Simula's Privacy Policy

There are no Simula end-user accounts, and we do not knowingly collect your name, email address, phone number, or other directly identifying contact information from end users.

When We Deliver Simula Ads in Publisher Apps

• Device and connection information, such as your device's advertising identifier (e.g., Apple IDFA or Google Advertising ID, where available and permitted by your device settings), IP address, device type and model, operating system and version, language, time zone, mobile carrier, and network type.
• App and ad activity information, such as the Publisher App in which an ad appears, the ad format and placement, and how you interact with Simula Ads — for example, impressions, clicks, time viewed, interactions within a playable ad, and whether a rewarded ad was completed.
• General location information inferred from your IP address (such as country or region). We do not collect precise GPS location.

When You Visit the Site

• IP address, used to infer general geographic location, for analytics, and for security and fraud prevention.
• Standard technical data received automatically by our servers, such as browser type, operating system, referring URLs, and pages visited.
• Device and browser storage. We use localStorage (persists until you clear it) and sessionStorage (cleared when your browser session ends) to store device-related information for advertising and analytics purposes. We do not use these mechanisms to store directly identifying personal data. A machine-readable disclosure of the client-side storage we use is available at simula.ad/simula_ad_device_storage_disclosure.json. The Site does not currently set cookies.

We use the information described above to:

• Select, deliver, and display ads, including limiting how often you see the same ad (frequency capping);
• Build advertising profiles and improve the relevance of the ads we serve, where permitted by applicable law and your device settings;
• Measure ad performance and provide aggregated reporting to our publishers and advertisers;
• Detect and prevent invalid traffic, fraud, and abuse, and secure our services and the Site;
• Perform billing, accounting, and discrepancy management with our publishers and advertiser clients;
• Operate, maintain, analyze, and improve our products, services, and the Site; and
• Comply with our legal obligations and enforce our agreements.

We may create de-identified or aggregated information from the data we process. De-identified and aggregated information is not personal information, and we may use and disclose it for any lawful purpose.

If you are in the European Economic Area or the United Kingdom, we process personal data on the following bases: consent (Article 6(1)(a) GDPR), where we store information on your device or process your data for personalized advertising; legitimate interests (Article 6(1)(f) GDPR), for security, fraud prevention, measurement, and operational analytics, where those interests are not overridden by your rights; and legal obligation (Article 6(1)(c) GDPR), where processing is required to comply with law. You may withdraw consent at any time; withdrawal does not affect the lawfulness of prior processing.

We may share the information described above with:

• Advertisers and demand partners, to the limited extent necessary to serve and bid on ads and measure their performance;
• Publisher partners, in the form of reporting and analytics about ad activity in their apps;
• Service providers that support our infrastructure, such as cloud hosting, measurement, and fraud-detection vendors, under appropriate data processing agreements, who are permitted to use the information only to provide services to us;
• Legal and safety recipients, where we believe in good faith that disclosure is required or appropriate to comply with law, legal process, or government requests, or to protect the rights, property, or safety of Simula, our partners, or others; and
• Successors, in connection with a merger, acquisition, financing, reorganization, or sale of assets, in which case information may be transferred as part of that transaction as permitted by law.

We do not sell directly identifying information such as names or email addresses — we do not collect it from end users in the first place. However, certain sharing of advertising identifiers, IP addresses, and device-level signals with advertising partners may be considered a “sale,” “sharing,” or “targeted advertising” under applicable privacy laws. You have choices about this, described below.

Depending on where you live, you may have rights under applicable law to: request confirmation of whether we process your personal information; request access to or a copy of it; request correction of inaccurate information; request deletion; request portability; restrict or object to certain processing; opt out of “sales,” “sharing,” or targeted advertising; and not be discriminated against for exercising your rights.

• United States. Residents of California and other states with comprehensive privacy laws may exercise the rights above as provided by those laws.
• EEA & UK. You have the rights provided under the GDPR and UK GDPR, including the right to lodge a complaint with your local supervisory authority.
• Canada, Australia & New Zealand. You may have rights under PIPEDA, the Australian Privacy Act, the New Zealand Privacy Act, and other local laws, including rights of access and correction.

To exercise any of these rights, contact us as set forth below. For requests relating to in-app ad processing, include your device's advertising identifier so we can locate information associated with your device. We will take steps to verify your identity or your device and will respond within the timeframes required by applicable law.

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have a complaint, contact us at: