SSP Media LTD.  (“we” “us” “our” or “SSP Media”) is a global ad-tech company that operates and provides an online supply side platform currently known as “PX” (“SSP”). Company’s SSP provides third party partners (“Advertisers”) with a proprietary technology, designed and developed to offer an end-to-end solution, which enables third party publishers (“Publishers”) to display online advertisements to end users who use or otherwise interact with certain mobile webpages and desktop websites (“Digital Assets”) using available solutions in the market, such as real time bidding, tag integration, header bidding and other advanced hybrid solutions.

SSP Media recognizes the importance of your privacy and we take this issue very seriously. To this end, we have designed the SSP Media privacy policy (“Privacy Policy”) in a format that is easy to read so that you can clearly understand our privacy practices. This Policy describes SSP Media’s collection and use of the information provided or collected on or through our various services and features (collectively shall be defined hereinafter as the “Services”), which includes, our website which is currently located at sspmedia.co (“Site”) as well as our SSP for the purpose of displaying online advertisements within Digital Assets. We are committed to treating any information we collect with care and respect.

We have included below information about which data is collected, how we process and use your data, but before we would like to explain the basis on which we do so:

Where you sign up for any of our Services, we process your personal data in order to perform our contract with you;

If we have a legitimate interest in processing data, such as for direct marketing, online advertising or online identifiers when you access our Site or use our Services; or

We will also process your personal data where you have provided us with consent to do so.

INFORMATION WE MAY COLLECT

We may collect two types of data and information from our Users. The first type of information is non-identifiable and anonymous information (“Non-Personal Information”). We are not aware of the identity of the User from which we have collected the Non-Personal Information. Non-Personal Information is any unconcealed information which is available to us while Users are using the Services. Non-Personal Information which is being gathered consists of technical information and behavioral information, and may contain, among other things, the activity of the User on the Services, type of operating system and type of browser, type of device, User’s connection to the Site, or approximate geo-location.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information includes either: (i) contact information such as your name, email address, etc., which you have submitted voluntarily; or (ii) your Internet Protocol (“IP”) addresses (the addresses of computers on the Internet), (collectively, “Identifiers”). Note that, while Identifiers are considered Personal Information in many jurisdictions (such as the EEA), there are some jurisdictions in which such data is not considered as Personal Information. Therefore, we treat such information as Personal Information, in accordance with applicable laws, however we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any Personal Information such as your name or email address. The IP may be collected by our third party analytic partners that offer ways to opt-out, all as detailed below.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

You are not required by law to provide us with any information. You can always avoid from providing us certain Personal Information; however, you acknowledge that it may prevent you from engaging in certain Services.

Information we collect from visitors of our Site and Users of the SSP Media Services

Type of Information How Do We Use It?

In the event you contact us for support or other inquiries, either through the online form available on the Site, by sending us an email or by other means of communications we make available, you will be requested to provide us your name and email address. We will use this information solely for the purpose of responding to your inquiries and provide you with the support or information you have requested.

Identifiers We either directly or indirectly may collect our visitors’ of the Site IP or Identifiers when using the Services. We use this for our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Site and Services and the way in which we offer them; (ii) enhancing your experience with the Services; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow; and (iv) our legitimate interest of serving personalized advertisements on Digital Assets.

If you voluntarily subscribe to our newsletter you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option within the body of the newsletter or rather or by contacting customer support at clients@sspmedia.co If you voluntarily subscribe to our newsletter you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option within the body of the newsletter or rather or by contacting customer support at clients@sspmedia.co

We also collect certain technical Non-Personal Information (as detailed above) which relates to your use of the Services or the Site. We use this technical data in order to operate and manage our Site.

Information We Collect from Advertisers or Publishers

Type of Information How Do We Use It?

In order to use our Services as an Advertiser or Publisher you will be required to enter into a physical agreement with SSP Media. We will use this information for the purpose of performing our contract with you in order to provide you with the Services you have requested.

We also collect certain technical Non-Personal Information (as detailed above) as a visitor to the site and as detailed above. See the table above.

HOW WE COLLECT INFORMATION

Depending on the nature of your communication with us, we may collect the above detailed information from you, as follows:

automatically, including through the use of cookies (as detailed below), or other similar tracking technologies when a user interacts with a Digital Assets; or

when you voluntarily choose to provide us with information, i.e. when you contact us, sign-up for our newsletter, all as detailed in this Privacy Policy. Whenever technically possible and required under applicable law, we will ask for your consent to collect your Personal Information and offer you the choice to opt-out.

COOKIES AND SIMILAR TECHNOLOGIES

When you access or use the Service, we may use industry-wide technologies such as “cookies” (or similar technologies), which store certain information on your device (i.e., locally stored) and which will allow us to customize the Service and content as well as enhance your experience of the Services.

The cookies and similar technologies used by us are created per session and do not include any Personal Information, other than your preference, navigation on the applicable Digital Assets as well as the session key and allow us to analyze trends, track users’ movements around the Site, which are removed as your session ends. Most browsers will allow you to erase cookies from your device, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your experience may be limited.

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited

SHARING YOUR INFORMATION WITH THIRD PARTIES

SSP Media will not share the Personal Information it collected with any third parties or any of its partners except in the following:

(a) Authorized Disclosures. We may disclose your Personal Information to third parties when you consent to a particular disclosure of your Personal Information. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices. In addition, we may share Identifiers, for the purpose of operating our business and providing the Services, as well as to calculate payments and detect fraud, security or technical issues in connection with the Services.

(b) Compelled Disclosures. To the extent required, SSP Media will share Personal Information to comply with any applicable law, regulation, legal process or governmental demand (e.g., pursuant to law enforcement inquiries, subpoenas or court orders), or when we believe, in good faith, it is required in order to enforce our policies (including our policies and agreements) including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues. In addition, we will share your information, solely to the extent required to establish or exercise our rights to defend against legal claims or to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.

(c) Fraud Detection. To detect, prevent, or otherwise address fraud, security or technical issues;

(d)  Service Providers. We may disclose Personal Information to our service providers in order for such service providers to perform requested services on our behalf.

(e) Business Transfers. We may share Personal Information, in the event of a corporate transaction. In the event of the aforementioned, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.

(f) Non-Personal Information. We may share aggregate or Non-Personal Information with our Business Partners and additional third parties in accordance with the terms of this Policy. We may store Non-Personal and Personal Information on our servers or our cloud servers, use or share Non-Personal Information in any of the above circumstances, as well as for the purpose of providing and improving our Service, aggregate statistics, marketing and conduct business and marketing analysis, and enhance your experience with the Digital Assets.

(g) Identifiers. We may share identifiers collected by us (as detailed above), for the purpose of operating our business and providing the Services, as well as to calculate payments in connection with the Services.

 User Rights

Individuals have the right to know what information we hold about them and, in some cases, to have

such information communicated to them. Individuals may also ask for our confirmation as to whether or

not we process their Personal Information. Subject to the limitations in applicable law, individuals may

also be entitled to obtain from us the Personal Information they have provided to us in a structured,

commonly-used, and machine-readable format, and may have the right to transmit such Personal

Information to another party.

The principal rights under applicable data protection law in relation to Personal Information are as follows:

the right to access any information which is provided to us;

the right to rectification;

the right to erasure;

the right to restrict processing;

the right to object to processing;

the right to data portability;

the right to complain to a supervisory authority; and

the right to withdraw consent (to the extent applicable).

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.

Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.