MultiBrain

MultiBrain INC. Privacy Policy

Last updated: July, 30, 2025

1. Introduction

MultiBrain INC. (“MultiBrain” or “We”) is committed to protecting consumer privacy and providing transparent information about the collection and use of personal information. This Privacy Policy (“Policy”) outlines how MultiBrain collects, processes, and shares personal information when delivering mobile advertising automation technology and solutions to advertisers, buyers, app developers, and publishers of mobile apps and websites (collectively, “Clients” or “You”). Our practices are designed to ensure market quality and transparency, aligning with regulations on data privacy.

This Policy applies specifically to information gathered through MultiBrain’s Ad Services, which may include advertising, measurement, data validation, fraud protection, and related services. The Policy also explains your choices regarding the processing of your information within these services.

2. Information Collection

We collect various types of information to optimize ad delivery and provide a personalized advertising experience.

Ad Service Information:

Bid Request Data: We retain only the minimum bid request data needed for operational purposes. These data fields include request_id, timestamp, adslot_id, auction_type, floor_price, deal_id, country, region, device_type, ad type, and ad size.

Tracking Mechanism Data: We use tracking mechanisms (such as pixels and cookies) to collect data fields including ad interactions (impressions and clicks), related metadata (such as campaign IDs, creative IDs, and ad formats), contextual information (such as app bundles, operating systems, and domains), and attribution data (such as last click IDs). We also collect location-related data points such as country and region to meet advertisers' specific demands for ad delivery in certain geo-locations.

Personal Identifiable Information (PII) Minimization: Our systems are designed to exclude PII (e.g., name, email, phone number, full address) from being collected or processed by default during the bid request, response, or tracking stages. We do not access, use, or process any personal information provided by Google that directly or indirectly identifies an individual in the European Economic Area (EEA).

3. Data Use, Retention, and Security

We use the collected information in various ways to provide and improve our services.

Data Use Purposes: Data collected from the bidding process is used for:

Deciding whether to bid and for how much.

Frequency capping to prevent users from being overexposed to ads.

Tracking ad delivery and user engagement.

Attribution modeling to assign credit for conversions across touchpoints.

Model training and algorithmic improvements using historical performance data.

Inventory quality assurance to identify suspicious click or impression patterns.

Supporting billing and reconciliation to ensure financial accuracy.

Data Retention: We adhere to data minimization principles. Once the bidding process is complete, our system performs a set of automated operations to manage, minimize, and delete data. We retain only the minimum bid request data needed for operational purposes, such as win/loss logging, campaign performance measurement, and fraud detection. The data retention period is a maximum of 30 days for fraud analysis, delivery debugging, and analytics.

Aggregation: Before long-term storage, we anonymize and group data by dimensions such as domain/app bundle, device type, country/region, ad format, time buckets, and campaign/creative ID.

4. Interest-Based Advertising and Compliance

We are committed to complying with applicable data privacy regulations and industry guidelines.

User Consent:

EU (EEA): We follow the General Data Protection Regulation (GDPR) and Google's EU User Consent Policy. We are a registered vendor of the TCF (Transparency and Consent Framework) v2.2 and only process or bid on EEA inventory when we receive a valid consent signal.

California: We comply with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). We parse incoming OpenRTB bid requests to interpret the regs.gpp signal and honor the "Do Not Sell or Share My Personal Information" signal.

User Opt-Out Process: We accept user opt-out requests via TCF and direct opt-out forms, among other methods. Once a user opts out, we will "prevent the use of personal data for targeting, analysis, or enrichment, and stop serving interest-based ads to those who have opted out."

Online Behavioral Advertising (OBA): All creatives involving behavioral targeting are tagged with the AdChoices icon or an equivalent notice. Our bidder includes the ext.oba field in bid responses to explicitly declare when an ad is behaviorally targeted. We honor all user opt-outs and "Do Not Track" signals.

5. Ad Creative Process

We have a multi-staged process in place to ensure ad creative compliance.

Creative Submission and Review: All creatives are subject to a mandatory pre-submission scan via our deep API integration with The Media Trust (TMT) before being submitted to Google. TMT performs real-time, in-depth analysis to detect malware, undeclared vendors, misleading content, and policy violations. Any creative that fails the TMT scan is automatically quarantined and blocked.

Disapproved Creatives: If a creative is disapproved by Google, it is marked as ineligible and "prevented from being included in any bid requests." We maintain an internal database to track all creatives disapproved by Google. If an advertiser wishes to use a previously disapproved creative, it must undergo a strict remediation and resubmission process, which includes a mandatory TMT pre-scan and internal quality review.

Sensitive Category Declarations: Advertisers are required to explicitly declare if their creative falls into any sensitive categories. Our internal systems also perform automated content analysis to aid in classification. This information is stored as structured metadata and automatically included in the bid response.

6. Opting Out of Your Information

You can opt out of certain processing of your personal information in the following ways:

Cookies: Most web browsers accept cookies by default, but you can choose to reject or delete them through your browser settings.

Device Identifiers: You can adjust your device settings to reset or limit the use of mobile device identifiers, such as the Advertiser ID (IDFA) or Android Advertising ID (AAID).

Opt-Out Tools: You may use industry-provided opt-out tools, such as those from the Network Advertising Initiative (NAI) and the Digital Advertising Alliance (DAA), to opt out of certain advertising.

7. Policy Changes

MultiBrain is committed to continuously reviewing and improving its privacy practices. As part of this commitment, we may update this Privacy Policy from time to time.1

Minor changes will take effect 14 days after the notice is posted. Significant changes, which could substantially affect the way we handle your personal information, will take effect 30 days after the notice is post2ed. By continuing to use our services after the updated policy takes effect, you agree to the revised terms. Please note that if we need to modify this policy to comply with legal requirements, the new policy will take effect immediately or as required by law.

8. Contact Us

If you have any questions or suggestions regarding MultiBrain's Privacy Policy, please contact us at [email protected]. For your protection, please do not include sensitive information in your email.