Welcome to Reticle.
Reticle is an ADX and programmatic advertising platform that provides advertising exchange, campaign delivery, traffic monetization, attribution, analytics, and marketing optimization solutions supported by AI-enabled performance algorithms, big data analysis, and deep learning technologies. Reticle helps advertisers, publishers, and other business clients acquire users, improve campaign performance, optimize advertising inventory, and increase advertising revenue through platform features and related services (the "Services").
You and Reticle have entered into an agreement for the provision of the Services, as amended from time to time (the "Agreement"). This Privacy Policy explains how Reticle and its applicable affiliates ("we," "us," or "our") collect, use, disclose, transfer, and otherwise process personal information in connection with the Services. Where you accept this Privacy Policy on behalf of a client, customer, or other organization, you represent and warrant that you have the authority to bind that party, that you have read and understood this Privacy Policy, and that you agree to it on that party's behalf. If you do not have such authority, you must not accept this Privacy Policy or use the Services on that party's behalf.
01What Information Is Collected and How Do We Collect Your Information?
We may collect, transmit, store, and otherwise process information about you and end users in connection with the use of the Services, including information submitted to or transmitted through the Services. We use this information to provide and operate the Services, fulfill requests, improve service quality, conduct research and analysis, personalize experiences, track usage, provide feedback to third-party businesses listed on or integrated with the Services, display relevant advertising, market the Services, provide customer support, send service-related messages, back up our systems, support disaster recovery, enhance security, prevent fraud, and comply with legal obligations. Even where we do not retain certain information, it may need to be transmitted to our servers and stored for the limited period necessary to process it.
The personal information we collect depends on the context of your interaction with our Site and the Services. The categories of data we may process include the following:
Customer Account Data
- Scope of data
- Name, email address, company name, payment details, billing address, and related transaction information when you sign up, contact us, or complete a transaction.
- Purpose
- To create and administer accounts, provide the Services, process payments, verify orders, and communicate with you.
- Legal basis
- Performance of a contract; compliance with legal obligations where applicable. Under U.S. privacy laws, this is collected for disclosed business purposes.
End-User Identifiers and Technical Data
- Scope of data
- Advertising ID (IDFA/GAID), client ID (cuid), Android ID, Vendor ID (IDFV), IP address, device model, operating system version, system language, SDK version, and platform integration version.
- Purpose
- To enable attribution analysis, cross-device matching, troubleshooting, fraud prevention, and technical service delivery.
- Legal basis
- Legitimate interests as processor on behalf of clients/controllers, provided that the client has secured valid consent where tracking, profiling, or device access requires consent.
User Activity and Interaction Data
- Scope of data
- Ad clicks, impressions, bid requests, bid responses, win/loss signals, conversion events such as purchases or sign-ups, event timestamps, source platforms, supply sources, demand partners, and interactions with platforms such as Meta, Google Ads, TikTok, Snapchat, or similar advertising channels.
- Purpose
- To conduct marketing attribution and analytics, measure campaign effectiveness, optimize delivery, and generate performance reports.
- Legal basis
- Legitimate interests as processor on behalf of clients/controllers. The client is responsible for obtaining consent through a lawful and appropriate mechanism where required.
Security and Fraud Prevention Data
- Scope of data
- Debugger or emulator detection results, jailbreak or root status, validation-service data, and related integrity signals.
- Purpose
- To maintain system security and integrity, prevent fraud, detect abuse, and protect the Services.
- Legal basis
- Legitimate interests in operating, securing, and protecting the Services; compliance with legal obligations where applicable.
Inferred Data
- Scope of data
- Inferences derived from collected data, including behavioral patterns, purchase intent, interest segments, audience characteristics, and propensity scores.
- Purpose
- To optimize advertising models using AI technology and to provide advanced analytics, audience insights, and campaign optimization for clients.
- Legal basis
- Legitimate interests as processor, provided that the processing does not result in automated decision-making that produces legal or similarly significant effects on the data subject.
Location and Geolocation Data
- Scope of data
- Timezone, country code, and broad location signals derived from SIM information or IP address.
- Purpose
- To analyze advertising performance by geographic region and apply geographic-specific advertising controls.
- Legal basis
- Legitimate interests as processor for broad location data. Precise location data, if ever processed, requires an applicable lawful basis and consent where required.
We may also collect information through the following methods and sources:
- Information provided directly to us, including names, gender, birth dates, personal identification information where lawfully provided, addresses, telephone numbers, email addresses, occupations, education, work experience, and related information.
- Passive information generated when users access or use the Services, including browser information, browser type, IP host address, mobile device type, IDFA, GAID, advertising interaction data, device identifiers, domain name, visited pages, and session duration, collected through technologies such as IP addresses, cookies, internet tags, and navigation data collection tools.
- Cookies and similar technologies that collect information about the device and network used to access the relevant domain, together with the date and time of access. This information is used for internal operational purposes, such as optimizing the Services. Where required by law, cookies or similar technologies will be used only after obtaining appropriate consent.
- Information received from third-party partners, including companies that provide services to us, advertising platforms, supply-side platforms, demand-side platforms, publishers, measurement providers, analytics providers, and other business partners.
We do not intentionally collect sensitive personal information, such as health information, political opinions, religious beliefs, or similar special-category data, for the purpose of creating advertising audiences. If such information is inadvertently received, we will process it only as necessary to provide the Services, comply with law, or delete or de-identify it as appropriate.
02How We Handle Customer Information
The Services are designed to help advertisers, publishers, and other business clients automate, measure, monetize, and optimize advertising campaigns and advertising inventory. In many cases, we process personal information of your customers, users, or other end users on your behalf and in accordance with your documented instructions. In that context, you determine the purposes and means of processing, and we provide the Services as your service provider or processor.
03Information We Process from Clients, End Users and Advertising Platforms
To provide the Services, we may process information from clients, end users, advertising inventory sources, demand partners, and integrated third-party platforms, including:
- Customer and End-User Information: names, email addresses, telephone numbers, dates of birth, gender, addresses, postcodes, and similar contact or profile information where lawfully provided by clients or partners. If an end user interacts with a social media or advertising platform, such as Facebook, Twitter/X, Google, TikTok, Snapchat, or another platform, we may receive account or interaction information permitted by that platform and applicable law.
- Browsing, Advertising and Behavioral Data: ad impressions, ad clicks, bid requests, bid responses, publisher or inventory information, page or placement information, conversion events, purchase or sign-up events, search or browsing signals, and interactions with advertising platforms.
- Device and Technical Data: IP address, device identifiers, Google Advertising ID, Apple IDFA, device type, cookie ID, SDK identifiers, and device fingerprint or similar technical signals.
- Business and Campaign Data: business, campaign, inventory, placement, pricing, deal, order, creative, and performance information obtained from clients, advertising platforms, publishers, exchanges, and other partners.
04How We Collect Information
Information may be collected automatically through technical tools, SDKs, pixels, cookies, devices, or similar technologies, or may be received from third parties across different technologies over time. We may combine information collected from different sources with information derived through analytical techniques where necessary to provide, secure, measure, and improve the Services.
05How We Use Information
We process information to deliver and improve the Services. Our uses include:
- Personalized Advertising: where applicable and legally permitted, using customer data to display relevant and personalized advertisements on websites, digital properties, and advertising platforms, including retargeting.
- Campaign Optimization: helping clients create, optimize, and measure advertising campaigns, including by building or improving audience models, lookalike audiences, campaign delivery, and conversion analysis.
- Performance Measurement and Analytics: generating reports regarding advertising performance, campaign effectiveness, attribution, conversions, and customer behavior.
- Service Maintenance, Security and Fraud Prevention: maintaining the Services, troubleshooting errors, improving performance, preventing fraud, detecting abuse, and protecting system integrity.
- Compliance and Administration: complying with legal obligations, enforcing agreements, managing business records, and responding to lawful requests.
06How We Share Information
We may share information processed through the Services in the following circumstances:
- Advertising Ecosystem Partners: we may share data with advertising networks, exchanges, supply-side platforms, demand-side platforms, publishers, advertisers, measurement partners, verification providers, and other advertising partners to provide ad exchange, advertising delivery, attribution, analytics, monetization, and campaign optimization services. These partners may also process data under their own privacy policies when they act independently.
- Service Providers: we may disclose data to service providers that support technical infrastructure, hosting, security, data analysis, customer support, billing, and similar operations. Such providers are required to protect the data and use it only for the contracted purposes.
- Legal Requirements: we may disclose information to governmental authorities, regulators, courts, or other third parties when required by law, for tax or accounting purposes, in response to lawful requests, or in connection with investigations, claims, disputes, or litigation.
- Business Transfers: we may disclose or transfer personal information as part of a merger, acquisition, joint venture, financing, sale of assets, insolvency, bankruptcy, receivership, or similar corporate transaction.
- Affiliates: we may share necessary personal information with our affiliates for purposes consistent with this Privacy Policy and subject to appropriate safeguards.
07International Data Transfers
Personal information processed through the Services may be transferred to, stored in, and processed in countries outside the country where the relevant user resides, including Singapore and other jurisdictions where our servers, service providers, or processing facilities are located. These jurisdictions may have data protection laws that differ from those in the user's country of residence.
Where required by applicable law, we implement appropriate safeguards for cross-border transfers, which may include the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum or equivalent mechanisms, data protection frameworks, and contractual, technical, and organizational safeguards designed to protect personal information wherever it is processed.
08Your Responsibilities as Client, Publisher or Advertiser
As the client, controller, publisher, advertiser, or business using the Services, you are responsible for your customer and end-user information. You must ensure that:
- Your website, digital property, advertising inventory, or other relevant service provides a clear and comprehensive privacy notice explaining how you collect and use personal information, including your use of third-party services such as Reticle.
- You have obtained all consents and provided all notices required for advertising, tracking, profiling, cookies, device identifiers, cross-context behavioral advertising, and similar processing activities.
- Where the IAB Europe Transparency and Consent Framework (TCF) or another consent-management framework applies, your implementation accurately discloses the relevant purposes, features, vendors, and legal bases, and transmits valid consent or preference signals to us and relevant partners.
- You are responsible for responding to access, correction, deletion, portability, opt-out, and other privacy requests from your customers. We will reasonably cooperate with you to fulfill such requests where required by law or contract.
- You will not transmit sensitive personal information, children's data, or other restricted data to the Services unless expressly permitted under the Agreement and applicable law.
09Privacy Choices
End users may opt out of certain interest-based advertising by adjusting device settings or visiting industry consumer choice tools, including the Network Advertising Initiative at https://optout.networkadvertising.org/ and the Digital Advertising Alliance at https://optout.aboutads.info/. Where required by law, clients and clients must provide appropriate consent choices, opt-out links, and preference-management tools, including "Do Not Sell or Share My Personal Information" mechanisms where applicable.
10Children's Privacy
We do not knowingly collect personal information from, or serve advertisements to, children under the age of 16 or the minimum age required by applicable law. If you believe that we have served an advertisement to a child, processed personal information from or about a child, or received data from a digital property directed to children in violation of this Privacy Policy, please contact us at support@reticle.info.
11Data Security and Retention
We maintain reasonable technical, organizational, and administrative measures designed to protect personal information against unauthorized access, use, disclosure, alteration, and loss. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.
We retain personal information for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, enforce agreements, support security and fraud prevention, or satisfy the purposes described in this Privacy Policy, unless deletion is requested and no legal or contractual basis requires continued retention. When personal information is no longer needed, we will delete, aggregate, or de-identify it in accordance with applicable requirements.
12Privacy Policy Updates
We may update this Privacy Policy from time to time. If we make material changes, we will provide notice by posting the updated policy on the platform notice page or through another appropriate channel. Continued use of the Services after an updated Privacy Policy becomes effective means that you acknowledge the updated terms, subject to applicable law.
13Contact Us
If you have questions about this Privacy Policy or our data practices, please contact us at:
- Email: support@reticle.info
- Website: https://reticle.info
14Specific Provisions for U.S. and EU/UK/Swiss Users
U.S. Residents
If your customers are residents of U.S. states with comprehensive privacy laws, including California, Virginia, Colorado, Connecticut, Utah, and other states, they may have specific rights with respect to their personal information, subject to applicable exceptions.
- Right to Know and Access: the right to request information about the categories of personal information collected, the sources of collection, the business or commercial purposes for collection, use, sale, or sharing, and the categories of third parties to whom personal information is disclosed.
- Right to Delete: the right to request deletion of personal information, subject to legal exceptions.
- Right to Correct: the right to request correction of inaccurate personal information.
- Right to Opt Out of Sale or Sharing: the right to opt out of the sale or sharing of personal information for cross-context behavioral advertising. Clients, publishers, and advertisers are responsible for providing required opt-out mechanisms on their properties.
- Right to Limit Use and Disclosure of Sensitive Personal Information: the right to limit certain uses or disclosures of sensitive personal information. As stated above, we do not intentionally process sensitive personal information for advertising audience creation.
- Non-Discrimination: the right not to receive discriminatory treatment for exercising applicable privacy rights.
EU, UK and Swiss Individuals
If customers or end users are located in the European Union, the United Kingdom, or Switzerland, the GDPR, UK GDPR, Swiss data protection law, and related rules may apply.
- Controller and Processor Roles: Clients, publishers, and advertisers generally act as controllers for their customers' or end users' personal data. We generally act as a processor or service provider when processing data on their behalf and in accordance with documented instructions.
- Legal Basis: Clients are responsible for identifying and documenting the lawful basis for processing, including obtaining valid consent where required for cookies, tracking technologies, advertising identifiers, profiling, or personalized advertising. We may rely on legitimate interests for limited processing necessary to operate, secure, and improve the Services where legally permitted.
- Data Subject Rights: Individuals may have rights to access, rectify, erase, restrict processing, object to processing, and receive data portability, subject to applicable conditions and exceptions.
- Automated Decision-Making: We do not intend to make automated decisions that produce legal or similarly significant effects on individuals without a lawful basis and appropriate safeguards.
- Data Retention and Transfers: We retain data only for as long as necessary for the purposes described in this Privacy Policy and use appropriate safeguards for international transfers where required.