Your Trust, Our Priority.

1. Introduction

Welcome to DataTempo, a leading data tech company. We understand that your

data is not just an asset—it's the lifeblood of your business. And we are committed to

safeguarding the privacy of our users and clients. That's why we've invested in state-ofthe-

art security protocols to ensure that your data is handled with the utmost integrity,

confidentiality, and availability. Below is an overview of how we're committed to keeping

your data safe, secure, and accessible only by you.

This Privacy Policy provides comprehensive details about the information we collect,

how we use it, and your rights and choices. This policy applies to all personal

information collected by DataTempo via our website located at https://datatempo.ai


2. Definition of personal information

As per the Privacy Act 1988 (Cth), "personal information" is defined as information or an

opinion about an identified individual or an individual who is reasonably identifiable:

a. Whether the information or opinion is true or not.

b. Whether the information or opinion is recorded in a material form or not.

If the information does not disclose your identity or enable your identity to be

ascertained, it will in most cases not be classified as "personal information" and will not

be subject to this privacy policy.

3. Types of information we collect

The personal information which we collect and hold about you may include:

a. Personal Information: Such as name, address, email address, phone number,

and other identifiers.

b. Usage Data: Information about how you use our services and website.

c. Technical Data: IP address, login data, browser type and version, time zone

setting and location, browser plug-in types and versions, operating system, and

platform.

d. Cookie ID: A unique device ID generated for every new device which interacts

with our advertisements or website tracking.

e. Mobile Advertising ID: Technical ID in Mobile App Environments.

f. Cross-Device IDs: User ID generated by DataTempo using algorithms to

link devices and identifiers belonging to the same user.

g. Partner IDs: Pseudonymous IDs exchanged with partners to enable our

Services.

4. How we collect your information

The personal information which we collect and hold about you may include:

a. Personal Information: Such as name, address, email address, phone number,

and other identifiers.

b. Usage Data: Information about how you use our services and website.

c. Technical Data: IP address, login data, browser type and version, time zone

setting and location, browser plug-in types and versions, operating system, and

platform.

d. Cookie ID: A unique device ID generated for every new device which interacts

with our advertisements or website tracking.

e. Mobile Advertising ID: Technical ID in Mobile App Environments.

f. Cross-Device IDs: User ID generated by DataTempo using algorithms to

link devices and identifiers belonging to the same user.

g. Partner IDs: Pseudonymous IDs exchanged with partners to enable our

services.

h. Detect traffic that is not "real" traffic, and prevent fraudulent activities.


5. Data usage and sharing

We use the information we collect to:

a. Provide, maintain, and improve our services.

b. Respond to your requests, comments, or questions.

c. Send you technical notices, updates, and support messages.

d. Monitor and analyse trends, usage, and activities in connection with our services.

e. Detect, investigate, and prevent fraudulent transactions and other illegal

activities.

f. Analyse and report on advertising performance.

g. Improve online advertising experience and efficiency.

h. Detect traffic that is not "real" traffic, and prevent fraudulent activities.

i. Facilitate the process of buying and selling online advertising.


6. Data protection officer

For support, additional requests, or any privacy-related concerns, you can reach out to

our Data Protection Officer at info@datatempo.ai

7. Access, correction, and complaint procedure

Australian Privacy Principle 12 permits you to obtain access to the personal information

we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct inaccurate personal information subject to certain exceptions. If you would like to obtain such access, please contact us as set out above.

If you have a complaint concerning the manner in which we maintain the privacy of your

personal information, please contact us as set out above. All complaints will be

considered, and we may seek further information from you to clarify your concerns. If

we agree that your complaint is well-founded, we will, in consultation with you, take

appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you

may refer the matter to the Office of the Australian Information Commissioner.


8. Overseas Transfer

Your personal information may be transferred to recipients located in other parts of the

world. This may include one of our partners like LiveRamp or platform partners like

Adform or Microsoft Azure’s data centres. We adhere to all of the required data

protection laws which protect personal information in a way which is at least

substantially similar to the Australian Privacy Principles. In these circumstances, we do

require these overseas recipients to comply with the privacy principles relevant to their

Jurisdiction.


9. Monetisation and Data Sharing

We monetise the data we collect through various channels, as per our data reseller

agreements. While we monetise this data, we prioritise the privacy of individuals. The

data we sell is aggregated and anonymised via LiveRamp, ensuring that individual

identities are not disclosed. However, it's essential to understand that the nature of our

business requires the processing of personal data to provide valuable insights.

10. Data protection and privacy

Given the nature of our business and the vast amounts of data we handle, we have

stringent data protection measures in place. We ensure that all data is stored securely,

and access is restricted to authorised personnel only. Our commitment to data

protection is unwavering, and we continuously update our security protocols to address

emerging threats.

11. Your rights and choices

At DataTempo, we take data privacy and compliance very seriously. We have a

dedicated team of approximately 30-40 professionals, including data specialists,

developers, analysts, and tech support personnel, who are well-equipped to handle data

subject rights requests effectively and efficiently.

Furthermore, we make use of LiveRamp to anonymise data, and create RAMP IDs

before pushing the data through to our DSP/DMP. Our data practices are GDPR, CCPA

and ISO 27001 compliant, and our partnerships with some of the biggest tech

corporations in the industry like Microsoft, LiveRamp and Adform speak for our

responsible practices.

We offer you the right to:

a. Right to Be Informed: We ensure that data subjects are informed about the

processing of their data through transparent privacy policies and

communications.

b. Right of Access: We have the ability to provide data subjects with access to

their personal data upon request. Our systems enable us to retrieve individual

customer profiles promptly.

c. Right to Rectification: We have processes in place to rectify inaccuracies or

incomplete personal data promptly upon receiving a request from a data subject.

d. Right to Erasure: Our team can facilitate the erasure of personal data in

accordance with legal requirements, ensuring compliance with the right to be

forgotten.

e. Right to Restrict Processing: We are capable of restricting the processing of

personal data when requested, ensuring that it is not used for further processing.

f. Right to Data Portability: Data subjects can request the transfer of their

personal data to another organisation, and we have mechanisms in place to

facilitate such transfers securely.

g. Right to Object: We respect data subjects' right to object to the processing of

their personal data for specific purposes.

Moreover, our commitment to compliance means that we can complete the above

actions within a timeframe of 48 hours, as required by data protection regulations.

We understand the importance of data subject rights and remain dedicated to upholding

the highest standards of data privacy and security.

12. Use of client data

Commitment to Purpose-Limited Data Utilization

In our unwavering commitment to the trust and privacy of our clients, DataTempo

strictly adheres to the principle of purpose-limited data utilization. We hereby affirm that:

a. Exclusive Use for Intended Purposes: All client data collected, processed, or

handled by DataTempo is used exclusively for the purposes for which it was

originally intended, as explicitly communicated to and agreed upon by our clients.

This includes, but is not limited to, the provision of our services, improvement of

user experience, and compliance with legal obligations.

b. Prohibition of Secondary Use: Under no circumstances will client data be

utilized for secondary or unrelated purposes without the explicit and informed

consent of the client. This encompasses a prohibition on the sale, transfer, or use

of client data for external marketing, research, or any commercial activities not

directly related to the agreed-upon services.

c. Safeguards and Compliance: We implement rigorous safeguards and

compliance measures to ensure that all team members, processes, and

technologies align with this commitment. Regular audits and reviews are

conducted to verify adherence to this principle.

d. Transparency and Accountability: DataTempo maintains a policy of

transparency with our clients regarding data utilization practices. Any changes to

the purpose of data usage will be communicated promptly and will require explicit

client consent.

e. Client Empowerment: Clients reserve the right to inquire about the specific uses

of their data, request limitations on data utilization, or withdraw consent for

certain uses, in accordance with applicable data protection laws and regulations.

By integrating this clause into our Privacy Policy, we reinforce our dedication to ethical

data practices and the protection of our clients' privacy and trust.

13. Security standards

ISO 27001: Best Practices in Data Security

We have been maintaining strict ISO 27001 security standards since we got officially

certified in 2020. While we are currently renewing the certification, we continue to

adhere to the rigorous standards set by this internationally recognised system for

managing information security. Our compliance ensures that we have robust processes

in place to assess and minimise risks.

Microsoft Azure Cloud: A Secure Foundation

Our platform is hosted on Microsoft's Azure cloud services—a trusted name in cloud

computing. Azure comes with a plethora of built-in security features that help safeguard

your data, such as advanced threat detection, multi-factor authentication, and stringent

access controls.

Key azure features utilised:

a. Azure Databricks: For big data analytics and processing, we rely on Azure

Databricks which offers an enterprise-level security model.

b. Data Residency: All data is stored exclusively in Azure data centers located in

Australia, ensuring that it complies with data sovereignty laws.

Our security measures include:

a. Role-Based Access Control (RBAC): We employ RBAC to ensure that only

authorised individuals have access to specific information within the platform.

b. Regular Audits: We conduct regular security audits to ensure the ongoing

integrity of our system and to make sure we are consistently aligned with industry

best practices.

c. Data Backups: We perform regular backups to ensure data integrity and

availability. In the event of a system failure, we can quickly restore your data.

d. Compliance Updates: Our team is consistently updated on new laws and

regulations affecting data security to make sure we're always in compliance.

GDPR and CCPA: Committed to Global Standards

What is the GDPR?

The general data protection regulation (GDPR) is a new data protection regulation in the

European Economic Area (EEA) replacing data protection directive 95/46/EC (data

protection directive) which was designed to harmonise data compliance requirements

across the EEA and protect all EU citizens' data privacy, effective from May 25, 2018.

Who does the GDPR apply to?

The GDPR applies to all organisations established in the EEA and to organisations,

whether or not established in the EEA, that process the personal data of EEA data

subjects in connection with either the offering of goods or services to EEA data subjects

or the monitoring of behavior that takes place within the EEA.

What does the GDPR require?

The GDPR lays out responsibilities for organisations to ensure the privacy and

protection of personal data, as well as providing certain rights to data subjects.

Some of the key privacy and data protection requirements of the GDPR include:

a. Incorporating organisational and technical mechanisms to protect personal data

in the design of new systems and processes

b. Requiring the consent of subjects for data processing where user consent is the

lawful basis for certain business practices

c. Requiring certain companies to appoint a data protection officer (DPO) to

oversee GDPR compliance

d. Providing data breach notifications

e. Safely handling the transfer of data across borders

How did we prepare for GDPR?

In preparation for GDPR, we closely analysed the requirements of the GDPR and

implemented enhancements to its products, processes, and policies on an on-going

basis. In the lead up to, and the period after GDPR went into effect, we have worked to

support our clients and partners in their own GDPR compliance initiatives.

We are in an a-typical position as we as a company have always had the policy of only

processing pseudonymous data which means that no directly identifiable data is allowed

onto the platform. We use LiveRamp to anonymize data like names, emails, phone

numbers and similar data. However, if opted into our CDP services, we offer you a

unified view of all your first-party customer data exclusive to you. The database is

scanned daily for violation by algorithms as well as manually. Furthermore, several

measures like IP truncation are also enforced automatically and through violation scans.

We have actively enforced policies to avoid sensitive data. We fully support opt-out

frameworks and provide full disclosure of our activities to clients and data subjects.

This means we adhere to stringent data protection requirements and are committed to

respecting the privacy and rights of our users, no matter where they are located.

In some circumstances, the European union general data protection regulation (GDPR)

provides additional protection to individuals located in Europe. However, our website

does not specifically target customers located in the European union, and we do not

monitor the behavior of individuals in the European union. Accordingly, the GDPR does

not apply.

Conclusion

When it comes to securing your data, we at DataTempo believe in a no-compromise

approach. With a foundation built on best practices and the robust Azure

cloud infrastructure, your data is in safe hands. Rest easy, focus on what you do best,

and let us handle the security of your data.

For further questions and consultations, please don't hesitate to reach out to our

security team.

14. Changes to this policy

We may update our Privacy Policy from time to time. We will notify you of any changes

by posting the new Privacy Policy on this page and updating the "Last Updated" date at

the top.

15. Contact us

For any questions, concerns, or clarifications about this Privacy Policy, or if you wish to

exercise any of your rights, please contact our Data Protection Officer at

info@datatempo.ai.