Privacy Policy

1. Introduction

This Privacy Policy explains how REMOBY LTD (“Remoby”, “we”, “us”, “our”) collects, uses, shares and protects personal data when you:

• visit our website remoby.com (the “Website”);
• use our advertising and monetization solutions, including our supply-side platform and related services (collectively, the “Platform”); and
• communicate with us by email, phone or other channels.

We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable national data protection laws.

For the purposes of this Privacy Policy, “personal data” means any information that identifies, or can reasonably be used to identify, an individual.

2. Data controller and contact details

The data controller responsible for processing personal data in connection with the Website and the Platform is:

REMOBY LTD
28 Oktovriou, 367, Mediterranean Court, 1st Floor, Office A5,
3107, Limassol, Cyprus
Email: [email protected]
Phone: +357 9420300

If you have any questions about this Privacy Policy or our data protection practices, please contact us at the above details

3. Categories of personal data we collect

The personal data that we collect depends on how you interact with us and which services you use. We may collect and process the following categories of data:

1. Account and contact data

• Name, business email address, company name, role/title, login credentials, billing and invoicing information, communication preferences

1. Platform usage and log data

• IP address, device identifiers, browser type and version, operating system, time zone, language settings, date and time of access, pages viewed, Platform features used, clickstream data, referring/exit pages.

1. Advertising and monetization data

• Information related to advertising campaigns, creatives and performance metrics (impressions, clicks, conversions, revenue, spend, etc.), placement details, traffic sources, and similar information required to operate and optimize the Platform.

1. End-user data (publishers’ and advertisers’ users)

2. When our technology is implemented on websites, apps or other digital properties, we may process limited data about end users on behalf of our clients, such as:

• IP address, device and browser information, approximate geolocation (e.g. country, city), cookie identifiers or mobile advertising identifiers, information about ad requests and responses, and interaction with ads (e.g. views, clicks, conversions).
• Where required under GDPR, such processing is based on consent collected by our partners or on another applicable legal basis they determine.

1. Communication and support data

• Content of your communications with us (emails, messages via contact forms, support tickets), related metadata (date/time, technical logs), and any information you choose to provide.

1. Financial and transaction data

• Limited payment details related to payouts and invoices (such as bank account/IBAN, payment reference, billing address), records of payments and payouts.

We do not knowingly collect or process special categories of personal data (such as data about health, religion, political opinions, etc.) in the context of our business.

4. Purposes and legal bases

We process personal data only where we have a valid legal basis under GDPR. Depending on the context, this may be:

• Contract performance (Art. 6(1) (b) GDPR)
• Legitimate interests (Art. 6(1) (f) GDPR)
• Consent (Art. 6(1) (a) GDPR)
• Legal obligation (Art. 6(1) © GDPR)

In particular, we process personal data for the following purposes:

1. Providing and operating the Platform

• Creating and managing user accounts, verifying identity, enabling access to features, serving ads, measuring performance, processing payments.
• Legal basis: contract performance; legitimate interests in operating a secure and efficient ad platform.

1. Optimizing campaigns and Platform performance

• Analysing campaign performance, traffic quality, ad placements and user interactions in order to improve targeting, prevent invalid activity and optimize results for our clients.
• Legal basis: legitimate interests in improving our services and protecting our business and customers.

1. Customer support and communication

• Responding to enquiries, providing technical support, sending service-related notifications (e.g. account, billing or security notices).
• Legal basis: contract performance; legitimate interests in providing quality support.

1. Marketing and updates

• Sending information about new features, product updates, case studies, events and promotions, where legally permitted.
• Legal basis: consent (where required); legitimate interests in promoting our services to business contacts. You can opt out at any time using the unsubscribe link or by contacting us.

1. Security, fraud prevention and compliance

• Detecting and preventing fraudulent activity, abuse of the Platform, violations of our Terms of Use, as well as complying with legal and regulatory obligations (e.g. tax, accounting, anti-fraud).
• Legal basis: legitimate interests in securing our systems and clients; legal obligations.

1. Analytics and Website improvements

• Using aggregated and/or pseudonymised data to analyse Website traffic, improve user experience and develop new features.
• Legal basis: legitimate interests in operating and improving the Website; consent where cookies/trackers require it. See our Cookies Policy for details.

5 How we share personal data

We do not sell personal data. We may share personal data with:
1. Group entities and business partners

• Other entities within the same corporate group, and selected partners involved in delivering the Platform and related services (e.g. supply partners, demand partners, data centres, payment providers), to the extent necessary for the purposes set out in this Policy.

1. Service providers

• Third-party vendors that provide services such as hosting, infrastructure, analytics, fraud detection, security, communication tools, or payment processing. These providers only process personal data on our instructions and subject to appropriate contractual safeguards (including data processing agreements where required by GDPR).

1. Clients and publishers (for Platform operations)

• In the context of serving and measuring ads, certain pseudonymous identifiers or aggregated performance data may be shared with advertisers, agencies, SSPs, exchanges and publishers, as necessary to run campaigns and provide transparent reporting.

1. Authorities and legal requests

• Public authorities, regulators or courts where we are required to do so by law, or where disclosure is necessary to protect our rights or the rights of third parties, to enforce our agreements, or to investigate suspected fraud or other unlawful activity.

In all cases, we share only the minimum amount of personal data necessary for the relevant purpose and apply technical and organisational measures to protect it.

6 International data transfers

Because Remoby works with partners and service providers worldwide, your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), some of which may not provide the same level of data protection as your home country.
Where we transfer personal data outside the EEA, we ensure that appropriate safeguards are in place, such as:

• adequacy decisions by the European Commission;
• standard contractual clauses approved by the European Commission; or
• other mechanisms permitted by GDPR.

You can contact us using the details above if you would like further information on the specific safeguards applied to international transfers.

7 Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including:

• for the duration of your account and for a reasonable period thereafter for legitimate business purposes (e.g. resolving disputes, enforcing agreements, maintaining records);
• for the period required by applicable laws (e.g. tax and accounting rules);
• for shorter or longer periods where this is required or allowed by law, or where we have an overriding legitimate interest (for example, in case of ongoing disputes or investigations).

When personal data is no longer required, we will delete it or anonymise it in a secure manner.

8 Your rights under GDPR

Subject to certain conditions and limitations, you have the following rights under GDPR:

• Right of access – to obtain confirmation as to whether we process your personal data and, if so, to receive a copy.
• Right to rectification – to have inaccurate personal data corrected and incomplete data completed.
• Right to erasure – to request deletion of your personal data in specific circumstances (“right to be forgotten”).
• Right to restriction of processing – to request that we limit the processing of your personal data under certain conditions.
• Right to data portability – to receive certain personal data in a structured, commonly used and machine-readable format and have it transmitted to another controller where technically feasible.
• Right to object – to object to processing based on legitimate interests, including profiling, and to object at any time to processing for direct marketing.
• Right to withdraw consent – where processing is based on your consent, you may withdraw that consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
• Right to lodge a complaint – to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or alleged infringement.

To exercise your rights, please contact us at [email protected]. We may need to verify your identity before responding.

9 Cookies and similar technologies

We use cookies and similar tracking technologies on the Website and within the Platform to:

• enable core functionality and security;
• remember your preferences;
• measure and improve performance;
• support advertising and fraud prevention.

For more detailed information about the types of cookies we use and how you can manage your preferences, please refer to our Cookies Policy.

10 Security

We take appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, alteration or destruction, including:

• access controls and authentication;
• encryption in transit and at rest where appropriate;
• network and application security measures;
• regular monitoring, backups and audits.

However, no system can be completely secure. You are responsible for keeping your account credentials confidential and for notifying us promptly if you suspect any unauthorised use of your account.

11 Children’s data

Our Website and Platform are intended for business users and are not directed at children. We do not knowingly collect personal data from minors under the age of 18. If we become aware that such data has been collected, we will take steps to delete it.

12 Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated “Last updated” date. We encourage you to review this Policy periodically to stay informed about how we process personal data.

If required by applicable law, we will notify you of material changes and, where necessary, obtain your consent.