This privacy policy ("Policy") explains Epom's privacy practices for processing personal information on Epom's website (the "Site") and via Epom's Services. It applies whenever you access or use the Site or a mobile application or website that is connected and/or uses the Services (as applicable). Please take the time to read the full Policy. Capitalized terms used herein are defined in this Policy.

Epom acknowledges the importance of information privacy. Epom is firmly committed to protecting the privacy of Internet users and fostering users' confidence in the Internet, Internet advertising and has created this Policy.

1. Epom Services

Epom is an ad serving platform and exchange that provides targeted advertising services to its clients ("Partners").

Epom develops and operates several services in the ad-tech environment, such as a programmatic ad exchange, mediation platform, programmatic mediation platform and other online advertising-related services, all of which may include advertising management services, such as optimization, ad serving, campaign management and the compilation of relevant statistical data (collectively, the "Services").

Epom collects personal information in order to provide the Services and for other specific purposes, as described in this Privacy Policy. Please note that you are not required by law to provide Epom with any personal information.

Whenever user visits a website operated by a Partner or any third-party site or application where ads code from Epom is implemented, ads may be served and some data may be collected. That data helps to get the most relevant ads for the user.

We collect and store Personal Information that you provide directly to us through the Website during the registration process or otherwise in connection with your use of our Website. We require registration at Epom from everybody who wants to gain access to the platform and use its features. The registration process presupposes providing personal information, including full name, contact details. When you choose to provide us with your Personal Information you consent to the use of your Personal Information as identified in this Policy and as may be further identified at the time of collection. You can choose not to provide us with your Personal Information, but in that event, we may not be able to provide you with full use of the Website or Services.

We may also automatically collect some Personal Information from you when you visit our Partners Websites, or through third party websites (include social media websites).

All of your Personal Information may be processed automatically.

2. Use of Personal Information

We may use your Personal Information for a number of purposes, such as:

• — to inform the agents of prospective advertisers that you are on visiting the web site, so that the website can solicit bids for the opportunity to show an ad to you;

• — to combine your browsing habits with data they already have collected about you (and infer further insights about you) so that they can select relevant ads for you;

• — to identify whether you are the kind of person that its advertising clients want to show ads to;

• — to monitor your behavior on websites in order to determine if you have viewed or interacted with an ad;

• — to combine your browsing habits with data they already have collected about you (and infer further insights about you), to verify that you are human rather than a "bot" attempting to defraud advertisers;

• — to record the number of times you have viewed each ad, to prevent a single ad being shown to you too frequently;

• — to enable and optimize the Services' tools and features

• — to target advertising to the most receptive audiences;

• — to help us develop, customize, deliver, support and improve our services, products, content, and advertising;

• — to serve advertisements on our Service or through emails;

• — tracking and analyzing user preferences;

• — enhancing user experience;

• — ensure you have a personalized and consistent experience in using the Website and Services;

• — protecting the security of our Website;

• — other legitimate business purposes described in this Policy.

Any of your Personal Information be used for Epom internal purposes only.

3. Collected data

The following data and information may be collected from a user:

• — name;

• — email address;

• — website.

The following data and information may be collected automatically:

• — activity on the website;

• — IP address;

• — date and time of visit;

• — device and browser information;

• — geographic info, based on IP address (to the city level);

• — served ads data;

• — data, received from other digital advertising networks;

• — hashed email address;

• — User ID assigned in our system;

• — Cookies;

• — Web beacons.

Applications with embedded Epom's Android/iOS SDK also may gather IDFA/AAID and exact location, if it's allowed by application permissions.

This data is used in a non-personally identifiable way for the purpose of ad serving operations only.

4. Information sharing

Epom does not sell raw collected information to any third party.

Epom may share personal information to Partners, Epom's corporate affiliates in order to provide the Services.

Epom may also disclose collected information to an authorized third party in connection with legal proceedings or with a sale of Epom's business.

Users' contact details will not be shared with, sold to or accessible to any third party, being used only for communication between a user and Epom administrators.

Aggregated pseudo-anonymized information may be shared with third parties for reference, statistical or marketing reasons and other similar purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you.

Upon the user request Epom may provide a list of Partners and Epom's corporate affiliates to whom Personal Information has been transferred.

Epom will share your personal information only subject to the terms of this Policy, or subject to your prior consent.

5. Beacons and cookies

Epom may use cookies, tracking pixels and other similar beacon technologies to provide services to Partners.

Cookies are small data files stored on user's device that help to identify the same user's browser. Using cookies is common and prevalent practice in the ad industry. The following types of cookies may be employed by Epom:

• — cookies necessary for proper website operation (e.g. authorization);

• — cookies gathering personally non-identifiable information on how people use Epom and tracking performance;

• — option and functionality choices storage to provide users with customized and relevant experience;

• — targeting and advertising data cookies for the purpose of advertising campaign tracking, serving targeted relevant ads and interest-based advertising.

Cookies are used to assign an anonymous and unique ID number to users when they view or login to our site. The cookie does NOT include user's name, address, phone number, e-mail address, or any other personally identifiable information. Cookies are relevant to our servers for recognizing the authorized users, so that users can browse the site without being repeatedly asked for authorization.

Web Beacons are transparent small images or JavaScript codes. They are used to gather personally non-identifiable data on how visitors interact with sites, such as ad impressions, clicks on ads, and similar.

6. Cookies and IDFA/AAID removal

Cookies can be removed using privacy preferences in user's browser or application or using general system privacy settings (such as available in Android operating system, for instance). After that Epom will not be able to serve relevant targeted advertising and will continue serving general non-personalized ads.

Please refer to browser instructions to decline the saving of cookies:

• Chrome: https://support.google.com.

• FireFox: https://support.mozilla.org.

• Safari: https://support.apple.com.

• Internet Explorer: http://windows.microsoft.com.

Declining of cookie saving can affect normal site operation.

For changing privacy settings on mobile devices please refer to the following instructions:

• Android: https://support.google.com.

• iOS: https://support.apple.com.

7. Epom cookies opt-out and behavioral advertising opt-out

Cookies opt-out allows you to instruct Epom that you do not want to be assigned a unique user identification number. Opt-out means that a special cookie OPTOUT=1 is set for ad serving domain with expiration date in 2 years. This cookie will prevent Epom from setting any new cookie and clearing existing cookies after the next request to the ad server. Epom may still show ads to users who chose to opt-out from cookies. Epom's Partners may use several different ads serving domains, cookies opt-out mean you need to opt-out for every ad serving domain. Epom's Partners are required to provide a tool to opt-out from all ad serving domains as a part of their respective Privacy Policy.

In order to provide users with the most relevant ads Partners may cooperate with other ad networks which provide their own opt-opt tools. To opt-out from behavioral and interest-based advertising users may use services www.youronlinechoices.com/ provided by Interactive Advertising Bureau and www.networkadvertising.org/choices/ provided by Network Advertising Initiative.

8. Security

Epom applies reasonable measures to protect the collected data against accidental or unlawful destruction and loss, alteration, unauthorized disclosure, processing or access. Personal Information of all European visitors are stored in Europe.

Epom is a member of Interactive Advertising Bureau and complies with its highest industry standards on digital advertising, including user's privacy protection best practices.

9. Request for access to and correction of Personal Information

Each user of Site or Epom's Services may update, edit, delete, withdraw consent for collection and obtain a copy of personal information. The Site never uses any of users' private data, except for the e-mail address in inner correspondence. Once collected, all private data will be stored safely for record keeping purposes.

Please be advised that Epom may retain and use your personal information as necessary to comply with its legal obligations, resolve disputes and enforce Epom's agreements.

In addition, after Epom deletes your personal information, residual copies may take a period of time before they are deleted from Epom's active servers and may remain in its backup systems. This deletion will not change or delete personal information which may have already been shared with third parties, as permitted in this Policy or any other agreement between you and Epom.

Epom conducts periodic assessments of its data processing and privacy practices to ensure that it complies with this Policy, update the Policy when necessary, and ensure that the policy is properly displayed and accessible.

10. Term of store Personal Information

We collect and store Personal Information for as long as this information is relevant and necessary for current advertising companies.

11. Children's Privacy

Our Services do not address anyone under the age of 16. We do not knowingly collect personal identifiable information from children under 16. In the case we discover that a child under 16 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

12. Partners

Partners and ads publishers may collect additional data and information for their use, explained by respective privacy policies on their web sites.

13. External links

Our site contains links to external websites. Epom.com is not responsible for the privacy practices and content of such websites or applications (including widgets). Often links to other websites are placed at Epom for informative purposes only, to refer our users to topics they may find useful. Please remember that your browsing any other website, including the ones linked up to Epom, is subject to their own rules and policies. Epom.com denies responsibility for your interaction on other websites.

14. Legal Basis for Processing Personal Data of EEA and Swiss Individuals

Epom is committed to compliance and adherence to Personal Data privacy and protection laws, rules and regulations, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

15. Changes

Epom reserves the right to amend this Privacy Notice from time to time. Changes will be posted on this page. All Personal Information can be processed automatically.

16. Contact us

If you have any questions or comments about this Privacy Policy, please contact us at support@epom.com

Epom Ltd.
Nancy Whiticker House,
7 Old Street,
Roseau,
Commonwealth of Dominica