Privacy Policy

Last updated: March 2026

[AsiaPac Net Media Limited] ("we", "us", "our") operates a Demand-Side Platform (DSP) that enables advertisers and agencies to purchase digital advertising inventory in real time through programmatic auctions.

We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the ePrivacy Directive, as well as the IAB Europe Transparency & Consent Framework (TCF v2.3).

This Privacy Policy explains how we process personal data when acting as a vendor in the digital advertising ecosystem, particularly under the IAB Europe TCF.

1. Who We Are (TCF Vendor)

We participate in the IAB Europe Transparency & Consent Framework as a registered vendor. Our Vendor ID will be available on the Global Vendor List (GVL) at:
https://iabeurope.eu/vendor-list-tcf/ after approval.

2. Data We Process

We may receive and process the following categories of personal data through bid requests, ad delivery, and measurement:

• IP addresses
• Device characteristics (e.g., user agent, browser type, operating system, screen resolution)
• Device identifiers (where applicable)
• Probabilistic identifiers (where applicable)
• Browsing and interaction data (e.g., ad impressions, clicks, viewability events)
• Non-precise location data (e.g., derived from IP address at city/region level)
• User profiles (inferred interest or behavioural profiles, only under consent for Purposes 3 and 4)

We do not collect precise geolocation data, user profiles for personalised advertising without consent, user-provided data (such as names or emails), or authentication-derived identifiers unless explicitly declared otherwise.

3. Purposes of Processing & Legal Bases

We declare the following purposes under the IAB Europe TCF:

• Purpose 1 – Store and/or access information on a device → Consent as sole legal basis
• Purpose 2 – Use limited data to select advertising → Consent or legitimate interest as a legal basis (default: Legitimate interest)
• Purpose 3 – Create profiles for personalised advertising → Consent as sole legal basis
• Purpose 4 – Use profiles to select personalised advertising → Consent as sole legal basis
• Purpose 5 – Create profiles to personalise content → Consent as sole legal basis
• Purpose 6 – Use profiles to select personalised content → Consent as sole legal basis
• Purpose 7 – Measure advertising performance → Consent or legitimate interest as a legal basis (default: Legitimate interest)
• Purpose 8 – Measure content performance → Consent or legitimate interest as a legal basis (default: Legitimate interest)
• Purpose 9 – Understand audiences through statistics → Consent or legitimate interest as a legal basis (default: Legitimate interest)
• Purpose 10 – Develop and improve services → Consent or legitimate interest as a legal basis (default: Legitimate interest)
• Purpose 11 – Use limited data to select content → Consent or legitimate interest as a legal basis (default: Legitimate interest)

We rely on legitimate interest (with the default setting shown above) where permitted by TCF Policies. For Purposes 3–6, we use consent only — no legitimate interest fallback is permitted.

Special Purposes (Legitimate Interests only)

We rely on legitimate interests (Article 6(1)(f) GDPR) for the following essential operational Special Purposes under TCF:

• Special Purpose 1: Ensure security, prevent and detect fraud, and fix errors
• Special Purpose 2: Deliver and present advertising and content

We process personal data for Special Purpose 1 solely for ensuring platform security and fixing technical errors. We do not perform fraud detection or anti-fraud activities for advertising traffic.

Users cannot object to these Special Purposes via CMP interfaces, as they are necessary for the secure and functional operation of our platform.

4. Legitimate Interest Claim – Special Purposes

We have conducted Legitimate Interests Assessments (LIAs) for each Special Purpose. Below is a summary:

Special Purpose 1 – Security, fraud prevention & error fixing

Legitimate interest: Protecting our platform, publishers, advertisers and the advertising supply chain from fraud (e.g., bots, invalid traffic), security threats and technical errors.

Our legitimate interest is limited to secure platform operation and error resolution. We do not process data for fraud prevention or detection.

Necessity: Processing is limited to the minimum data required (e.g., IP address, device signals, bid patterns) and only for real-time detection and mitigation.

Balancing: The processing has very low privacy impact, is expected in ad-supported services, and fraud prevention benefits the entire ecosystem. Data subjects’ rights do not override our interests.

Special Purpose 2 – Deliver and present advertising and content

Legitimate interest: Ensuring technical delivery of ads (e.g., compatibility checks, transmission of creative files).

Necessity: Strictly limited to basic technical data (IP address, user agent, connection type).

Balancing: Minimal intrusiveness; users reasonably expect ads to load correctly on ad-supported websites/apps.

Overall balancing test

In all cases, we apply data minimisation, short retention periods where feasible, pseudonymisation where possible, and technical/organisational safeguards. The interests pursued are legitimate, necessary and proportionate, and do not override the rights and freedoms of data subjects.

5. Cookie & Device Storage Disclosure

We may set and access cookies on your device (with your consent under Purpose 1).

Maximum cookie age: up to approximately 18 months (46,656,000 seconds) for certain cookies, which may be refreshed upon subsequent interactions or visits.

Some specific cookies have a maximum age of approximately 5 years (157,680,000 seconds) and not refreshed after the initial set period.

Detailed disclosure: https://www.aphub.ai/policy/tcf-device-storage.json

We do not use other storage methods such as localStorage, IndexedDB, or mobile advertising IDs.

6. Your Rights

You have the right to access, rectify, erase, restrict processing, data portability, and object to processing based on legitimate interests (where applicable).

To exercise your rights, contact us at: privacy-support@aphub.ai

For TCF-specific choices (consent withdrawal, objection to legitimate interests for regular purposes), use the CMP interface provided by the publisher/website.

7. Contact

Data Protection Officer / Privacy Contact:
Email: privacy-support@aphub.ai

(If you prefer not to list full address: "For privacy inquiries and data subject rights requests, please contact us at the email above. We will provide further details as needed.")

We may update this policy from time to time. Changes will be posted here with the updated date.