Privacy Policy

This Privacy Policy (the “Privacy Policy”) is designed to provide data subjects with information on the processing of their personal data (any information relating to them) by Yango (“Yango Ads” or “we” or “us” or “our”).

Yango Ads helps advertisers (“Advertisers”) to promote their products and services. We do that by providing Advertisers with access to an audience including websites, mobile apps and Smart TV apps of our partners (“Publishers”) and our own websites and services. Our Publishers receive income from serving ads and Advertisers get a flow of traffic and customers. We may also collaborate with other partners such as demand-side and supply-side platforms. Advertisers, Publishers and other partners are collectively referred to as “Partners”.

This Privacy Policy contains important information about, among others, the collection and use of your personal data; the legal grounds for the processing of that data; disclosures of that personal data to third parties and the use of cookies by Yango Ads. Privacy policy also covers the processing of personal data by our website and other websites of Yango Ads (“Website”).

This Privacy Policy is based on the provisions of data protection laws, which may be applicable in the country of your residence.

1. Controller

This Privacy Policy applies when we act as a data controller with regard to your personal data. The legal entity which processes personal data under this Policy is Air Smart Advertising Solutions FZ-LLC (4, Internet City Road Al Sufouh 2, Dubai, Commercial Office - DIC-Bldg 04-101, Commercial Office - DIC-Bldg 04-FL1C1). Depending on the specifics of your relationship with Yango Ads, another legal entity may act as a controller. Please pay attention to the section № 13 of the Privacy Policy (Additional information for certain jurisdictions).

Data subjects can contact us on any questions relating to the processing of their personal data under this Privacy Policy by either of the following methods:

By email: privacy_ads@yango.com

By mail: 4, Internet City Road Al Sufouh 2, Dubai, Commercial Office - DIC-Bldg 04-101, Commercial Office - DIC-Bldg 04-FL1C1.

2. Categories of processed personal data

We may process the following personal data depending on the circumstances of our interaction with data subjects. The table below sets out the categories of personal data we process.

Category of data	Description
Data collected on Advertisers’ websites and mobile applications	IP, cookies, GAID/IDFA/IDFV, device ID, latitude/longitude, Mobile Country Codes (MCC) and Mobile Network Codes (MNC), identifiers of 3rd-party advertising systems (Criteo ID, id5, etc), another data transferred by Advertisers to us.
Data collected on Publishers’ websites and mobile applications	IP, cookies, GAID/IDFA/IDFV, device ID and other device parameters, information about the browser and operating system version, Internet connection type, sim card data (mnc, mcc), identifiers of 3rd-party advertising systems (Criteo ID, id5, etc), another data transferred by Publishers to us.
Data collected by our other Partners	IP, cookies, GAID/IDFA/IDFV, device ID, lat log (coordinates), sim card data (mnc, mcc), identifiers of 3rd-party advertising systems (Criteo ID, id5, etc), another data transferred by Partners to us.
Data collected by our Website	Cookies and other information you provide us by filling out the forms and etc.
Data necessary for concluding and exercising contracts with Partners	Partner representatives’ contact details such as full name, job title, e-mail, phone number, power of attorney or other legal basis for the provision of interests.

3. Purposes and legal bases for the processing

We process your personal data only when we have one of the legal bases mentioned below:

3.1. Performance of the contract. We may process your personal data to provide you with our services under the contract between you / your company.

3.2. Legitimate Interest. We may process your personal data when we (or a third party) have an interest in using your personal data in a certain way, which is necessary and justified in light of the possible risks.

3.3. Consent. Where required by applicable laws, we will process your personal data based on your consent.

3.4. Legal Obligations. When we must process your personal data to comply with applicable laws.

3.5. Other. We can also process your personal data to exercise our legal rights or on the other legal bases provided by applicable law.

The table below sets out:

• Yango Ads’s purpose for processing of personal data;
• Yango Ads’s legal basis for each purpose under applicable law;
• categories of personal data which Yango Ads uses for each purpose.

Purpose for processing	Legal basis	Categories of personal data used for the purpose
Display personalized advertisements	Consent	Data collected by our Partners, Data automatically collected by our Website
Display non personalized advertisements	Legitimate interest	Data collected by our Partners, Data automatically collected by our Website
To provide our services to our Partners, including to proceed payments	Agreement / Legitimate interest	Data necessary for concluding and exercising contracts with Partners
To market, promote, and advertise our services	Consent, legitimate interest	Data necessary for concluding and exercising contracts with Partners
To improve our services, including to train ML models	Legitimate interest	All data
To comply with legal obligations and law enforcement requests	Legal obligation, legitimate interest	All data
To establish, exercise, or defend legal claims	Execution of legal rights	Data necessary for concluding and exercising contracts with Partners
To detect and prevent fraud	Legitimate interest	All data
To provide security	Legitimate interest	All data
To conduct research, contests, surveys	Agreement, Legitimate interest, Consent	Data necessary for concluding and exercising contracts with Partners

We do not process your personal data for other purposes that are not covered by this Privacy Policy.

4. Recipients and sources of personal data

4.1. We disclose certain personal data to the following recipients to the extent required or permitted by applicable law and/or based on their legitimate and reasonable requests:

• our Partners to the extent necessary to serve ads to data subjects, among others, to Google (please see its’ Privacy Policy at https://policies.google.com/privacy;
• payment services providers;
• Partners providing sales and marketing services;
• Partners assisting us in gathering statistical and aggregated information;
• Partners otherwise assisting in provision of our services and achievement of other purposes mentioned in the section 3 of the Privacy Policy;
• affiliate entities of Yango Ads which are a part of the same group of companies
• governmental and regulatory bodies, including law enforcement authorities, in connection with enquiries, proceedings or investigations by such parties or in order to enable Yango Ads to comply with its legal and regulatory requirements.

4.2. We obtain personal data through any information you provide directly to us or through information provided by third parties. Below is the list of ways in which we collect your personal data.

Personal data collected directly from you, including:

• when you complete our Publisher or Advertiser registration forms (if any) or set up your passport / ID on our resources;
• when you use our Website;
• when you contact us for any enquiries, complaints or for any other reason.

Personal data collected from other sources, including:

• via third parties including our Partners in a manner that is permitted;
• through tags in websites data subjects use and/or manage or control.

5. Transfers to third countries

Parties we share your personal data with may be located in different countries, for example, in member states of the Convention for the Protection of Individuals with Regard to Automatic Processing of Personal Data (Convention 108, 1981)

Some of these countries may not provide the same level of data protection or data subject rights as the country where you use a service. In such cases, we follow the necessary procedures to ensure that your rights are respected and that your personal data are protected during and after the transfer.

Such procedures may include (subject to applicable privacy laws):

i) Commitments through data protection agreements based on standard contractual clauses for data transfers issued by relevant authorities;

ii) Additional contractual obligations based on our assessment of the local law of the country where your personal data are transferred and processed;

iii) Registration or authorisation of the transfer from competent data protection authority; and/or

iv) Additional technical and organisational security measures to prevent unlawful, i.e. incompatible with the laws of the country where we provide the service, or unauthorised access to your personal data.

We always comply with the privacy laws of the countries where we operate, including international data transfer requirements and limitations. We do not share your personal data with state authorities contrary to the applicable privacy law.

You can get more information on the mechanisms of transfers to third countries by Yango Ads by sending a request with the use of contact details specified in section 1 of this Privacy Policy.

6. Storage periods

We store personal data as long as it is required to achieve the purposes of the processing specified in section 3 of this Privacy Policy, unless there are specific periods defined in applicable laws.

If you wish to have any personal data removed from our databases, please contact us by sending a request with the use of contact details specified in section 1 of this Privacy Policy.

7. Basic rights of data subjects

Please see your rights and their descriptions in this table. The list of rights of personal data subjects available to you may differ depending on which legislation applies to the relationship between you and Yango Ads.

Right	Description
Access	You can ask us to confirm whether or not we process your personal data. If so, you can access these personal data and ask us to explain certain details of the processing.
Rectification	You can ask us to correct inaccurate personal data concerning you. If it complies with the purposes of the processing, you can ask us to rectify incomplete or inaccurate personal data.
Erasure (“right to be forgotten”)	You can ask us to erase personal data concerning you under applicable law. For example, this applies if (1) the personal data are no longer necessary in relation to the purposes for which they were processed; (2) you withdraw consent to the processing and there is no other legal ground for the processing; (3) the personal data have been unlawfully processed.
Restriction on processing	You can ask us to mark the stored personal data with the aim to limit their processing in the future under applicable law. This applies if (1) you contest the accuracy of the personal data; (2) you ask to restrict the use of the personal data when their processing is unlawful; (3) you need personal data to protect your rights when our services no longer needs the personal data; (4) you have objected the processing based on the legitimate interests pursued by us or by a third party.
Objection to processing	You can object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on the legitimate interests pursued by Yango Ads or by a third party. We shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

To exercise their rights, you can contact us with the use of contact details specified in section 1 of this Privacy Policy.

8. Withdrawal of consent

Where processing is based on consent (or explicit consent), you have the right to withdraw consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal. We can continue to process your personal data if we have another legal basis to do so. To withdraw consent, you can contact us with the use of contact details specified in section 1 of this Privacy Policy.

9. Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority in the area of data protection in the country of your residence.

10. Cookies

We use "cookies" to help personalize and optimize your online experience and time online, including for general improvement of our services. A cookie is a small file placed on your device. Cookies store bits of information that we use to help make our services as well as Website work and enable us to personalize your experience in line with your settings. They can’t run any code and don’t contain viruses.

We use the following types of cookies:

Technical (strictly necessary) cookies: These cookies are necessary for the website/app to function and cannot be switched off in our systems. They are usually only set in response to actions made by visitors which amount to a request for services, such as setting privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but this may cause parts of the site/app to not work properly. These cookies do not store any personal data.

Marketing cookies: Marketing cookies are necessary to track visitors across the website/app and display ads that are relevant.

Analytical cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our services. They help us to know which pages are the most and least popular and see how visitors move around the site/app. If these cookies are disabled, we will not know when a user like yourself has visited our site/app or be able to monitor the site’s/app's performance.

Most browsers allow you to control cookies through their setting preferences. Limiting the ability of websites to set cookies, however, may deteriorate the overall user experience or deactivate features that you wished to utilize.

For more information please see our Cookie Policy.

11. Children’s privacy

We do not knowingly or intentionally collect personal data through our services from children under eighteen (18) years of age. If you are under eighteen (18) years of age / other age, recognized in your jurisdiction as sufficient for your use of our services, do not attempt to register for or use of our services (for example, as Publisher), do not provide us any personal data about yourself unless you have the requisite parental consent. If you are a parent or guardian and you are aware that your child has violated this Privacy Policy and provided us personal data, please contact with the use of contact details specified in section 1 of this Privacy Policy. If we become aware that a minor has provided us personal data or we otherwise process his personal data in violation of the Privacy Policy, we will take steps to remove that information.

12. Changes to this Privacy Policy

We may change this Privacy Policy from time to time at our sole discretion. If so, we may notify the data subjects about these changes by an appropriate method. If there is no explicit notification, the data subjects may always review the up-to-date version of this Privacy Policy.

13. Additional information for certain jurisdictions

This section of the Privacy Policy applies only with regard to specified jurisdictions. When applicable, this section shall prevail over all other parts of the Privacy Policy in case of discrepancies.

MEXICO

For users to whom the Mexico data protection legislation is applied, the data controller is Modern Internet Solutions S. de R.L. de C.V.

Data subjects can contact us on any questions relating to the processing of their personal data under this Privacy Policy by either of the following methods:

By email: privacy_ads@yango.com

By mail: 11560, Av. Ejercito Nacional 418, 307, Col. Polanco V Seccion, Miguel Hidalgo, Ciudad de Mexico, Mexico.

Applicable legislation for such users is the Ley Federal de Datos Personales en Posesión de los Particulares (the Law), and its regulations.

If in some types of data processing activities consent is the only legal basis, you provide such consent by agreeing to use our services. We hereby inform you, and you hereby acknowledge, that you have no legal obligation to provide us with any personal data when you use our services, and such provision is solely based on your free will. However, you are aware that without the provision of some personal data, we will not be able to provide you with the services.

You have following rights under Mexican data protection legislation: we respond to all requests we receive from users wishing to exercise their data protection rights, including their ARCO rights - access, rectification, cancellation and opposition - in accordance with the Law.

You have also the right to lodge a complaint to the *“*Instituto Nacional de Transparencia Acceso a la Información y Protección de Datos Personales” (INAI).

BRAZIL

For users to whom the Brazil data protection legislation is applied, the data controller is Adtech Solutions Ltda (São Paulo, State of São Paulo, Rua Libero Badaró, 293, 21st floor).

Data subjects can contact us on any questions relating to the processing of their personal data under this Privacy Policy by either of the following methods:

Our DataProtection Officer details: MATHEUS PUPPE SOCIEDADE DE ADVOGADOS, CNPJ 41.632.008/0001-58, with its registered office at Rua Chile 136, sl 202, CEP 30310670, Belo Horizonte-MG.

By email: privacy_ads@yango.com

By mail: São Paulo, State of São Paulo, Rua Libero Badaró, 293, 21st floor.

Applicable legislation for such users is the Brazilian General Data Protection Law (LGPD), Federal Law no. 13,709/2018.

When we transfer your personal information outside Brazil, we do so in accordance with the terms of this Privacy Policy and applicable data protection law. Your personal information can be transferred to United Arab Emirates. When we transfer your personal information outside Brazil, we follow the necessary procedures described in Section 5 of this Privacy Policy to ensure that your rights are respected and that your personal data are protected during and after the transfer.

You have following rights under Brazilian data protection legislation:

• confirmation of the existence of processing from data controller;
• access to your personal data;
• correction of incomplete, inaccurate or outdated personal data;
• anonymization, blocking or deletion of unnecessary, excessive or processed data in violation of the provisions of Brazilian legislation;
• portability of data to another service or product provider, upon express request, in accordance with the regulations of the ANPD, subject to commercial and industrial secrets;
• deletion of personal data processed with your consent of the data subject, except in the cases provided for in art. 16 of the LGPD;
• to receive information on public and private entities with which the controller made shared use of data – as described in section 4 of this Privacy policy;
• to receive information about the possibility of not giving consent and about the consequences of the refusal;
• revocation of consent, pursuant to § 5 of art. 8 of the LGPD.

You have also the right to lodge a complaint to the National Data Protection Authority (ANPD).

CHILE

For users to whom the Brazil data protection legislation is applied, the data controller is Modern Digital Solutions SpA (Avenida Costanera Sur 2730, of 1201, Borough of Las Condes, Santiago, Chile)

Data subjects can contact us on any questions relating to the processing of their personal data under this Privacy Policy by either of the following methods:

By email: privacy_ads@yango.com

By mail: Avenida Costanera Sur 2730, of 1201, Borough of Las Condes, Santiago, Chile

Applicable legislation for such users is Law 19,628/1999 On the protection of private life (PDPL); Personal Data Protection Law (Law 21.719).

When we transfer your personal information outside Chile, we do so in accordance with the terms of this Privacy Policy and applicable data protection law.

You have following rights under Chilean data protection legislation: we respond to all requests we receive from users wishing to exercise their data protection rights, including their PDPL rights - access, rectification, erasure restriction on processing, objection to processing - in accordance with the Law.

TURKEY

For users to whom Turkish data protection legislation is applied, the data controller is Büyük Reklam Çözümleri Limited Şirketi (Halaskargazi Mah. Halaskargazi Cd. No:38-66/E İç Kapı No:215 Şişli/ İstanbul)

Data subjects can contact us on any questions relating to the processing of their personal data under this Privacy Policy by either of the following methods:

By email: privacy_ads@yango.com

By mail: Halaskargazi Mah. Halaskargazi Cd. No:38-66/E İç Kapı No:215 Şişli/ İstanbul

Applicable legislation for such users is Personal data protection law of the Republic of Türkiye №6698 of 24/3/2016 (the Law)

When we transfer your personal information outside Turkey, we do so in accordance with the terms of this Privacy Policy and applicable data protection law.

You have following rights under Turkish data protection legislation:

• Learn whether your personal data is being processed,
• Request information if your personal data has been processed,
• Learn the purpose of processing your personal data and whether they are being used for their intended purpose,
• Know the third parties to whom your personal data have been transferred domestically or abroad,
• Request correction of your personal data in case they are incomplete or inaccurate,
• Request the deletion or destruction of your personal data in accordance with the conditions envisaged in Article 7 of the Law,
• Request that the third parties to whom your personal data have been transferred be notified of the corrections, deletions, and destructions made in accordance with your rights mentioned above,
• Object to the occurrence of a result against you through the analysis of your personal data exclusively by automated systems,
• Demand compensation for damages in case you suffer damage due to the unlawful processing of your personal data.

Date of publication: 26.11.2025.

 

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