Privacy Policy

Spotible is committed to protecting individual privacy and operating in compliance with applicable data protection and privacy laws within the United States and globally. Spotible’s digital engagement technology is designed to function without collecting personal data by default. Spotible does not collect, sell, or share personally identifiable information (“PII”) unless a user knowingly and explicitly provides consent in connection with a specific advertising campaign or promotion.

Spotible does not require users to register, create accounts, or submit personal information to view or interact with Spotible-powered advertisements. Spotible does not collect names, email addresses, phone numbers, precise geolocation data, biometric data, or other sensitive personal information unless explicitly and voluntarily submitted by a user.

To support advertising functionality such as frequency capping, performance measurement, and fraud prevention, Spotible may utilize Local Storage Objects (LSOs), cookies, or similar technologies. These technologies:

• Assign a pseudonymous or device-level identifier
• Do not directly identify an individual
• Are used solely for operational and measurement purposes
• Can be managed or removed through standard browser or device settings

These identifiers do not intrude upon user anonymity and are not combined with personal data unless explicit user consent is provided.

Spotible collects and may share aggregated, de-identified, or anonymized information, including:

• Advertisement interaction metrics (e.g., impressions, engagement, completion)
• Device or browser type
• Time, date, and general placement of advertisements
• Non-identifiable performance and reporting analytics

This information cannot reasonably be used to identify an individual and is shared only for legitimate business purposes such as campaign analytics, benchmarking, and optimization.

In limited cases, a user may voluntarily submit personal information (e.g., ZIP code, email address) as part of an advertiser-sponsored campaign or promotion. In such cases:

• The personal data is collected solely at the user’s direction
• Spotible acts as a Processor or Service Provider
• Advertiser-sponsored campaign information is transmitted directly to the advertiser, publisher, or their authorized service provider

The advertiser’s or publisher’s privacy policy governs their handling of user-submitted information, and Spotible is not responsible for third-party privacy practices.

Spotible uses collected information strictly for:

• Delivering and measuring advertising campaigns
• Ad frequency management
• Performance analytics and reporting
• Ensuring compatibility with device capabilities
• Preventing fraud and abuse

Spotible does not engage in automated personal data collection, decision-making or profiling that produces legal or similarly significant effects on individuals.

Where applicable, Spotible relies on one or more of the following lawful bases:

• Legitimate interests (e.g., ad delivery, measurement, fraud prevention)
• User consent (where personal data is voluntarily provided)
• Compliance with legal obligations

Spotible implements data minimization, purpose limitation, and privacy-by-design principles across its systems.

Spotible’s data practices are designed to comply with applicable privacy and advertising regulations, including but not limited to:

• EU General Data Protection Regulation (GDPR)
• UK GDPR
• California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• Virginia Consumer Data Protection Act (VCDPA)
• Colorado Privacy Act (CPA)
• Connecticut Data Privacy Act (CTDPA)
• Utah Consumer Privacy Act (UCPA)
• Brazil’s Lei Geral de Proteção de Dados (LGPD)
• Children’s Online Privacy Protection Act (COPPA)
• Digital Advertising Alliance (DAA) Self-Regulatory Principles
• Network Advertising Initiative (NAI) Codes of Conduct

Spotible does not knowingly collect data from children under 13 and does not serve behaviorally targeted advertising to children.

Depending on jurisdiction, individuals may have rights including:

• Access to personal data
• Correction of inaccurate data
• Deletion of personal data
• Restriction or objection to processing
• Data portability
• Opt-out of certain data uses

Due to Spotible not automatically collecting personal data, many of these rights are not applicable; however, requests may be submitted using the contact information below.

Spotible may process information in the United States or other jurisdictions where Spotible, its affiliates, or service providers operate. Where personal data is transferred internationally, Spotible implements appropriate safeguards consistent with applicable legal requirements.

Spotible employs reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, or destruction. While Spotible uses industry-standard security measures such as encryption and secure transmission protocols, no system can be guaranteed to be 100% secure.

Spotible may update this Privacy Policy from time to time to reflect legal, technical, or business changes. The “Last Updated” date will indicate when revisions were made. Continued use of Spotible services after an update constitutes acceptance of the revised policy.

For privacy-related inquiries or requests, please contact Spotible via email: compliance@spotible.com or phone: +1 (877) 709-7768. Spotible will respond in accordance with applicable data protection laws.