Madex (Mobiledex) LLP Privacy Policy
Effective Date: November 17, 2023
Table of contents
About Us

Madex (Mobiledex) LLP. (“Madex”) operates an ad network platform that allows app developers to serve ads within their apps, and advertisers to promote their products, and services within apps.

We collect information in either of 2 ways:
  1. Directly – through our SDKs integrated by app developers in their apps. SDK, or a Software Development Kit, is a software component that allows us to serve ads in a mobile app, and to collect information directly from such apps.
  2. Indirectly – through other third party mediation platforms with which we engage in order to serve ads in apps, or by receiving information from our advertisers.
Scope:

This privacy policy describes Madex’s privacy practices with respect to information it processes through its ad network. This privacy policy does not govern the use of our website https://madex.world/monetization.  To learn what data we collect when you visit our website, please scroll down to Madex Website Privacy Notice.

Madex serves ads to users all around the world. Accordingly, throughout the document, we try to harmonize our approach and the language of the privacy policy as much as possible. However, sometimes we refer to specific laws that require further disclosures. For example, whenever you see throughout the policy the annotation “The GDPR angle”, it means that the purpose of such section is to satisfy the transparency requirements of the General Data Protection Regulation (the “GDPR”), and therefore it applies only to personal data (as defined by the GDPR) associated with devices who we deem to be located in the European Economic Area, United Kingdom, or Switzerland. If you are a resident of California, Virginia, Colorado or Connecticut, please see the “State Privacy Rights” section of this privacy policy for information related to privacy laws in these states.
Information we collect through our Ad Network Platform (“Ad Network Information”) -

Identifiers: Advertising ID, IP address, a self-created ID unique to a specific app, and IDs unique only to apps of the same developer. The term Advertising ID refers to the Google Advertising ID on Android devices, and ID For Advertising (“IDFA”), on iOS devices . The Advertising ID is a resettable persistent identifier generated by Android or iOS that allows online advertising companies to recognize a device across apps, for advertising purposes. You can find additional information about how to limit our use of the Advertising ID under “How to Control Information”. If you submit a customer support request to us, we will also collect your email address in order to respond to your request.

General technical information about a device: Technical information such as the device’s time zone, the amount of free memory on the device, the name and version of the app to which the ad is served, battery status, operating system name and version, the language of the operating system, time zone, the name of the mobile carrier, internet connection type (e.g. WiFi), etc.

Campaign information: An indication if an ad was viewed, or clicked, or if there was an install of an advertised app. Information about actions performed within an advertiser’s app following such an install, such as in-app purchases, and level in the game (if the advertiser chooses to provide such information). Publishers, at their option, may also share with us information about what level of the game you are on and your in-app purchases.

How we use the information we collect:

We use the information we collect through our ad network platform to provide you with the service and to serve ads on app developers' apps. More specifically, we use that information in the following ways:

  • Ad delivery: we use the information to technically enable the delivery of ads to your device.
  • To serve you offers customized based on your interests inferred from your past activity.
  • To serve you offers based on information such as the publisher app, technical parameters of the device, and interactions with the offerwall.
  • Reporting, billing and attribution: Generating reports for our publishers and bill advertisers and publishers, including for ensuring that if you interacted with our ads, we will receive payment for our service.
  • Internal Operations: For internal operations, such as debugging, support, security, and improving our services.
  • Optimization and frequency capping: For optimizing advertising campaigns, including for limiting the number of times you view a specific campaign across our network, or the number of ads you view in a specific app.
  • Whitelisting/blacklisting: We allow advertisers to upload lists of device IDs to include/exclude in, or from their advertising campaigns.
  • To notify app developers of when you earn rewards through our platform, so they can increase your in-app virtual currency balances by the amount of the reward.
  • To respond to and resolve your customer support requests.
  • Fraud detection and prevention: We use Ad Network Information for detecting and preventing fraud, and for ensuring viewability of our ads.
  • Operating our ad marketplace. We use Ad Network Information to allow the third party advertising companies to bid on ad inventory.
The GDPR Angle:
Our legal basis for processing personal data:
  • When we process personal data for operating our ad network, including for purposes listed above, such as optimization and frequency capping, reporting, attribution, fraud detection and prevention and internal operations, we process data as a data controller and we rely on our legitimate interests, and the legitimate interests of our app developer and advertiser partners.
  • When we process personal data for the operation of our advertising network – an advertising platform (allowing third parties to place bets on advertising inventory) for the purpose of operating our ad marketplace, including the sharing of personal data with third party advertising partners listed here, for the purpose of receiving bids from such third party advertising partners, we process the data as a data controller and rely on your consent.
  • When we process personal data for the purpose of serving you offers based on your interests, we process data as a data controller, and we rely on your consent.
  • When we process personal data for the purpose of serving you offers based on information such as the publisher app, technical parameters of the device, and interactions with the offerwall, we rely on our legitimate interests, and the legitimate interests of our app developer and advertiser partners/
  • When we process personal data for the purpose of excluding/including devices from, or in an ad campaign, we act as a processor on behalf of our app developer or advertiser partner, who also chooses the applicable legal basis for such processing, as the data controller.
  • We may also process personal data for compliance with applicable legal obligations. In that case, we shall act as a data controller and our legal basis is compliance with a legal obligation.
How long do we keep information collected?

We keep information as long as necessary to provide our services, generally speaking. Information used for interest-based ad targeting is rotated out on a 90-day basis. Conversion data and non-production backups of production data are retained for longer due to financial records and disaster recovery requirements.
How we share information

We share information with:

  • App developers and advertisers: To provide you with the service and for the purposes of attribution, whitelisting/blacklisting and reporting, as stated above, and as required to investigate and resolve your customer support requests.
  • Other advertising partners – We share Ad Network Information for the purpose of allowing the advertising companies to bid on ad inventory. The full list of Madex Partners can be found here: https://madex.world/partners-privacy-policies
  • Service providers: for the purpose of receiving services such as fraud detection and prevention, viewability measurement, reporting, and storage.
  • We may also disclose information if we have a good faith belief that disclosure of such information is reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our agreements and policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; (vi) 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; or (vii) when we are undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of our assets.
How to control information

Updated versions of iOS, and Android, enable you to control how apps can collect the Advertising ID. To do that, please follow the below instructions:

  • iOS devices (iOS 14+): go to Settings > Privacy > Tracking > Allow Apps to Request to Track. Please note that if you use more than one device, you need to opt-out separately in each device.
  • Android devices: Please follow the instructions set forth at: https://support.google.com/ads/answer/1660762 (under Mobile devices). Please note that if you use more than one device, you need to opt-out separately in each device.
The GDPR Angle:

Withdraw consent – You have the right to withdraw the consent you provided to us. You can withdraw your consent from within the app you provided to us the consent (this will affect only our processing within this specific app), or by following the instructions above on how to control collection of device data (this will affect our processing of data of all apps on your device).

Data subject rights – Please note that you have the right to request from us access to and rectification or erasure of your personal data we process as controllers, or to restrict or to object to processing of your personal data in accordance with the provisions of the GDPR. To submit a request for exercising your rights, please send an email with your request to the following address: support@madex.world. Please note that we will process your request subject to verification, and authentication of your identity.

Complaint to supervisory authority – You also have the right to file a complaint with the relevant supervisory authority (e.g. of your country or domicile) where Madex has not addressed your concerns.
Children

If you believe your child has provided us with personal information, you may contact us at support@madex.world and we will make reasonable efforts to delete the information from our records.

The GDPR Angle:

We do not collect or otherwise process personal data from individuals in the European Economic Area, the United Kingdom, and Switzerland whom we know to be under the applicable age stated in the different implementations of the GDPR, except to comply with law or to support our legitimate interests or the legitimate interests of our app developers partners as described above.

International transfers

We store information that we collect from a device on servers in the territory of the Russian Federation Accordingly, please note that if you do not live in the Russian Federation, we will transfer your information to and store it in the Russian Federation.

We may transfer the information we collect about you to countries other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws. For example, if we transfer your information from the European Economic Area to a country outside it, such as the United States, we will seek to take additional steps such as entering into EU compliant data transfer agreements with the data importer where necessary.

The California Consumer Privacy Act (hereinafter “CCPA”) applies to processing of personal data in relation to customers who are residents of California. We take measures to collect, use and disclose such data solely for the purpose of providing Services to you, or for other purposes provided for by the CCPA.
State Privacy Rights

California, Virginia, Connecticut and Colorado residents have certain rights under state privacy laws with respect to personal data we collect. If you are a resident of such states, this section of the privacy policy contains disclosures required by law and explains rights that may be available to you.

This section applies only to personal data that is subject to the state laws noted above.

In many cases, we act as a service provider or processor to collect personal data from, or on behalf of, customers who use our services. These customers have their own privacy policies that describe how they use information. To the extent that we are processing personal data subject to state privacy laws on behalf of a customer in our role as a service provider or processor, you should reach out to that customer directly to exercise your rights under state privacy laws.

The remainder of this section provides disclosures for users for cases where we are not acting as a service provider or processor to a customer.

Personal Data We Collect and Disclose: We collect, sell (including sharing for targeted advertising), and disclose for business purposes the following categories of personal data.. We do not knowingly sell, nor do we share or process for targeted advertising purposes, personal data about consumers under the age of 16.
Categories of Sources – As described in the “About Us” section above, we collect personal data from the following categories of sources:
  1. Directly through our SDKs integrated by app developers in their apps.
  2. Other third-party mediation platforms.
  3. Advertising partners.
Our Purposes for Processing Personal Data – We use and disclose the personal data we collect for our commercial and business purposes, as further described above in the “How We Use the Information We Collect” and the “How We Share Information” Sections.

Recipients of Personal Data – Although we do not sell personal data for monetary consideration, we do sell personal data, including sharing for targeted advertising purposes, subject to users’ choices communicated to us by app developers, to the categories of third parties listed below:
  • Advertising/marketing companies;
  • App developers; and
Your Rights Regarding Personal Data – Residents of certain states have rights with respect to the personal data collected by businesses like Madex. You may be able to exercise the following rights regarding your personal data, subject to certain exceptions and limitations: The right to confirm whether we are processing personal data about you.

The right to correct inaccuracies in the personal data we have collected about you.
  • The right to confirm whether we are processing personal data about you.
  • The right to correct inaccuracies in the personal data we have collected about you.
  • The right to know the categories and specific pieces of personal data we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal data, our purposes for collecting or selling your personal data, the categories of your personal data that we have either sold (including shared for targeted advertising purposes) or disclosed for a business purpose, and the categories of third parties with which we have disclosed personal data.
  • The right to request that we delete the personal data we have collected from you or maintain about you.
  • The right to opt out of our sale of your personal data and our processing (including sharing) for targeted advertising purposes. Please note that if you opt out of certain practices, we may be unable to provide you with some services.
  • The right not to receive discriminatory treatment for the exercise of the above privacy rights.
While some states provide residents with rights related to “sensitive” personal data, Madex does not collect this type of personal data.

Exercise your rights – To exercise any of the above rights, please send an email with your request to the following address: support@madex.world.

Depending on your state, if you have submitted a request that you believe we have not fulfilled, you may contact us to appeal our decision by replying to our response to your request, or by contacting us at support@madex.world.

Verification Process and Required Information – Note that we may need to request additional information from you to verify your identity or process your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your email address and state of residence. We will also collect information that identifies your device when you submit a request, in order to help verify your identity.

Authorized Agent – You may designate an authorized agent to make a request on your behalf by verifying your identity and providing the agent with written permission to make the request on your behalf.
Changes to This Privacy Policy:

We may revise this privacy policy from time to time. The most current version of the policy will govern our processing of information and is posted at support@madex.world. If we make a change to this policy we will post the revised privacy policy to this page.
Contact Us:

Madex (Mobiledex) LLP.
email: support@madex.world
Kazakhstan, Almaty city, Turksib district, st. Zavetnaya, 31
Attn: Data Protection Officer
Madex (Mobiledex) Website Privacy Notice
Effective Date: November 17, 2023
We have prepared this Privacy Notice to explain how, why, and when we collect data from you on our website.

Please note that this Privacy Notice only applies to data that we collect when you visit the Madex website at https://madex.world/monetization.

The Site are accessible for individuals around the world. Accordingly, throughout the document, we try to harmonize our approach and the language of the privacy policy as much as possible. However, sometimes we refer to specific laws that require further disclosures. These disclosures cover laws and regulations applicable to the following regions:
  1. Individuals who we deem to be located in the European Economic Area, United Kingdom, or Switzerland – With respect to the collection and processing of their personal data, as defined by the General Data Protection Regulation (“GDPR”), and the UK Data Protection Act.
  2. If you are a resident of California, Virginia, Connecticut, or Colorado – please see “State Privacy Rights” section of this privacy policy for information related to privacy laws in these states.
Your Consent (PLEASE READ CAREFULLY!) BY ACCESSING THE SITE AND/OR USING THE SITE, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY”), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT USE THE SITE.

Information We Collect, and Purposes of Processing

We may collect the following categories of information on our website and use them for the purposes explained below.

1) Information collected automatically from Users who are visiting the Site (“Site Information”):
  • Technical Information – Technical information about your browser and device is automatically collected when you visit the Site. Such information consists of the device’s IP address, device ID, the type and version of browser used to access the Site, operating system, language of the browser and operating system, and type of device.
  • Interaction Information – Information about your interactions with the Site or Dashboard apps (e.g. whether you clicked on a specific link, where you clicked, time on Site, etc.)
2) Information you voluntarily provide us:
  • Registration Information – When you register to our services, you will be asked to provide your email address, password, billing information, details about your apps, and payment details.
  • Communication Information – If you choose to communicate with us via an online form on the Site, email, you may provide us with information such as your name, and your email address, your messenger and any other information you choose to share with us.
What are the Purposes of the Collection of Information?
I. We use the information we collect for the following purposes:
Sharing Information with Third Parties

We may share information with our affiliated companies, and with vendors and service providers for the purposes set forth in this Privacy Policy. We may also disclose information if we have a good faith belief that disclosure of such information is reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our agreements and policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; (vi) 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; or (vii) when we are undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of our assets.

Deletion or Modification of Personal Information
If for any reason you wish to modify or delete your Personal Information please send us an email to support@madex.world, and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws.

Retention of Information
We store information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this privacy policy. In some circumstances we may store information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.

Minors
To use the Site, you must be over the age of eighteen (18). Therefore, Madex does not knowingly collect personal information from individuals under the age of eighteen (18) and does not wish to do so. If you have any reason to believe that a minor has shared Personal Information with us, please contact us an email to support@madex.world.

Third Party Site
While using the Site you may encounter links to third party webSite. Please be advised that such third party webSite are independent Site, and we assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such Site. We encourage you to carefully read the privacy policies and the terms of use or service of such webSite.

Cookies
When you access or use the Site, we may use industry-wide technologies such as “cookies” (or similar technologies), which store certain information on your computer and which will allow us to enable automatic activation of certain features, and make your service experience much more convenient and effortless. It is easy to prohibit certain cookies. You can do so by editing your preferences through the Site’s cookie settings link. In addition, 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 your online experience may be limited.

Information to Individuals Located in the European Economic Area, Switzerland, and the United Kingdom

1. International Transfers – We store information that we collect from a device and the website on servers in the territory of the Russian Federation Accordingly, please note that if you do not live in the Russian Federation, we will transfer your information to and store it in the Russian Federation. We will transfer personal data countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.
We may transfer the information we collect about you to countries other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws. For example, if we transfer your information from the European Economic Area to a country outside it, such as the United States, we will seek to take additional steps such as entering into EU compliant data transfer agreements with the data importer where necessary.
The California Consumer Privacy Act (hereinafter “CCPA”) applies to processing of personal data in relation to customers who are residents of California. We take measures to collect, use and disclose such data solely for the purpose of providing Services to you, or for other purposes provided for by the CCPA.

2. Your Rights – Data subjects have the right to request us to access, rectify or erase personal data that we process, or to restrict or object to its processing in accordance with the provisions of the GDPR. A data subject can submit a request for exercising these rights by sending us an email to support@madex.world. Please note that we will process the request subject to verification of the consumer’s identity.
A data subject that chooses to withdraw consent can do that by the cookie settings available on the Site.

A data subject also has the right to file a complaint with the relevant supervisory authority (e.g. of the consumer’s country or domicile) where we have not addressed the data subject’s concerns.

State Privacy Rights

1. California, Virginia, Connecticut and Colorado residents have certain rights under state privacy laws with respect to personal data we collect. If you are a resident of such states, this section of the privacy policy contains disclosures required by law and explains rights that may be available to you.
2. We collect, sell (including sharing for targeted advertising), and disclose for business purposes the following categories of personal data. We do not knowingly sell, nor do we share or process for targeted advertising purposes, personal data about consumers under the age of 16.
3. Our Purposes for Processing Personal Data – We use and disclose the personal data we collect for our commercial and business purposes, as further described above in the “Information We Collect, and Purposes of Processing” and the “Sharing Information With Third Parties” Sections.

4. Recipients of Personal Data Although we do not sell personal data for monetary consideration, we do sell personal data, including sharing for targeted advertising purposes, subject to the choices you make on the Site, to the categories of third parties listed below:
– Advertising Companies; and
– Analytics Providers.

5. Your Rights Regarding Personal Data – Residents of certain states have rights with respect to the personal data collected by businesses like Madex. You may be able to exercise the following rights regarding your personal data, subject to certain exceptions and limitations:
  • The right to confirm whether we are processing personal data about you.
  • The right to correct inaccuracies in the personal data we have collected about you.
  • The right to know the categories and specific pieces of personal data we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal data, our purposes for collecting or selling your personal data, the categories of your personal data that we have either sold (including shared for targeted advertising purposes) or disclosed for a business purpose, and the categories of third parties with which we have disclosed personal data.
  • The right to request that we delete the personal data we have collected or maintain about the you.
  • The right to opt out of our sale of your personal data and our processing (including sharing) for targeted advertising purposes. Please note that if you opt out of certain practices, we may be unable to provide you with some services.
  • The right not to receive discriminatory treatment for the exercise of the above privacy rights.
While some states provide residents with rights related to “sensitive” personal data, Madex does not collect this type of personal data.

Exercise Your Rights

You can submit a request by sending us an email to support@madex.world.

In order to exercise the right to opt out of our sale or sharing of your personal data, including for targeted advertising purposes, use the cookie settings provided in the Site.

Depending on your state, if you have submitted a request that we have not fulfilled, you may contact us to appeal our decision by sending an email with the subject line “Appeal” to support@madex.world.
You may also designate an authorized agent to make a request on your behalf by verifying your identity and providing the agent with a written permission to make the request on your behalf.

Verification Process and Required Information
Note that we may need to request additional information from you to verify your identity or process your request. You will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your email address and state of residence. We may also ask you to provide us a few of your device identifiers, so that we can verify your identity. Once we verify your identity, we will request additional information necessary to authenticate the request.

Changes to the Privacy Policy
We may revise this privacy policy from time to time. The most current version of the policy will govern our processing of information and is posted at email to support@madex.world. If we make a change to this policy, we will post the revised privacy policy to this page.

Have any Questions?
If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email to support@madex.world and we will make an effort to reply within a reasonable timeframe.

Data Protection Officer
Madex (Mobiledex) LLP.
email: support@madex.world
Kazakhstan, Almaty city, Turksib district, st. Zavetnaya, 31
Attn: Data Protection Officer