Effective Date: January 1, 2024
Last Updated: January 18, 2026

This Privacy Policy explains how Clearpier Technology Limited ("Company," "we," "us," or"our"), a company headquartered in Canada, collects, uses, discloses, and protects information in connection with our website and our Connected TV (CTV) and digital advertising services (the "Services").

We are committed to respecting data privacy rights across all jurisdictions, including under the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), and the Personal Information Protection and Electronic Documents Act (PIPEDA).

1. Scope & Role

This Privacy Policy applies to:
1. Website Visitors: Individuals who visit our corporate website.
2. Advertising Services: Technical data processed through our advertising platforms and Connected TV (CTV) DSP/ad network.
Our Role in Advertising: With respect to our CTV and advertising Services, Company acts primarily as a Data Processor or Service Provider on behalf of our business clients (advertisers, publishers, and media partners). We do not collect directly identifiable Personal Information (such as real names, home addresses, or government IDs) from end users of CTV devices or applications.

2. Information We Collect

A. Corporate Website Data
When you visit our website, submit an inquiry, or contact us:
- Contact Information: Name, business email, phone number, and company name provided voluntarily via contact forms.
- Technical Log Data: IP address, browser type, operating system, and referral URLs collected via standard web server logs and cookies.

B. Advertising Platform & CTV Services Data
When ads are served via our CTV DSP or ad platform, we collect pseudonymous device and technical data, including:

- Device Identifiers: Advertising IDs(e.g., Roku Advertising ID, Amazon Fire TV ID, Apple IFA, Google GAID, Smart TV IDs).

- Network & Location Data: IP address (used to infer broad geographic location at the country/city level) and network connection type.

- Technical Parameters: App bundle name/ID, user agent, operating system version, device model, screen resolution, and timestamp.

- Ad Interaction Data: Ad impressions, views, completion rates, clicks, and aggregated performance metrics.

We do not knowingly collect or receive Sensitive Personal Data or directly identifiable PII (such as full names, email addresses, SSNs, or precise geolocation coordinates) via our ad technology services.

3. How We Use Information

We use the collected information for the following business purposes:

- Service Provision & Ad Delivery: To deliver, measure, target, and optimize CTV and digital ad campaigns.

- Reporting & Analytics: To provide aggregated performance reporting, impression counting, and attribution to advertisers and publishers.

- Fraud Detection & Security: To detect, prevent, and mitigate invalid traffic, ad fraud, security incidents, and technical glitches.

- Legal Compliance: To comply with applicable laws, industry standards, and legal obligations.

- Website Operation: To maintain, improve, and analyze the usability of our corporate website.

4. Legal Basis for Processing (GDPR /PIPEDA Compliance)

Where applicable under European or Canadian privacy laws, our legal grounds for processing pseudonymous ad data include:
- Legitimate Interests: For ad delivery, performance measurement, fraud prevention, and system security.

- Consent: Obtained by our publishing partners and app publishers on our behalf prior to ad serving, where required by local regulations.

5. Sharing & Disclosure of Information

We do not sell personal information or share directly identifiable PII. We may share pseudonymous ad data only with:

- Service Providers / Sub-processors: Cloud hosting providers (e.g., AWS), data security providers, and measurement partners bound by strict confidentiality and privacy agreements.

- Business Partners: Advertisers and publishers in the form of aggregated or pseudonymous campaign performance reports.

- Legal Requirements: If required to respond to lawful subpoenas, warrants, court orders, or government inquiries.

- Corporate Transfers: In connection with a merger, acquisition, reorganisation, or sale of company assets.

6. Children’s Privacy (COPPA Compliance)

Our Services are intended exclusively for general audiences. We do not knowingly collect personal data from children under the age of 13 (or under 16 in the EEA/UK). If we learn that we have inadvertently collected personal data from a child under the applicable age limit, we will promptly delete such information.

7. International Data Transfers

Company operates in Canada and stores data primarily in secure cloud infrastructure located in Canada, the United States, and/or the European Union. When data is transferred internationally, we ensure appropriate safeguards are implemented in accordance with applicable data protection laws (including Standard Contractual Clauses or equivalency frameworks where relevant).

8. Data Security & Retention

- Security: We implement technical, organizational, and administrative security measures (including encryption in transit via TLS, access controls, and firewall defenses) to protect data from unauthorized access or disclosure.

- Retention: Pseudonymous advertising data and log records are retained only for as long as necessary to fulfill business reporting, attribution, and legal obligations (typically deleted or anonymized within 90 to 180 days).

9. Your Privacy Rights & Opt-OutOptions

Depending on your region, you may have rights regarding your personal information, including the right to access, correct, or request deletion of your data.

- CTV & Mobile Ad Opt-Out: Users can opt out of interest-based advertising or reset their advertising ID through their smart TV, streaming media player, or mobile device settings (e.g., "Limit Ad Tracking" or "Reset Advertising ID" on Roku, Fire TV, Apple TV, Android TV, iOS, or Android).
- Privacy Requests: To exercise privacy rights, please submit a written request to `privacy@clearpiergroup.com`.

10. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in our operational practices or legal requirements. Updated versions will be posted on our website with a revised "Last Updated" date.

11. Contact Us

If you have questions, comments, or requests regarding this Privacy Policy, please contact us at: privacy@clearpiergroup.com