Effective Date: 1 September 2026
Last Updated: 1 September 2026
By accessing or using Edge (the “Platform”), you acknowledge that you have read and understood this Privacy Policy (“Policy”) and agree to its terms. Cubera Adexchange, Inc. (“Cubera”, “we”, “us” or “our”) operates the Platform and its underlying technology and is committed to protecting Personal Data processed through our website, products, services and Edge platform.
Edge is a proprietary demand-side platform that enables advertisers, agencies and other customers to purchase, manage, optimise and measure digital advertising inventory across websites, mobile applications, connected television/OTT environments and other digital channels (collectively, the “Services”). This Policy explains the Personal Data we collect, how we use and disclose it, and the choices and rights available under applicable privacy and data protection laws, including applicable United States federal and state laws and Indian laws and regulations (“Applicable Laws”).
In providing the Services, Cubera may process Personal Data on behalf of customers. In those cases Cubera generally acts as a service provider, processor or similar role and the applicable customer agreement governs processing. Where Cubera independently determines processing purposes and means, including for its website, account administration, security or certain analytics activities, it may act as a controller, business or similar role under Applicable Laws.
“Campaign” means a digital advertising campaign created, managed or executed through the Services. “Data Processor” means a person who processes Personal Data on behalf of a Data Fiduciary. “Data Principal” means the individual to whom Personal Data relates, including a Data Subject or analogous term under applicable privacy laws.
“Demand Side Platform” or “DSP” means Edge, Cubera’s demand-side advertising platform and related technology. “Grievance Officer” means the officer designated by Cubera to handle queries, process rights requests and resolve grievances regarding Personal Data. “Personal Data” means information that identifies, relates to, describes, or could reasonably be linked to an identified or identifiable individual, or otherwise constitutes personal data, personal information or a similar term under Applicable Laws.
“Third-Party Platforms” means third-party websites, applications, advertising exchanges, SSPs, publishers, data providers, measurement and attribution providers, technology providers and other services or platforms that interact with or support the Services.
This Policy applies to Personal Data collected or processed through our website and web properties, Edge and related technology, customer accounts, Campaign management and reporting tools, APIs, SDKs, tags, pixels, Cookies and similar technologies, and sales, support and other communications. It does not apply to Personal Data collected or processed independently by customers or other third parties. When you interact with an advertisement, website, application or other customer or partner service, that party’s privacy policy may also apply.
Depending on how the Platform and Services are used, we may collect information provided directly, information generated through accounts and Campaigns, information received from third parties in the digital advertising ecosystem, and technical information collected automatically.
When you create or manage an account, we may collect your name, business email, telephone number, job title, company and business details, login credentials, billing and payment information, account preferences, and information provided through forms, customer support, sales or other communications. We may also collect account and user IDs, Campaign settings, budgets, objectives, Advertising Materials, Targeting Parameters, audience segments, bidding and delivery settings, performance and reporting data, billing records, notifications and administrative activity.
In connection with the DSP, we may receive or process IP address, cookie and advertising identifiers, device and browser information, operating system, approximate location, publisher or application information, advertising inventory and contextual information, pseudonymous identifiers, audience and Campaign identifiers, and impression, interaction, conversion and measurement data from advertisers, agencies, publishers, SSPs, ad exchanges, data providers and other Third-Party Platforms.
We automatically collect technical and usage information, including IP address, device and browser information, login and authentication details, timestamps, pages or features accessed, referring URL, error and diagnostic information, and information about Service use. We may use Cookies, pixels, SDKs, log files, web beacons, tags and similar technologies. The Platform may generate and process API keys, tokens, authentication logs and other technical credentials required for secure access and integrations. We do not intend to collect or use Sensitive Personal Data for targeted advertising unless permitted by Applicable Laws and expressly authorised under the applicable customer agreement.
We may use Personal Data as permitted by Applicable Laws and as necessary to:
Where required, we process Personal Data based on consent, contractual necessity, legal obligations, legitimate interests or another lawful basis recognised under Applicable Laws. Consent may be withdrawn as permitted by law, without affecting processing previously carried out lawfully.
Where we process Personal Data on behalf of an advertiser, agency, publisher or other customer, we generally act as a processor, service provider or equivalent role. The customer determines processing purposes and means, and remains responsible for providing required privacy notices and obtaining required consents, permissions or another lawful basis. We process Personal Data only as authorised by the customer and Applicable Laws, maintain appropriate technical and organisational safeguards, and may assist with privacy requests, security incidents and compliance obligations. If you believe Personal Data was processed through our Services on a customer’s behalf, please contact that customer first.
We use Cookies, pixels, web beacons, local storage and similar technologies to operate, secure and improve the Platform and Services. These support essential functions such as authentication, session management and fraud prevention; preferences such as remembering account and display settings; and analytics and performance. Where applicable, they may support advertising measurement, attribution, conversion tracking, frequency management and audience management.
Some Cookies expire when you close a browser; others remain for a defined period or until deleted. Where required, we obtain consent for non-essential Cookies and provide options to manage or withdraw consent. You may control or delete Cookies through browser or device settings, though disabling certain Cookies may affect Platform functionality or performance.
The Platform facilitates automated digital advertising transactions and may process information associated with advertising opportunities received from publishers, applications, ad exchanges, SSPs, advertisers, agencies, data providers, measurement providers and other advertising partners. This may include pseudonymous identifiers, IP address, cookie or advertising identifiers, device and browser information, approximate location, contextual information, audience or segment information, Campaign identifiers and other signals associated with an advertising request.
We may use that information to evaluate advertising opportunities, conduct real-time or automated bidding, apply Campaign targeting and frequency controls, select and deliver advertisements, measure impressions and conversions, perform attribution and analytics, optimise Campaign performance, generate reports, and detect and prevent fraud, invalid traffic and other misuse. Information may be shared or matched with Third-Party Platforms and service providers where necessary to provide Services. Where permitted, information may be hashed, pseudonymised, aggregated or de-identified. We do not intentionally use pseudonymous advertising identifiers to determine an individual’s identity except for a lawful purpose or as authorised by the customer agreement.
We may disclose Personal Data where necessary to provide, secure and improve the Services, comply with Applicable Laws, or for the purposes described in this Policy. We may share information with service providers and processors supporting hosting, infrastructure, security, fraud prevention, analytics, communications, payment processing, customer support and other operations, subject to appropriate contractual and security safeguards.
In connection with the DSP, information may be exchanged with publishers, SSPs, ad exchanges, advertisers, agencies, data providers, measurement and attribution providers, fraud-prevention providers and other technology partners for bidding, ad delivery, Campaign management, measurement, attribution, optimisation and fraud prevention. We may share Personal Data with Affiliates for legitimate business purposes; with authorities where legally required or necessary to protect rights or prevent abuse; and as part of a merger, acquisition, financing, restructuring, sale of assets or similar corporate transaction. Cross-border transfers will be made in accordance with Applicable Laws and subject to appropriate safeguards where required.
We maintain reasonable technical, organisational and administrative safeguards against unauthorised access, use, disclosure, alteration or destruction. Measures may include access controls, encryption, authentication, secure storage, logging and monitoring, network security, vulnerability management, security assessments, employee training and incident-response procedures. You are responsible for keeping account credentials, API keys and tokens secure and promptly notifying us of suspected compromise or unauthorised access.
If a security incident occurs, we will take reasonable remedial steps and provide notifications required by Applicable Laws. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
We retain Personal Data only as long as reasonably necessary to provide Services, fulfil the purposes in this Policy, maintain business and financial records, comply with Applicable Laws, resolve disputes, enforce agreements and prevent fraud or misuse. Retention periods vary based on information type and nature, processing purpose, our relationship with you, and legal or contractual requirements. Where we process Personal Data on a customer’s behalf, retention and deletion generally follow the customer agreement.
Account and Campaign information may be retained during the relationship and thereafter as reasonably required for legal, regulatory, financial, security or legitimate business purposes. API keys, tokens and other credentials will be deactivated when no longer required. We may retain aggregated, anonymised or de-identified information longer where permitted. When Personal Data is no longer required, we will securely delete, destroy or anonymise it, subject to routine backups or legally required retention.
Depending on your location and Applicable Laws, you may have rights to access, correct, delete or obtain a copy of Personal Data; request information about its use or sharing; object to or restrict certain processing; withdraw consent; opt out of certain targeted advertising or profiling; request portability; and appeal a privacy-request decision. These rights are subject to legal limitations and may vary by the nature of the Personal Data and our processing role. Requests for data processed on a customer’s behalf may need to be directed to that customer.
To exercise an applicable privacy right or raise a concern, contact our Grievance Officer at Cubera Adexchange, Inc., 5535 Peregrine Way, Blaine, WA 98230, or legal@cubera.co. Please provide enough information to identify your request. We may verify identity and will use verification information only as permitted by Applicable Laws. We will not discriminate against you for exercising applicable rights.
The Platform and Services are intended for business use by individuals at least 18 years old or the applicable age of majority. We do not knowingly collect Personal Data from minors without appropriate parental or guardian consent where required. If we learn that a minor’s Personal Data was collected without required consent, we will take reasonable steps to delete it. Parents or guardians may contact our Grievance Officer.
The Platform and Services may link to or integrate with third-party websites, applications or services. We are not responsible for their privacy practices and recommend reviewing their privacy policies before providing Personal Data. Advertising ecosystem participants may collect and process information under their own privacy policies.
The DSP may use automated systems, algorithms and machine-learning technologies to evaluate advertising opportunities, optimise Campaigns, manage frequency and bidding, detect fraud and measure performance. These processes may involve profiling or automated decision-making. Where Applicable Laws provide rights relating to such processing, we will provide applicable information and mechanisms to exercise those rights.
When you interact with us in a business capacity, we may collect professional information such as name, business email, job title, company name and business telephone number. We use this information to manage business relationships, provide Services, communicate with you and fulfil contractual or legitimate business purposes.
Where material changes are made to this Policy, we will notify you by updating the “Last Updated” date at the top of this Policy and displaying a prominent notice on the website. Continued access to or use of the website after notification or publication of an updated Policy constitutes acknowledgement and acceptance of the revised terms. We encourage periodic review of this Policy.
If you have questions, concerns or requests regarding this Privacy Policy or our privacy practices, please contact:
Cubera Adexchange, Inc.
5535 Peregrine Way, Blaine, WA 98230
Email: legal@cubera.co
As part of the digital advertising ecosystem, the DSP may receive and process privacy preferences, consent signals and other information from publishers, browsers, operating systems, consent management platforms, customers and other authorised partners. Where applicable, we support industry-standard privacy and consent mechanisms.
Advertising-related processing generally uses pseudonymous or technical identifiers. Depending on the information involved and Applicable Laws, such identifiers may constitute Personal Data. We do not intentionally use the DSP to collect or process Sensitive Personal Data for targeted advertising unless permitted by Applicable Laws and authorised under the applicable customer agreement.