Tiburtina SA (“Lemmonet”, “we”, “us”, “our”) provides digital advertising services. This Privacy Statement is provided to help you understand how Lemmonet processes personal data on behalf of customers who use our services. It does not state the use practices or policies of our clients, of apps on which ads are shown, or of other parties. Lemmonet and our customers care about how personal data is collected, used, and shared. We are a “data sub-processor” that collects and analyzes personal data at the specific request of our customers (data controllers), through third party Mobile Measuring Platforms that act as “data processors”. Lemmonet also collaborates with Programmatic Ad Exchanges that act as “data controllers”. In this scenario, we are “data processors” (and “data co-controllers” in some specific cases). This means we collect and securely forward data to be used for attribution to third party Mobile Measuring Platforms. As set forth in Lemmonet’s Terms of Service, Lemmonet collaborates with approved social network platforms (ie, Facebook, Twitter, Instagram, Tik Tok, Snapchat, YouTube and Twitch). In this respect, Lemmonet is in full compliance and does not infringe any of the terms of service and privacy policies of such approved social network platforms. Upated versions to the terms of service and privacy policies of the approved social networks can be found in the following URL links:

https://privacycenter.instagram.com/policy/

https://support.google.com/youtube/answer/7671399?hl=en&p=privacy_guidelines

https://www.tiktok.com/legal/page/row/privacy-policy/en

Our Business

Lemmonet’s technology powers advertisements that can appear on web sites and applications on mobile phones or other devices connected to the mobile internet. You may interact directly with our servers (for example, when you click on an ad) or indirectly via the mobile web site or application that displays the ads.

Personal Data

Personal data refers to any information about personal or factual circumstances of an identified or identifiable person. This includes information and details such as your name, home address or other postal address, telephone number and also your e-mail address. In the context of Lemmonet, personal data mostly refers to a smartphone device ID such as Google Advertising ID for Android phones or IDFA for iPhones, and IP address.

Legal basis

Your data is handled according to the following legal provisions:

• with regard to data communicated in forms, etc. with your consent, Art. 6(1) (a) GDPR;
• with regard to services you use for the performance of a contract , Art. 6(1)(b) GDPR;
• otherwise, with particular regard to statistical data and online identifiers based on legitimate interests, Art 6(1)(f) GDPR (see below).

Legitimate interests

When handling your data, we pursue the following legitimate interests:

• improving our service;
• protecting against misuse;
• statistics;
• protection against ad fraud.

Data sources

Unless otherwise specified, we receive the data through third parties, that is collected through devices used by app users.

Data transfer to third countries

In order to process and store the data we collect, this Data is sometimes transferred to countries outside the European Union. This is done on the basis of contractual regulations stipulated by law that ensure appropriate protection of your data and that are available for you to view upon request.

Retention period

We retain app user data,

• if app users have consented to this, until such time they withdraw this consent,
• if we need the data to undertake an agreement, until such time as the contractual relationship with the app user ceases or legal retention periods expire,
• if we use the data on the basis of a legitimate interest, until such time as the app user’s overriding interest obliges us to delete or anonymise them.

Purposes of use

Personal data will only be collected and processed by Lemmonet to the extent and for the purpose 1) for which it was provided by the Data Controller or, 2) in the cases where we are acting as “Data Co-controller”, declared in written contracts with our partners, with explicit consent from the Data Subject.

We use and store your personal data as part of our services for the following purposes, only if you have provided us with your express consent:

• We use this information in order to help deliver more interesting and relevant ads to app users, and provide our customers and partners with reports containing aggregated data (for instance: the number of clicks on those ads, and so on). These reports are used to analyze trends, and to perform fraud detection.
• We use your personal information only in aggregate and only within the company’s systems and forward it only to those companies that are involved in performing according to the contracts concluded with you or otherwise involved in providing the relevant service. Otherwise, your personal information will not be forwarded to third parties, unless you have given your express consent for this or unless we are obliged to disclose it, for example, at the direction of a court or administrative authority.
• We only forward the following personal data to third parties: Device identifier, IP address, User Agent, Location.

Data protection

We have taken extensive technical and organisational measures to secure your data against potential risks, such as unauthorised login or access, unauthorised perusal, amendment or distribution, as well as against loss, deletion or misuse.

In order to protect your personal data against unauthorised access by third parties when being transmitted, we secure data transmissions, if necessary, using SSL encryption.

This is a standard encryption procedure for online services, particularly for the Internet.

Cookies

Cookies are small files that your browser stores on your PC in a directory designated specifically for this purpose. These cookies can be used e.g. to find out whether you have already visited a website. Most browsers accept cookies automatically.

Nevertheless, you can change the settings in your browser, so that no cookies can be stored or so that your explicit agreement is required before any cookies are stored. You can also delete previously set cookies at any time. Please note that disabling cookies may result in your use of our website being restricted.

We use cookies only for the following purposes:

• Track conversions and advertising campaigns performance. The cookies are set upon user click on the banners and not before.
• Authentication and user tracking in "connect.lemmonet.com" and “contentcreators.lemmonet.com”.

Opt-out

If you wish to block these cookies, you will need to change the relevant settings on your mobile device. Some, but not all, mobile platforms allow you to manage settings specifically for the Lemmonet.com domain; on others you can only control cookies at a global level. Details on how to do this vary based on your mobile device operating system and browser, but common cases can be addressed as follows:

iOS

• From the home screen of your device, select the “Settings” icon
• Select ‘Safari’ from the list
• To adjust the cookie settings, tap ‘Accept Cookies’
• Choose either “Never”, “From visited”, or “Always”

Android

• Open the browser app
• Push the ‘Menu’ button
• From the options that are shown to be running, select the ‘More’ option
• Select the ‘Settings’ function from the list of browser functions
• Scroll down to the ‘Accept cookies’ option. If the box is checked, uncheck it to disable cookies; if the box is unchecked, select it in order to enable cookies.

Web analysis

Like almost all website operators, we use analytical tools in the form of tracking software to ascertain the number of users using our website and how frequently they visit.

To enable us to optimise our website and our service, we use Google Analytics, which is a web analysis service provided by Google Inc. (“Google”). Google Analytics uses what are known as “cookies”: these are text files stored on your computer and used to analyse your website usage. The information generated by the cookie about your use of this website (including your IP address) will be sent to a Google server in the USA and stored there. However, if IP anonymisation is enabled on this website, within member states of the European Union, or in other states that are party to the agreement on the European Economic Area Google first abbreviates your IP address.

The full IP address will only be transmitted in exceptional circumstances to one of Google's servers in the USA, where it will then be abbreviated. Google will use this information on behalf of our website operator to analyse your use of the website in order to compile reports about website activities for the website operator and to perform other services connected with the use of the website and of the Internet. The IP address transmitted by your browser as part of Google Analytics will not be merged or combined with other data by Google. You can prevent cookies from being stored by applying the appropriate settings in your browser software; please note, however, that in this case you may not be able to use all of the functions of this website to their full extent.

You may also prevent Google from collecting data generated by the cookie referring to your website usage (including your IP address), and from processing these data by downloading and installing the browser plug-in available from the following link https://tools.google.com/dlpage/gaoptout?hl=en.

As an alternative to the browser add-on or within browsers on mobile devices, please click on this link to prevent Google Analytics from collecting data in this website in future (the opt-out only works in this browser, and only for this domain). This stores an opt-out cookie on your device. If you delete your cookies in this browser, you need to click on this link again. Further information is available at https://tools.google.com/dlpage/gaoptout?hl=en or at www.google.com/intl/en/analytics/privacyoverview.html (general information on Google Analytics and data protection).

Third-party services

We use third-party services for various functions on our website.

Rights of the data subject

Right to access, rectification, right to object, to complaint, erasure and blockage.

• You have the right to request information about whether and which personal data is processed by our company. You also have the right to demand that your personal data is rectified or amended.
• Under certain circumstances, you have the right to request that your personal data should be deleted.
• Under certain circumstances, you have the right to demand that the processing of your personal data should be restricted.
• You can withdraw your consent to the processing and use of your data completely or partially at any time with future application.
• You have the right to obtain your personal data in a common, structured and mechanically readable format.
• If you have any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal data, you can also contact our data protection officer in detail.
• You also have the right to complain to the responsible supervisory authority if you believe that the processing of your personal data is in violation of the legislation.

Requirement or obligation to provide data

Unless expressly stated, when data is collected, the provision of such data is neither required nor obligatory.

Changes to Privacy Policy

Lemmonet is committed to continually examining and reviewing its privacy practices, and may make changes to its Privacy Policy. In the event that material changes are made, the Privacy Policy on this website will be changed.

Questions and Concerns

If you have any questions or concerns about our privacy practices, you may contact us:

• Tiburtina SA
• Cesar Cortinas 2037, Montevideo, Uruguay CP 11500
• Email: privacypolicy@lemmonet.com