MARZIPAN CCPA Privacy Policy
Effective Date: December 04, 2023
This Privacy Policy explains how SUR IT MARZIPAN UNLOOSEN CUTS LTD (“Marzipan”) receives and processes user’s personal information (“Users PI”). Marzipan receives Users PI that has been provided to it by publishers (“Supply Partners”), and shares the Users PI to advertisers and related parties (“Demand Partners”) in order to provide various services including personalized advertising and related adtech services (“Services”).
What Information & Why

Marzipan has no direct engagement with Supply Partner Users. Marzipan requires its Supply Partners and Demand Partners to provide a privacy notice as required under applicable laws. Supply Partners are responsible for ensuring that Users PI has been collected in accordance with applicable law.
Marzipan’s Supply Partners download a Software Development Kit (“SDK”) on their mobile site(s). The SDK facilitates the transfer of User PI to Marzipan so that Marzipan can provide ad monetization Services to the Supply Partner including the placement and serving of personalized ads to the mobile site(s) for viewing by the User.

Marzipan only receives User PI that Supply Partners have instructed us, with their Users permission, for the business purposes of providing the Services. For example, if a User uses a mobile application where the Supply Partner has embedded Madex’s SDK, then the SDK will provide to Marzipan only the User PI that Supply Partner has enabled Marzipan to receive in order to provide the Services.

Marzipan may receive the following User PI:
  • Information about User’s mobile advertising identifiers, such as User’s Advertising ID (Apple IDFA or Google AAID).
  • Information that User’s device provides, such as device IP address, network connection type and device GPS location.
  • Information about User’s age and gender.

Marzipan processes this User PI solely for the business purposes of providing the Services, which include:
  • Providing personalized ads to Users;
  • Providing support to Supply Partners;
  • Analyzing the performance of the Services;
  • Improving the Services; and
  • Protecting the Services from fraud, misuse and illegal activity.
With Whom?

At the instruction of its Supply Partners, Marzipan shares the Users PI with its Demand Partners for the purpose of providing Services including serving personalized ads to Users. The full list of Marzipan Partners can be found here:

In addition to its Demand Partners, Marzipan shares Users PI with other trusted Service Providers who provide services for the business purposes of hosting services, payment processing, IT services, security services, customer services, and marketing services.
Aggregated Information

Marzipan may use aggregated information (not containing personal information) to analyze trends and improve our Services.
Compliance with Laws

Marzipan may disclose Users PI to a third party if (a) it believes that such disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, or (b) to protect the security or integrity of the Services from harm or illegal activities.
Business Transfers

Marzipan may share or transfer Users PI in connection with, any merger, sale of Marzipan assets, financing, or acquisition of all or a portion of the business to another company.
California Users

Marzipan acts as a Service Provider under the California Consumer Protection Act (“CCPA”). Marzipan follows the Supply Partner(s)’ instructions in processing the Users PI for the business purposes of providing the Services. Marzipan follows the Supply Partner(s)’ instructions to delete any Users PI requested. Marzipan does not sell its Users PI as defined under CCPA. Marzipan upholds Users right of non- discrimination as defined under CCPA.
Nevada Users

Marzipan does not sell Users PI as defined by Section 1.6 of Chapter 603A of the Nevada Revised Statutes.
Retention Policy

Marzipan retains Users PI as long as necessary to provide the Services unless a longer period is required to be permitted for legal or compliance purposes. Do Not Track: Some browsers offer a “do not track” (“DNT”) option. Marzipan does not respond to DNT signals.

Marzipan employs industry standard technological measures that are reasonably designed to help protect information from loss, unauthorized access, disclosure, alteration or destruction. While Marzipan takes reasonable efforts to guard information, no security system is impenetrable.
Policy On Information Collected From Children

This Site and our Services are not directed at children under the age of 18 in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).

Marzipan may need to update this Privacy Policy from time to time to reflect changes to our Services and the laws applicable to our provision of the Services to you. If Marzipan does change this Privacy Policy, it will revise the “Last Updated” date at the top of this Privacy Policy on the Site. Continued use of this Site or the Services after the posting of such notice will be subject to the terms of the then-current Privacy Policy. Contact: If you have any questions regarding this Privacy Policy, please contact Marzipan via email at
Contact Us:

Agias Zonis & Thessalonikis NIKOLAOU PENTADROMOS CENTER, 10th floor, Flat/Office 1001, Block B, 3026, Limassol, Cyprus
Attn: Data Protection Officer