" in the subject line.

We honor Global Privacy Control (GPC) signals as valid opt-out requests.

Shine the Light: You may request (up to twice annually) information about categories of personal information shared with third parties for direct marketing purposes. Email privacy@mlion.io with "California Privacy Data Request" in the subject line.

7.3 Israel

If you are located in Israel, your rights are governed by the Protection of Privacy Law, 5741-1981:

• You have the right to access and request correction of your information
• Requests may be submitted directly or through a legal representative
• We will provide access to your information, typically at no cost
• You may request information about processing purposes and third-party sharing
• Cross-border data transfers comply with applicable safeguards
• We retain information only as long as necessary or required by law

Contact privacy@mlion.io to exercise your rights. We may request proof of identity before processing requests.

8. International Data Transfers

The Platform is hosted on servers located in North America, Europe, and Asia. Your information may be transferred to and processed in countries outside your jurisdiction, including countries that may not provide the same level of data protection.

We use appropriate safeguards for international transfers, including:

• Standard Contractual Clauses approved by relevant authorities
• Adequacy decisions recognizing equivalent protection
• Other legally compliant transfer mechanisms

Our hosting providers include Amazon Web Services (AWS). You can review their privacy practices at https://aws.amazon.com/privacy/.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Remember your preferences and settings
• Authenticate your account
• Analyze Platform performance and usage
• Deliver personalized content and advertising

Cookie Management:

You can control cookies through your browser settings:

• Chrome: https://support.google.com/chrome/answer/95647
• Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
• Safari: https://support.apple.com/en-us/105082
• Edge: https://support.microsoft.com/en-us/windows/manage-cookies-in-microsoft-edge

Third-Party Cookies:

We use third-party analytics services like Google Analytics. These providers have their own privacy policies. Learn how Google uses data at https://policies.google.com/technologies/partner-sites.

Mobile Advertising IDs:

• iOS: Settings > Privacy & Security > Tracking, or reset under Privacy > Apple Advertising
• Android: Settings > Google > Ads > Opt out of Ads Personalization

10. Children's Privacy

The Platform is not intended for individuals under 18 years of age. We do not knowingly collect information from minors. If you believe a child has provided us with information, contact privacy@mlion.io immediately. We will take prompt steps to delete such information.

11. Third-Party Links

The Platform may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information.

12. Marketing Communications

You may opt out of marketing communications by:

• Clicking "unsubscribe" in any marketing email
• Emailing privacy@mlion.io with your request

You will continue to receive transactional and service-related communications necessary for Platform operation.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will notify you by:

• Updating the "Last Updated" date
• Posting a notice on the Platform
• Sending you an email or other notification (where required by law)

Your continued use of the Platform after changes become effective constitutes acceptance of the updated Privacy Policy.

14. Contact Us

15. Governing Law and Disputes

This Privacy Policy is governed by the laws of [Insert Jurisdiction]. Any disputes arising from this Privacy Policy shall be subject to the exclusive jurisdiction of the courts located in [Insert Location].

The United Nations Convention on Contracts for the International Sale of Goods does not apply.

16. Intellectual Property

All content, trademarks, and materials associated with the Platform are owned by Mlion Ads LTD. "Mlion" and related marks are trademarks of Mlion Ads LTD. No license to use any trademarks is granted without our prior written consent.

Last Modified:20/09/2025