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PRIVACY POLICY

Adorphic Group | Corporate Compliance Document | Effective: July 1, 2026

Through this Privacy Policy (“Privacy Policy”), Adorphic Group—which includes Adorphic Ltd, Adorphic FZ-LLC, and its global subsidiaries (“Adorphic”, “we”, “us”, or “our”)—outlines our practices regarding the collection, use, disclosure, and safeguarding of personal data. Adorphic operates a programmatic Supply-Side Platform (SSP) and ad exchange technical infrastructure. Because we interact with different categories of individuals, we have structured this policy to clearly identify your rights and our obligations based on your relationship with us.

1. DEFINITIONS & INTERPRETATION

To ensure total transparency across our operations, technology stack, and public-facing assets, the following definitions apply throughout this document:

Business Partners: Any digital publisher, supply partner, advertiser, demand-side platform (DSP), agency, or data provider that contracts, registers, or communicates with Adorphic to utilize our ad exchange or monetization technology. Users: End-users who visit or interact with third-party Digital Properties (websites, mobile applications, or connected TV platforms) that utilize Adorphic’s programmatic advertising technology. Visitors: Individuals who directly visit or interact with Adorphic’s own corporate website, portal, marketing pages, or communications at https://www.adorphic.com. Digital Property: An online asset (website, mobile application, web page, or video player) owned or operated by a third party where Adorphic's technology is deployed to serve, optimize, or measure advertising. Data Protection Laws: Refers collectively to the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and any other applicable global privacy legislation. TC String (Transparency & Consent String): A structured data string used to store and transmit user privacy preferences under the IAB Europe Transparency & Consent Framework.

2. CORE COMPLIANCE FRAMEWORKS

Adorphic is committed to a lawful, correct, and transparent approach to data processing. We integrate compliance natively into our real-time bidding architecture.

IAB Framework Compliance: Adorphic actively participates in and complies with the specifications and policies of the Interactive Advertising Bureau (IAB) Self-Regulatory Principles for Online Behavioral Advertising, the IAB Europe OBA Framework, and the IAB Europe Transparency & Consent Framework (TCF v2.2).

Framework Identity: Adorphic operates within the TCF as a registered Vendor. We ingest, respect, and propagate TC Strings downstream to ensure end-user choices regarding tracking and profiling are strictly enforced across our real-time bidding infrastructure.

3. DATA PROCESSING BY CATEGORY

3.1. Business Partners (Publishers, Advertisers, and DSPs)

If you represent an entity conducting business with Adorphic, we collect information necessary to establish, maintain, and execute our contractual relationship.

Data We Collect: Contact Information (Name, corporate email address, telephone number, job title, and physical business address); Account Credentials (encrypted usernames, passwords, and access permissions for the platform portal); Financial & Billing Data (invoicing details, corporate bank accounts, tax identification numbers, and transaction history); Campaign and Technical Specifications (ad tags, endpoint URLs, QPS thresholds, ad creative assets, and delivery metrics).

Purposes of Processing: Fulfilling contractual commitments, managing corporate accounts, processing payments, executing bank reconciliations, handling invoicing, issuing financial settlements, optimizing real-time bidding traffic, running system diagnostics, and maintaining platform stability.

Legal Bases (GDPR/UK GDPR): Performance of a contract; Compliance with legal obligations; Legitimate interests (managing commercial client relationships).

3.2. Visitors (Adorphic Corporate Website)

When you browse our public-facing digital properties, we collect basic technical analytics to maintain site security and respond to inbound inquiries.

Data We Collect: Inbound Correspondence (Name, email address, corporate identity, and message contents submitted via contact forms); Technical Log Data (IP address, browser type/version, device operating system, access timestamps, and referrer URLs); Website Usage & Analytics (clickstream data, pages viewed, time spent per page, and interaction patterns).

Purposes of Processing: Responding directly to business development inquiries or partnership applications; safeguarding our website from cyber-attacks, malicious scripts, and unauthorized access; and analyzing web traffic trends to improve user experience.

Legal Bases (GDPR/UK GDPR): Consent (for marketing or non-essential cookies); Legitimate interests (ensuring network security and executing business development).

3.3. Users (End-Users of Third-Party Digital Properties)

When you visit a website or application that uses Adorphic’s programmatic video and display technology, our ad-serving infrastructure processes pseudonymized data to facilitate real-time bidding (RTB) auctions. We do not collect directly identifying information such as your real name, physical address, or national identity numbers.

Data We Collect: Online Identifiers (Unique Cookie IDs, Mobile Advertising IDs such as Apple’s IDFA or Google’s AAID, and Device IDs); Technical & Network Data (IP address, browser configuration, operating system, device make/model, screen resolution, internet service provider, and language settings); Precise or Coarse Geolocation Data (coarse geographic region country, city, or postal area derived from your IP address to ensure ads are relevant); Engagement & Interaction Data (referrer URLs, pages visited, ad creatives viewed, video player interactions, and click-through metrics); Contextual Data (content category tags of the website or page you are visiting); Privacy Preference Identifiers (the IAB TCF TC String indicating your stored choices).

Purposes of Processing: Real-Time Bidding & Ad Delivery; Frequency Capping; Audience Profiling & Personalization; Data Enrichment with authorized partners; Fraud Detection & Traffic Quality optimization.

Legal Bases (GDPR/UK GDPR): Consent (where required by local law for cookies and profile tracking, communicated via the IAB TCF); Legitimate interests (for fraud prevention, measurement, and core technical ad delivery).

4. DATA RETENTION POLICY

We retain personal data only for as long as necessary to fulfill the specific purposes outlined in this policy:

CategoryRetention PeriodJustification
Business Partner DataDuration of active contract + 6–7 yearsStatutory corporate tax and accounting regulations.
Visitor Data30 – 90 DaysSecurity logs analysis, server optimization, and threat mitigation.
User Pseudonymized DataMax 13 MonthsStandard cookie expiry and behavioral ad profile sunsetting.

5. DATA SHARING AND INTERNATIONAL TRANSFERS

To operate an international programmatic ad exchange, Adorphic shares information with trusted downstream recipients:

Programmatic Market Participants: Bid request details (excluding raw IP addresses where restricted) are shared with Demand-Side Platforms (DSPs), ad networks, and advertisers to enable automated auctions.

Service Providers: We utilize third-party cloud hosting providers, fraud detection vendors, and financial accounting tools operating under strict Data Processing Agreements (DPAs).

International Cross-Border Transfers: Personal data collected within the UK or European Economic Area (EEA) may be transferred to infrastructure located in third countries (such as the United States or the UAE). When making these transfers, we utilize standard contractual clauses (SCCs) or UK International Data Transfer Agreements (IDTAs).

6. YOUR PRIVACY RIGHTS

Depending on your geographic location, you possess distinct legal rights regarding your personal data:

UK and European Citizens (GDPR / UK GDPR): You have the right to request Access, Rectification, Erasure ("Right to be Forgotten"), Restriction or Objection to processing profiles, and Data Portability.

California and US State Residents (CCPA/CPRA): You possess the Right to Know what categories of personal information we collect, sell, or share; the Right to Delete; and the Right to Opt-Out of the sale or sharing of personal info for cross-context behavioral advertising. Adorphic respects Global Privacy Control (GPC) signals transmitted by your browser.

7. CONTACT & DATA PROTECTION OFFICER (DPO)

For any inquiries regarding this policy, to exercise your legal rights, or to submit a complaint regarding our data handling, please contact our privacy compliance team directly:

Email Contact: privacy@adorphic.com Compliance SLA: All verified privacy requests are reviewed and responded to within one calendar month of receipt.

If you are unsatisfied with our response, you retain the right to lodge a complaint with your local supervisory body (such as the Information Commissioner’s Office (ICO) in the UK).

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Adorphic measures the intrinsic quality of media against the recognition it receives, and amplifies what the market has overlooked.

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