Legal

Privacy Policy

Effective Date: December 4, 2020

This Privacy Policy explains how OpenX Software Ltd. and its subsidiaries (“OpenX”, “we” or “our”) collect, use, and disclose information, and your choices for managing your information preferences.

Key Points

  • We operate one of the world’s largest independent advertising exchanges, enabling websites, apps and advertisers to market, sell and buy digital and mobile ad space.
  • If you visit one of the websites or apps that we work with, we may collect, process and share data about you or your device with advertisers so they can determine whether to show you an ad. The data collected and shared about you allows our advertising partners to show you ads they believe will be relevant to you.
  • This information is limited to device identifiers and other identifiers consisting of a random series of letters and numbers. We don’t have your name, contact information or any other information that directly identifies you as an individual.
  • You have rights and choices with respect to how we collect and use your data. Learn more in the sections of this Privacy Policy entitled “Interest-Based Advertising and Opting-Out.” California residents can learn more about their rights, including how to ask us not to sell their information, under the California Privacy Notice section of this Privacy Policy.
  • Please read this entire policy for further detail.

What This Policy Covers

This Privacy Policy describes OpenX’s data practices when you:

  • visit a website or app that uses the OpenX services (“Services”)
  • visit our corporate website (www.openx.com);
  • provide OpenX with your information to register for the Services; or
  • otherwise interact with the Services.

This Privacy Policy also describes the choices that OpenX provides in connection with our collection and use of your information.

OpenX receives data from website and app publisher customers and ad networks (“Publishers”), advertising demand partners (e.g. demand side platforms, advertising agencies and brands), (“Demand Partners”), service providers and consumer data resellers. You should note that Publishers, Demand Partners and other partners may also have their own policies that govern how they collect, use, and share data. These policies may differ from OpenX’s policies described in this Privacy Policy. In particular, you should consult the privacy policies of the websites you visit and apps you use to become familiar with their privacy practices and to learn about any choices that these companies may offer with respect to their information practices.

Finally, the OpenX website may contain links to websites or content operated and maintained by third parties, over which we have no control. We encourage you to review the privacy policy of a third-party website before disclosing any information to the website.

Data Practices for the Services

Background Regarding the Services

Our Services help Publishers make money through advertising, and Demand Partners reach the consumers they’re interested in targeting.  The Services include our Ad Exchange, a web-based marketplace that enables Publishers and Demand Partners to efficiently market, buy and sell digital and mobile advertising inventory (the “Ad Exchange”). 

Information We Collect through the Services

We collect information through Publishers that use our Services. For example, when you visit a website or app and the Publisher sends us a request to show you an ad, we collect certain information about the ad space, you and your device to help inform a Demand Partner’s decision to serve the ad.  We also collect information through Demand Partners that use our Services, as well as from other third-party partners. This information we collect can identify your device over time. We do not know your name or contact information, or any other information that would directly identify you as an individual.  However, this information may still be considered “personal data” or “personal information” under applicable data privacy or data protection laws. 

In particular, we may collect the following categories of information:

  • Unique online identifiers (e.g. IP address, cookies, mobile advertising identifiers such as Apple IDFA and Android Advertising ID)
  • Information about your  browsing behavior on a Publisher’s website or app (e.g. domain or app store URL or bundle ID, category code associated with website or app, referring website address, date/time of visit, ‘click through’ data) 
  • Browser information (e.g. browser type, version, language,)
  • Device information (e.g. screen dimensions, device brand and model)
  • Internet service information (e.g. Internet Service Provider used by you)
  • Derived location data (as derived from IP address or GPS (for mobile))
  • Precise location data (if you have enabled location services on your device and a Publisher passes that data to us)
  • Ad reporting or delivery data (e.g. size/type of ad, ad impressions, location/format of ad, data about interactions with the ad)
  • Interest segments (i.e. inferred information on the behavior or likely interests associated with you)
  • Retargeting data (i.e. data indicating previous interest in a product or website)
  • Other data that can be passed in the request to the Demand Partner to inform their decision (a non-exhaustive list of fields can be found at https://docs.openx.com/Content/publishers/s2s-openrtb-bidrequests.html).

We primarily recognize your devices through the following identifiers:

  • Cookies and Similar Technologies – We use cookies (a small file containing a string of characters that uniquely identifies your Web browser), Web beacons (an electronic file placed within a Web site that monitors usage), pixels, etags, and similar technologies to collect information about your browsing habits in order to make advertising more relevant to you and your interests. These technologies are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. They remember the websites you visit and that information is shared with other parties such as Demand Partners.  Please see our Interest-Based Advertising section below for information about your choices regarding our use of these technologies for interest-based advertising.
  • Mobile Advertising IDs – We and our partners use standard mobile advertising identifiers, for example the “IDFA” advertising identifier used on Apple’s iOS devices and the “Google Advertising ID” advertising identifier used on Android devices, to track your use of mobile apps on your device(s). 

Publishers, Demand Partners, and third party data partners may also utilize cookies or similar technologies. The collection of information through cookies or similar technologies by such third parties will be governed by their own privacy policies and principles, which OpenX does not control.

Your browser may offer tools to enable or disable cookies by modifying the settings in your browser. To read about your choices with regard to OpenX’s use of cookies in our Services, please see the “Interest-Based Advertising and Opting Out” section of this Privacy Policy.

How We Use the Information We Collect through the Services

We pass data we collect from ad requests Publishers send to the Ad Exchange to Demand Partners so that they can decide whether to show you an ad and send you more relevant ads. From certain ad request data received from Publishers, we derive additional information that we include in the request sent to Demand Partners. For example, from an IP address, we can derive certain general location information you like city and state. We may also add additional data we have collected from other sources to inform the Demand Partner’s bid and improve the relevance of the advertising. 

We also use the information we collect to host, operate, maintain, secure, and further develop and improve our Services, such as to keep track of advertising delivery, to measure the effectiveness of advertising delivered through our Services, and to investigate compliance with OpenX’s policies and terms and conditions.

How We Share Data Collected by the Services

We may disclose the information that our Services collect about you in the following ways:

  • Ad Transactions – We pass data to Demand Partners so that they can combine this information with other information they have independently collected to determine whether to show you an ad. 
  •  
  • Business Transfers – we may share the data we collect in connection with an actual or proposed sale or transfer of all or a part of our business or assets, corporate merger, consolidation, or bankruptcy.
  •  
  • Compliance with Regulatory Authorities and Laws – we may share the data we collect with law enforcement, regulatory authorities, courts with competent jurisdictions, emergency services or other necessary third parties for legal, protection, security and safety purposes, including: 
    • To comply with laws or regulatory requirements, including to meet national security requirements, and to respond to lawful requests and legal process;
    • To protect the rights and property of OpenX, our agents, customers, and others, including enforcing out agreements, policies, and terms of use and protecting our network and physical assets; and/or
    • To protect the safety of our employees and agents, or partners, or any person.
  • Service Providers – We share the relevant data we collect with our partners who perform functions on our or our clients’ behalf. Examples include: analyzing data; cross-device linking; fraud prevention; and hosting data. 

Data Practices for OpenX Website and Customer-Provided Information

Information the OpenX Website Collects

OpenX collects contact information through our website when you choose to provide it, such as your name, username, or email address. For example, you may be asked to provide us with contact information when you register with the OpenX website and when you use the Services. The decision to provide this information is optional; however, if you elect not to register or provide such information, you may not be able to access certain content, features, or services available on or through the OpenX website. In order to make payments owed to Publishers or collect payments from Demand Partners, OpenX may also request additional information from Publishers and Demand Partners such as other contact information and billing account information.

OpenX uses this contact and billing information to operate and improve our website and Services, such as to provide notices about your Service, to fulfill your service requests, or to request your feedback or conduct research. OpenX also uses contact information to send you information about new products or Services; where OpenX needs your permission to do this, we only send such information in accordance with any permissions granted.

We may also collect additional information about your activities on our website as described below.

Cookies and Other Similar Technologies. 

We use cookies, Web pixels, etags, and similar technologies to operate and improve our website. Some of our Vendors (defined below) may also use such technologies in connection with the services they perform on our behalf.

We use the following categories of cookies for our website:

  • Strictly Necessary Cookies

These cookies are essential in order to enable you to navigate our website and use its features. Without these cookies, services you have asked for such as remembering your login details cannot be provided.

  • Performance Cookies

These cookies collect anonymous information on how people use our website. For example, we use these cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve, such as navigation and marketing campaigns. These cookies do not store personal details that identify you as an individual.

  • Functionality Cookies

These cookies remember choices you make such as the country from which you visit our website, language, and search parameters such as size, color or product line. These cookies can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and relevant. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

Your browser may offer tools to enable or disable cookies by modifying the settings in your browser. However, please note that certain features of the OpenX website may not work if you delete or disable cookies. 

Information Sharing

We will disclose contact and billing information to third parties only as described in this Privacy Policy:

  • with your express permission;
  • with our affiliates, which include entities controlling, controlled by, or under common control with OpenX;
  • in the event that OpenX is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, we may disclose or transfer information in connection with such transaction;
  • where we believe it is necessary to protect OpenX or our users; to enforce our terms or the legal rights of OpenX or others; or to comply with a request from governmental authorities, legal process, or other legal obligations; orwhere we contract with third parties to provide certain services, such as advertising, analytics, data management services, web hosting, and web development (Vendors”). We ask Vendors to confirm that their privacy and security practices are consistent with ours, we provide our Vendors with only the information necessary for them to perform the services we request, and Vendors are prohibited from using such information for purposes other than as specified by OpenX. The following Vendors are considered processors for the OpenX website: 

Processor Purpose Entity Country Website
Marketo Collect data and insights on potential and active customers in order to provide relevant marketing content, insights and a better, more personalized experience with the OpenX brand. Also used to send external email communications and store lead data. USA https://www.marketo.com/
Wufoo Gather user feedback on documentation to help improve documentation. USA https://www.wufoo.com/
Google Analytics Collects data for website to track website usage, trends, and monitor for any potential errors or attacks USA https://analytics.google.com/analytics/web/
(or to opt out: https://tools.google.com/dlpage/gaoptout/)
MixPanel Analytics platform to track customer usage of our user interface, which can be used to inform product decisions USA https://mixpanel.com/
Appinium Surface training video content in an effort to provide our customers with multiple mediums through which to learn USA http://www.appinium.com/

 

We may also share and disclose other information that we collect, including deidentified or aggregate information, as we consider necessary to develop and provide our Services, including in the ways described above.

Public Forums 

OpenX may offer online resources that facilitate communications among the OpenX client community and others. Whenever you voluntarily post information to any public forum offered by OpenX, such information along with your user name can be accessed by other users of the forum, including members of the public if the forum is open to the public.

Children’s Online Privacy Protection Act Notice

OpenX does not engage in activities that require parental notice or consent under the Children’s Online Privacy Protection Act (COPPA). If you believe that OpenX has inadvertently collected information from a child under 13 that is subject to parental notice and consent under COPPA, please contact OpenX using the contact information below to request deletion of the information. 

Interest-Based Advertising and Opting Out

OpenX adheres to the Digital Advertising Alliance (DAA) Self-Regulatory Principles in the US and to the European Digital Advertising Alliance (EDAA) Principles in the European Union (“EU”) and the IAB Europe OBA Framework.

As discussed above, the Services use cookies, Web beacons, pixels, etags, and similar technologies to give Publishers the possibility to offer, and Demand Partners the ability to show, targeted ads on the device on which you are viewing this policy or a different device. These ads are more likely to be relevant to you because they are based on inferences drawn from location data, web viewing data collected across non-affiliated sites over time, and/or application use data collected across non-affiliated apps over time. This is called “interest-based advertising.” When we identify possible relationships among different browsers and devices, this is called “cross-device linking.” In addition, certain third parties may collect data on the OpenX website and combine this data with information collected from other websites over time for purposes that include interest-based advertising.

Opting Out for Cookie-Based Services: If you would like to learn more about this type of advertising, or would prefer to opt out of website interest-based advertising enabled by the Services, European Economic Area (“EEA”) individuals may opt-out of this form of advertising by companies participating in the EDAA at www.youronlinechoices.com and all other users may visit www.aboutads.info/choices to opt out of this form of advertising by companies participating in the DAA self-regulatory program. Please note that in order for your opt-out choice to be effective using this tool, you must ensure that your browser is set to accept third-party cookies such as the OpenX opt-out cookie. Some browsers block third-party cookies by default, and you may need to change your browser settings to accept third-party cookies before opting out. 

Opting Out for Certain Non-Cookie Services (in applicable countries): To help identify your browser and/or possible relationships between different browsers and devices, OpenX or our partners may use the local storage or cache in your browser. Using the browser cache or local storage helps OpenX or our partners deliver interest-based advertising to a browser without the use of third-party cookies. To opt out of OpenX’s use of local storage or the browser cache to provide its services, please (1) use any tools provided by your browser to clear local storage and the browser cache, and (2) turn on any “Do Not Track” header setting offered by your browser. As long as the two steps are completed and maintained on a browser, OpenX will not use local storage or the cache on that browser to identify and sync browsers and devices. If you also want to opt out of OpenX’s use of third-party cookies for interest-based advertising enabled by OpenX’s Ad Exchange, please see instructions above.  

Opting Out for Mobile Application Data: To opt out of OpenX’s collection, use, and transfer of data for interest-based advertising on mobile apps, you may download the DAA’s AppChoices application from the Android or iOS app store on your mobile device. Users outside the United States may not have access to this application; instead, you can use “Limit Ad Tracking” in your iOS settings or “Opt out of interest-based ads” in your Android settings to limit OpenX’s collection of data for interest-based advertising.

Opting Out for Location Data: You may opt out of our collection, use, and transfer of precise location data by using the location services controls in your mobile device’s settings.

Opting Out for Television & Internet Connected Device Data: Your Internet connected device (e.g. smart TV or a set up box) may give you the ability to opt out of the use of information for advertising purposes. To determine if your device has these options, please visit your device’s setting menus.

Effect of Opting Out: If you use a different device or browser, or erase cookies from your browser, you will need to renew your opt-out choice.

If you opt out of OpenX’s practices, you may continue to receive interest-based advertising through other companies. Publishers and Demand Partners that participate in the Ad Exchange may also use their own cookies and other ad service technologies to display and track their ads. We do not control and are not responsible for such Publishers’ and Demand Partners’ information practices or their use of cookies and other ad service technologies. To learn more about the practices of these companies, please read their privacy policies.

Even if you opt-out, OpenX may continue to collect data for other purposes and you still may receive advertising from the Ad Exchange when you visit websites of a Publisher who uses our Services – but such advertising will not be targeted to you.

Reviewing and Updating Information

OpenX takes reasonable steps to ensure that information is accurate, complete, current, and reliable for its intended use. For contact or billing information submitted through our website, you may review, correct, update, or change your information, request that we deactivate your account, or remove your information from our direct marketing efforts, at any time by e-mailing us at privacy@openx.com.

For information on opting out of interest-based advertising enabled by OpenX’s Ad Exchange, click here.

Nevada Privacy Rights

Under Nevada law, Nevada residents may submit a request directing us not to make certain disclosures of personal information we maintain about them.

To exercise this right, please contact us: 

California Privacy Notice

This section contains disclosures required by the California Consumer Privacy Act of 2018 (“CCPA”) and applies only to “personal information” that is subject to the CCPA and only to California residents. 

Collection, Disclosure or Sale of Personal Information

Customer Personal Information. Currently, personal information about our current and former business customers is exempt from most CCPA obligations.  We do not and will not sell personal information about our business customers and former customers.  

Personal Information About California Residents Collected through our ServicesIn the last 12 months, we collected the categories of personal information about California residents described above in the Data Practices for the Services section of this Privacy Policy and summarized in the chart below. Our use of such personal information may qualify as a “sale” under the CCPA, since the data we provide to partners helps us generate valuable consideration. The table below sets forth which of these categories was “sold” in the past twelve months.

Categories of Personal Information Categories of sources from which information is collected: Business or commercial purposes for collection, use, and sharing: Sold or Disclosed for business purposes to the following categories of third parties:
Personal and online identifiers (such as unique online identifiers like cookies, mobile advertising IDs, and hashed emails) All categories listed below. All purposes listed below. All categories listed below.
Commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered) consumer data resellers All purposes listed below. Disclosed for business purposes to service providers, cloud computing services providers, data analytics providers, and operating systems and platforms.
Internet or other electronic network activity information (such as browsing history, interactions with a website or advertisement) All categories listed below. All purposes listed below. All categories listed below.
Geolocation information All categories listed below. All purposes listed below. All categories listed below.
Inferences drawn from the above information about your predicted characteristics and preferences All categories listed below. All purposes listed below. All categories listed below.
Other information about you that is linked to the personal information above All categories listed below. All purposes listed below. All categories listed below.

Categories of Sources: We collect this personal information from the following categories of sources: Publishers; Demand Partners; service providers (e.g. fraud prevention services, identity resolution platforms, Vendors on our website); and consumer data resellers.

Why We Collect, Use, and Share California Information: We use and disclose the personal information we collect for our commercial and business purposes, as described in greater depth under the Data Practices for the Services section of this Privacy Policy.  These commercial and business purposes include, without limitation:

  • Providing the Services, including, without limitation, enabling Publishers and Demand Partners to market, sell and buy digital and mobile advertising inventory.
  • Other business purposes as identified in the CCPA, which include:
    • Providing advertising or marketing services;
    • Auditing related to our interactions with you;
    • Legal compliance;
    • Detecting and protecting against security incidents, fraud, and illegal activity;
    • Debugging;
    • Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
    • Internal research for technological improvement;
    • Internal operations;
    • Activities to maintain and improve our services; and 
    • Other one-time uses.

Recipients of California Personal Information: To the extent our use of personal information constitutes a “sale” under the CCPA, we “sell” the categories of personal information designated above to the categories of third parties listed below: 

  • Demand Partners (including, without limitation, demand-side platforms, ad agencies and advertisers);
  • Publishers; and
  • Advertising technology companies (including, without limitation, data management platforms used by our partners).

We disclose the categories of personal information designated above to the categories of third parties listed below for business purposes: 

  • Service providers, as defined by the CCPA;
  • Government entities;
  • Publishers;
  • Demand Partners;
  • Internet service providers;
  • Cloud computing services providers;
  • Fraud protection vendors;
  • Cybersecurity vendors;
  • Data analytics providers; and
  • Operating systems and platforms.

 

Your Rights Regarding Personal Information

California residents have certain rights with respect to the personal information collected by businesses.  If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

  • The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information.
  •  
  • The right to request that we delete the personal information we have collected from you or maintain about you.
  •  
  • The right to opt out of our sale(s) of your personal information.
  •  

To exercise any of the above rights, please click here and submit the verifying information.  Under the CCPA, you have a right not to receive discriminatory treatment when you exercise the above rights.

If you wish to opt out of the use of your personal information for interest-based advertising purposes, you may also do so by following the instructions under “Interest-Based Advertising and Opting Out” above. Note that because these opt outs are specific to the device or browser on which they are exercised, you will need to opt out on each browser and device.

Verification Process and Required Information: Because most of the information we store can only identify a particular browser or device, and cannot identify you individually, we may need to request additional information from you to verify your identity or understand the scope of your request. Such additional information may include your online identifier (i.e. cookie or mobile advertising ID) and some proof that the devices that have the cookie or mobile advertising ID you provide are yours, such as a screenshot of the applicable cookie or of a screen that displays the mobile advertising ID or other documentation that can verify you.

Authorized Agent: You may designate an authorized agent to make a CCPA request on your behalf by verifying your identity and providing written permission to your agent to make the request for you.

Minors’ Right to Opt In: We do not sell the personal information of consumers that we know to be under 16 years of age.  

International Information Transfers

Please be aware that the information we collect, including contact and billing information, may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store information in the United States and your consent to this Privacy Policy or use of OpenX Services represents your agreement to this processing.

For EEA and Swiss Individuals.

OpenX complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from EEA member countries and Switzerland, as that term is defined in the Privacy Shield Framework. OpenX has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

OpenX is accountable for information that it receives under the Privacy Shield and subsequently transfers to a third party. OpenX transfers contact and billing information to third parties as described above in this Privacy Policy. Additionally, OpenX transfers other information which meets the definition of “personal data” in the Privacy Shield Framework to service providers and to OpenX’s customers such as Publishers and Demand Partners including for interest-based advertising as described above. In particular, OpenX is responsible under the Privacy Shield Principles if third-party controllers to whom it transfers information or third-party agents it engages to process this information on its behalf do so in a manner inconsistent with the Privacy Shield Principles.

In cases of onward transfer to third parties of data of EEA or Swiss individuals received pursuant to the EU-US Privacy Shield or the Swiss-US Privacy Shield, respectively, OpenX is potentially responsible.

EEA and Swiss individuals have the right to access the personal information that OpenX maintains about you, as that term is defined in the Privacy Shield Framework, and you may be able to correct or amend that information if it is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, please email privacy@openx.com. For information on opting out of interest-based advertising enabled by OpenX’s Ad Exchange, click here.

OpenX commits to resolve complaints about our collection or use of your personal information. EEA or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact OpenX at:

privacy@openx.com
OpenX Technologies, Inc.
Attention: Legal Department
888 East Walnut Street, 2nd Floor
Pasadena, CA 91101
USA

or 

OpenX Technologies, Inc.
Attention: Legal Department
Aleja 29 Listopada 20
31-401 Krakow
Poland

OpenX has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. 

A binding arbitration option may also be made available to you in order to address Privacy Shield complaints not resolved by any other means.

OpenX is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Security

Information that we collect is stored using procedures and practices reasonably designed to help protect information from unauthorized access, destruction, use, modification, or disclosure.

Policy Updates

From time to time, we may change this Privacy Policy. If we decide to change this Privacy Policy, in whole or in part, we will inform you by posting the revised Privacy Policy on the OpenX website. Those changes will go into effect on the effective date disclosed in the revised Privacy Policy.

Contact Us

If you have any questions or concerns regarding this OpenX Privacy Policy, please contact us by e-mailing us at privacy@openx.com. You may also contact our data protection officer at dpo@openx.com.

Additional Information for EEA Individuals

For EEA individuals, the data controller in respect of your personal information is OpenX Ltd. Retention of personal information of EEA individuals will be handled in accordance with OpenX’s data retention policy.  As set out above, Publishers may use the Services to process data that they collect for their own purposes. In this respect we act as data processor for the Publisher, which may have its own Privacy Policy, which explains how it uses personal information.

Rights of EEA Individuals

Where OpenX processes personal data of EEA individuals as a data controller, such individuals: (i) may have the right to request access to and rectification or erasure of personal information; (ii) may restrict the processing of personal information, object to processing, and/or exercise the right of data portability; and (iii) may have certain rights to withdraw consent without affecting the lawfulness of processing and the right to lodge a complaint with a supervisory authority. For any requests or information regarding the rights set out above, please contact us by e-mailing us at dpo@openx.com.

Legal Basis for Processing Personal Information of EEA Individuals 

On certain occasions, OpenX relies on the consent of the individual to process personal information (for example, when the user inputs personal information into the OpenX website). On other occasions, OpenX may process personal information when OpenX needs to do this to fulfill a contract or where OpenX is required to do so by law.

OpenX may also process data when it is in OpenX’s or its customer’s legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights (which may vary based on an individual’s jurisdiction). Those legitimate interests include improving OpenX’s Services.

List of Sub-Processors

The sub-processors we use for our Services are available in the OpenX Community.

For Information Collected or Used in Japan

OpenX Japan Kabushiki Kaisha (OpenX Japan) may share contact and billing information in the cases of information sharing set forth in “Information Sharing.” When OpenX Japan shares contact and billing information with our affiliates, the affiliates will use such information for the purposes set forth in this Privacy Policy, and OpenX Software Ltd. is responsible for management of shared information.

You may request disclosure, notification of the intended purpose, correction, addition, deletion, and cessation of use or cessation of disclosure to third parties of your personal information held by OpenX Japan, by e-mailing us at privacy@openx.com.