Privacy Policy

Lupon Media provides our customers (“Publishers” of websites or content creators) with the technical ability to generate revenue through digital advertising (referred to as “Interest-based Advertising”) and/or affiliate marketing, to you, the “Reader.”

As a data broker, we also sell data to advertisers, brands, retailers, and other businesses who use the data to support their own commercial purposes.

This Privacy Policy (“Privacy Policy”) describes how Lupon Media collects, uses, and shares information from Publishers and about Readers in connection with Lupon Media Services and our public-facing business websites found at www.luponmedia.com and www.adxpremium.services (“Site”).

Definition of Terms

Throughout this Privacy Policy, we use the following terms:

“Advertiser” means an entity providing ads to be placed on Publisher websites.
“Non-Personal Information” means information that is not associated with or linked to Personal Information including aggregate or de-identified information.
“Personal Information” means any information that can be used to directly or indirectly identify a natural person, such as contact information (i.e., name, address, e-mail address, and/or phone number), and/or information that uniquely and persistently identifies a browser or device such as an IP address, mobile advertising identifier, cookie identifier, or email address that has been hashed to generate an alphanumeric identifier, or combination of information about a browser or device (such as IP address and browser type/settings). As explained below, Lupon Media Services do not collect types of Personal Information about Readers that can be used to identify specific individuals.
“Publishers” are websites or publications that use Lupon Media Services, or natural persons who interact with Lupon Media on behalf of such websites or publications.
“Readers” are individuals who visit our Publishers’ websites.
“Lupon Media” or “we” means Lupon Media Holdings, Inc. with our affiliates (including those not under the Lupon Media brand.

Description of Lupon Media Services

Our products are used on websites and other internet-connected services (such as smart TV’s and mobile devices). A more in depth description of our services can be found at our https://luponmedia.com/publishers site.

The Lupon Media Services that collect information from users are:

Lupon Media Exchange for Interest-based Advertising;

Lupon Media is a data broker. As a data broker we may share your information with other parties. For more information for California Residents, see “Personal Information we sell to third parties”, located under “Information for California Consumers” in the “Country and State Specific Disclosures” section, below. Other Lupon Media Services collect information about Publishers as described in our Publisher Agreements.

Lupon Media Services contain links to websites or content operated and maintained by third parties over which we have no control. We encourage review of the privacy policies of such third-party websites and content before disclosing any information to them.

Additionally, Lupon Media collects Personal Information through interactions with the Site. By visiting or submitting Personal Information through the Site, you acknowledge and agree to the terms of this Privacy Policy and to the processing of your Personal Information in accordance with this Privacy Policy.

Our goal is to be transparent about our business by describing our technology and services in simple terms. If unsure about any of the information provided, please reach out to [email protected].

Our Commitment to Good Advertising Practices

Lupon Media supports industry self-regulation and endorses industry best practices and self-regulatory standards.

Lupon Media follows and adheres to the industry Self-Regulatory Principles of the Digital Advertising Alliance (“DAA”).

Lupon Media also adheres to the Interactive Advertising Bureau (“IAB”) Code of Conduct, and actively participates in the IAB Europe Transparency & Consent Framework (TCF 2.0). We comply with IAB’s Specifications and Policies under vendor identification number 13.

For more information about industry self-regulation of Interest-Based Advertising, please visit: www.networkadvertising.org and www.aboutads.info.

Information We Collect

The information we collect allows us to see browsing habits at an individual level, but we do not attempt to identify the exact individual who is browsing. Read more about the types of information used in Interest-Based Advertising, as well as what to expect when visiting our Site.

Lupon Media Services and Site collects both Personal Information and Non-Personal Information. Lupon Media does not collect personally identifiable information (“PII”) about Readers such as names, email addresses, physical addresses, or phone numbers, unless provided to us through the Site when requesting materials or information from us.

The following provides more detail into the types of Personal Information we collect (and in some instances purchase from partners) and use in conjunction with the Lupon Media Services and Site:

Cookie ID	A randomly generated identifier (created by Lupon Media) that is stored on a browser and allows us to understand Reader browsing behavior, without knowing the exact identity of the individual. Also known as a third-party cookie.
Universal ID	An identifier typically constructed of a Reader’s hashed and salted email address that will recognize user identity across different platforms. The Universal ID is created by an identity provider, rather than each individual third party, as in the case of cookies, and is also known as first-party data.
Device information	Device information can include your browser agent, browser type, operating system, device type, use of ad blocking tools, and information about the possible relationships among different browsers and devices.
Hashed email	Hashing is a way of making a piece of data, like an email address, into a hexadecimal string so that it is no longer readable. Each email address has its own unique hexadecimal string that remains consistent no matter where the email address is used.
IP address	An Internet Protocol address (IP address) is a numerical label assigned by an Internet Service Provider (ISP) to each device connected to a computer network that allows the device to communicate on the Internet. Most IP addresses are dynamic, meaning they change every time the device is restarted.
General location information	Using your IP address and third-party services, we may collect general location information such as your country, city or state. Collecting this information not only supports our services, but helps us to understand your data rights.
Mobile advertising ID	In mobile apps, we use identifiers provided by the mobile device’s operating system that can be reset by users. Typical advertising IDs are AdID (Android) and IDFA (Apple). Mobile advertising IDs allow developers and marketers to track activity associated with a specific device for advertising purposes. They’re also used to enhance serving and targeting capabilities.
Personally Identifiable Information (“PII”)	PII such as first/last name and email address may be required for some inquiries through the Site. Lupon Media will only collect PII you voluntarily provide.
Precise location information	Precise location information may include, for example, data obtained from cell tower or Wi-Fi triangulation techniques, or latitude-longitude coordinates obtained through GPS technology, if such data is sufficiently precise to locate a specific device.

How We Collect Information

Lupon Media uses various technologies to collect both Personal- and Non-Personal Information, such as cookies, tracking pixels, or scripts. We also collect information voluntarily provided through our Site. The term ‘cookies’ is used as an umbrella term for these technologies; for convenience, these technologies are collectively referred to in this Privacy Policy as “cookies.”

About Our Cookies

Cookies are widely used in digital advertising to gather information about our website and its performance. Neither us, advertisers or our advertising partners can gain personally identifiable information from these cookies.

Most web browsers will allow you to turn off cookies. To do this, look at the “help” menu on your browser. However, switching off cookies may restrict your use of the website and/or affect the way in which it performs. We should add that opting out of advertising cookies will not mean you won’t see ads, just that they won’t be tailored to you. The cookies installed on luponmedia.com are as follows:

Lupon Media Website Cookies

_ga	Google Analytics User	This cookie is used by Google Analytics, a marketing tool and service provider, to identify a user for purposes of reporting and analytics on visits to Lupon Media sites.	2 Years	Google Privacy Policy
_gat	Google Analytics User Settings	This cookie is used by Google Analytics, a marketing tool and service provider, to control the frequency of requests to the Google Analytics service.	1 Minute	Google Privacy Policy
_gid	Google Analytics User	This cookie is used by Google Analytics, a marketing tool and service provider, to identify a user for purposes of reporting and analytics on visits to Lupon Media sites.	24 Hours	Google Privacy Policy

Through our Site

We collect Personal Information submitted to us voluntarily, such as name and contact information. For example, when signing up to receive our newsletter, we collect your email address. When contacting us via email, we will collect the email contents.

Both session cookies (which expire once the web browser is closed) and persistent cookies (which stay on a device until deleted) are used to collect viewing and search behaviors.

Through Lupon Media Services

The information we gather about browsing preferences and purchasing behaviors using cookies helps us provide Lupon Media Services to our Publishers, which in turn provides meaningful Interest-based Advertising to Readers.

Readers

We set cookies (where allowed) at the first visit to any of the Publisher sites that deploy Lupon Media Services. If our cookie is already set on a browser, we recognize a returning Reader and log data using the existing cookie. Readers have the option to use tools provided by browsers to decline to receive cookies or to clear cookies, which will result in us treating the Reader as a new visitor when encountering Lupon Media Services. However, in order to stop Interest-based Advertising by Lupon Media, individuals must explicitly opt-out as described in the “How to Opt-Out” section.

Lupon Media Services may use both session cookies (which expire once the web browser is closed) and persistent cookies (which stay on a device until deleted).

Some of our business partners (for example, Google Analytics) may set or use their own cookies on our Publisher websites or through Lupon Media Services where Lupon Media has no access to or control over these cookies.

Publishers

Publishers provide Personal Information about themselves when registering to use Lupon Media Services. Alternatively, Publishers may register for Lupon Media Services using an existing Google account, in which case Lupon Media will receive Personal Information from Google as defined by Google’s privacy policy. Personal Information collected at registration may include: a valid email address, username and password, first and last name, telephone number, website(s) URLs, software, mobile applications, log-in IP address(es), physical address, ZIP code, and country of residence for the Publisher contact.

We collect Publisher payment information from those who purchase Lupon Media Services. Lupon Media provides a third-party service to manage revenue payments to Publishers. This service also provides transactional information to Lupon Media for financial reporting purposes.

We may also collect and categorize information about the content on Publisher pages integrated with Lupon Media Services and link this information to Personal Information collected through the delivery of Lupon Media Services. A Publisher may also choose to provide us with log-in credentials for accounts with third-party services such as online advertising providers, in order for Lupon Media to provide services such as reporting and analytics, based on information from those third-party services.

Publishers may choose not to provide us with certain Personal Information, but this may limit the features of the Lupon Media Services available for use.

Lupon Media may store cookies on your device:

For Publishers, to allow you to use and access secure areas of Lupon Media Services. Without these cookies, it is not possible to load or offer key functionalities, such as logging in to your account, displaying dynamic elements or uploading information.
For both Publishers and Readers, for statistical purposes and to analyze and improve the use and performance of Lupon Media Services and Site, and to do the same for our Publishers’ websites. We also use cookies for a better online experience, as cookies allow us to load or offer key functionalities on our Site, such as displaying dynamic elements or uploading information
For Readers, to support Lupon Media Services, such as for our analytics and data services and to provide Readers with Interest-based Advertising, including through Google’s Exchange Bidding service, and the ability to opt out of such advertising, all as further described in this Privacy Policy. We also use cookies for social media and multimedia functionalities, where videos and other media often rely on cookies to function correctly. In addition, social media platforms such as Facebook and Twitter can use cookies to see if you are logged in and enable you to “like” content or send it to your friends. When you use these features, such third-party companies can collect information from you. Depending on your settings, these external parties may also use such information for advertising purposes. If you would like to know more about this, please refer to the respective privacy policies of these third parties.

Web pixels are electronic images that may be used on Publisher website(s) or in emails sent in Publisher campaigns. We use tracking pixels to deliver cookies, count visits, understand usage and effectiveness of offers.

Information from Third-Party Sources

We may receive Non-Personal Information and/or Personal Information about you from other sources and combine it with the information that we collect through Lupon Media Services, or Site. Sources may include information conveyed to us by telephone or fax, information that we receive from third-party data providers, or information provided to us by third parties through the Lupon Media Publisher network.

How We Use Information

We use Personal- and Non-Personal Information collected through Lupon Media Services and Site to support our commercial interests (Interest-based Advertising, affiliate marketing, and data brokerage), internal business operations (such as improving the Services, fraud prevention and security), and business intelligence.

Commercial Interests

Commercial interests are activities that allow Lupon Media and/or our customers and business partners (such partners include data services and data resellers) to earn revenue.

Serve Interest-based Advertising to Readers. Options for opting-out of such advertising may be found in the “How to Opt-Out” section of this Privacy Policy.
Provide Lupon Media Services, or any other materials requested through the Site (such as electronic newsletters or promotional emails) to Publishers.
Personal Information may be categorized to create audience segments* with common interests, intent or other characteristics (does not include PII).
If a Publisher chooses to provide us with log-in credentials for accounts with third-party services such as online advertising providers, Lupon Media will use the credentials to access and provide requested services, such as reporting on Publisher use of those third-party services.
Respond to comments or complaints.
We may use Publisher contact information to invite you to take part in market research.
Provide Interest-based Advertising to Readers and support third parties’ interest-based advertising activities.

* We do not knowingly use information that comes from what we consider to be sensitive health information. We may use health-related segments that are inferred from data we collect but are not derived from sensitive health data.

We may also use political-affiliation segments that are inferred from data we collect but are not derived from specific voter registration information.

A list of the health-related and/or political-affiliation segments that may be used by our platform may be viewed on our Audience Segments page.

Internal Business Operations

Internal business operations are activities that allow us to meet obligations to Publishers, Readers, and third-party partners (including regulatory bodies). Internal business operations do not directly benefit any one person or entity.

Improve and protect our products, content, services and websites.
Lupon Media will use a Publisher’s payment account information to make payments as part of our Services, where applicable.
Where Publishers have provided us access to accounts with third-party services, Lupon Media may aggregate data obtained through this account access for our internal purposes to improve the Lupon Media Services.
We may monitor any Publisher account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law.
Compliance with applicable laws and to protect Lupon Media’s legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with law enforcement requests, legal process or litigation).

Business Intelligence

Business intelligence allows us to analyze and report on the performance of Lupon Media Services and Site, as that performance relates to Publisher campaigns.

Monitor the use of Lupon Media Services to support Publisher analytics and reporting.
Analytics. We work with third parties that collect data about Reader use of the Site and other websites or online services over time for non-advertising purposes. For example, we use Google Analytics and other third-party services to improve the performance of Lupon Media Services and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data, visit https://policies.google.com/technologies/partner-sites. Opt-out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.
As part of Lupon Media Services, we store and may display some of the Publisher information entered upon account creation, such as username (or display name) and bio, as well as network connections. In order to access and remove or modify this bio and display name, and/or other contact information that is not displayed, you may login to your Lupon Media account, select the “Account” option, and edit the contact details.

A Note on Non-Personal Information

We may collect Non-Personal Information through Lupon Media Services or we may create Non-Personal Information from Personal Information by removing identifying information (such as email address or device identifiers).

We may use Non-Personal Information for a variety of purposes to operate and improve the Lupon Media Services, such as testing our IT systems, analyzing usage patterns, market research, data analysis, and developing new products.

We may also use Non-Personal Information on Readers’ activities collected from Publisher websites (such as page views, use of ad blocking technology, and search queries) to provide aggregate information to Publishers so that they can improve their offerings.

We may use and disclose Non-Personal Information for any purpose in our discretion, to the extent permitted under applicable law. If we are required to treat Non-Personal Information as Personal Information under applicable law, then we may use or disclose it for all the purposes for which we use and disclose Personal Information.

Our Information Sharing Practices

Lupon Media shares the Personal Information collected through our Services and Site with the following:

Business Transitions: In the event Lupon Media goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets including in bankruptcy, Personal Information may be among the assets transferred.
Law Enforcement: We may disclose Personal Information if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect and defend the rights or property of Lupon Media, Publishers, or third parties.
Publishers: We may disclose Personal Information that identifies a device or browser to Publishers and their service providers in order to provide the Lupon Media Services, such as measuring the effectiveness of advertising, advertising attribution, and preventing advertising fraud.
Other Third-Party Customers: We may disclose Personal Information that identifies a device or browser to our third-party customers that include, for example, other advertising services and data enrichment services, who will use and disclose the information for their own purposes. We may also share Non-Personal Information such as aggregated reports derived in part from the information we have collected. The information we share may also be combined with third-party data to provide an even broader service to our customers. Please see How to Opt-Out for more information on choices related to this practice.
Service Providers: We may provide Personal Information to third-party service providers (processors) who work on behalf of or with us to provide the Lupon Media Services including to help us communicate with you. Examples of such services include our ability to send email, perform data analysis, provide marketing assistance, process payments (including credit card payments, through a third-party service), and provide customer service.

How to Opt-Out

Lupon Media supports various opt-out mechanisms, where each option provides different results related to targeted advertising. While using these mechanisms may prevent Interest-based Advertising or the sale of your Personal Information, there are no mechanisms for preventing advertising altogether.

Opting Out of Lupon Media’s Interest-based Advertising

Readers can choose to opt out of Lupon Media’s Interest-based Advertising activities on their browser(s) or device(s). For more information on how to opt-out of the sale of personal information, please see the section, “Exercising California Consumer Rights” located under “Information for California Consumers” in the “Country and State Specific Disclosures” section, below or our Privacy Center.

Your opt-out choice will apply to the browser or device where you make the choice. This means that Lupon Media will not deliver Interest-based Advertising to this browser or device and we will not otherwise use or transfer data collected on this browser or device for Interest-based Advertising.

Readers who wish to opt out of Lupon Media’s collection, use, or transfer of such data from a browser for Interest-based Advertising purposes can visit https://www.aboutads.info/ to learn more about Interest-based Advertising and to exercise opt-out choice with respect to Lupon Media and other companies participating in the DAA’s self-regulatory program.

Readers who wish to opt-out of Lupon Media’s collection, use, or transfer of such data from apps on a mobile device for Interest-based Advertising purposes can download the DAA’s AppChoices app.

When using DAA’s opt-out tools, choice will be effective only on the browser or device where choice has been exercised. If using a different device or browser, the opt-out choice(s) will need to be renewed for the new device or browser. Our opt-out tool for browsers is cookie-based, so that an opt-out choice can only be honored if a browser is set to accept third-party cookies. If the opt-out cookie is deleted, then the opt-out choice(s) must be renewed.

Opting out of Interest-based Advertising does not prevent data collection–we may continue to collect, use and transfer such data for other purposes such as contextual advertising based on a current visit to a website, fraud prevention, improving site performance and other purposes referred to in this Privacy Policy.

Opting out also will not stop advertising from appearing in a browser. After opting-out, Readers may receive advertising from Lupon Media Services when visiting websites of a Publisher who uses our Services, but that advertising will not be interest-based. After opting out of Lupon Media’s Interest-based Advertising, Readers may also continue to receive Interest-based Advertising through other companies.

Using ‘Do Not Track’ Signals

Lupon Media Services are designed to respect ‘Do Not Track’ (or “DNT”) signals from your browser, such as ad blockers.

Opting Out of Lupon Media Marketing

Unsubscribe instructions will accompany each promotional email we send. Alternatively, contact us directly to change promotional email preferences at [email protected].

Regardless of your promotional communication preferences, we will send Publishers messages related to our business relationship or transactions.

For any questions regarding a Lupon Media Publisher account, please contact [email protected].

Children’s Privacy

Lupon Media does not knowingly collect personal information from or direct Lupon Media Services to children under the age of 16.

Data Retention

Publishers:

We will keep Publishers’ Personal Information according to the terms and conditions of our business relationship. This includes maintaining Publishers’ Personal Information after our relationship ends to protect ourselves from legal claims, to comply with law, or to administer our business.

Readers:

Personal Information collected about Readers through Lupon Media Services is generally retained for a maximum of eighteen months. However, laws, legal claims or other particular circumstances may require us to keep certain Personal Information longer.

Non-Personal Information:

We may retain Non-Personal Information for our business purposes, at our discretion or as permitted by law.

Security

Lupon Media has put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect.

Country and US State Specific Disclosures

Various data privacy laws require specific disclosures regarding the use of your personal information. These disclosures are meant to supplement, and are consistent with, the practices described in this Privacy Policy.

Information for Residents of European and UK Countries: Data Subject Rights

If located in the European Union, Switzerland, Norway, Lichetenstein, Iceland, or the United Kingdom (the “European and UK Countries”), individuals have certain rights and protections under applicable law regarding the processing of Personal Information.

Role of Lupon Media as a Controller or Processor

If located in one of the European and UK Countries, Lupon Media may act as a “controller” as defined under applicable law when processing Personal Information. Lupon Media may also act as a “processor” as defined under applicable law to the extent that we process Personal Information on behalf of and at the instruction of another party, for example a Lupon Media client.

Legal Basis for Processing

Lupon Media’s legal basis for processing Personal Information depends upon the specific context in which it is collected or used. We rely on data subject consent (as defined under applicable law) to process Personal Information for Interest-Based Advertising, which we require Publishers using Lupon Media Services to obtain on our behalf. In some cases, we may rely on our legitimate interests to collect and use Personal Information, except where our interests are overridden by data-protection interests or fundamental rights and freedoms. For example, we will process Personal Information collected from Interest-Based Advertising in order to improve the Lupon Media Services for our Publishers. Additionally, we may have a legal obligation to process Personal Information (such as for fraud prevention).

Exercising Data Subject Rights

Individuals may be entitled to exercise certain data subject rights available under applicable laws. These rights may include the right to request access to Personal Information we hold. Individuals may also have the right to object to, or request that we restrict, processing of Personal Information, such as profiling we perform for the purposes of direct marketing and interest-based advertising. Individuals may also have the right to ask that your Personal Information be corrected, erased, or transferred to another party. Where we have asked for consent to process data, consent may be withdrawn.

Anyone afforded any of these rights may exercise them by contacting [email protected].

These rights may be limited in some situations–for example, where we can demonstrate that we have a legal requirement to process data. In some instances, this may mean that we are able to retain data even if consent is withdrawn. In other instances, we may provide the requested information with some portions redacted in order to adhere to obligations of confidentiality to others.

Where we require Personal Information to comply with legal or contractual obligations, provision of Personal Information is mandatory; in all other cases, provision of requested Personal Information is optional.

Data Transfers

Lupon Media is a global company headquartered in UAE, Fujairah, with data centers located in Europe and the United States. By visiting Publisher’s sites who are using Lupon Media Services, Personal Information may be transferred to, stored, and processed by us, our affiliates, and by those third parties with whom we may share your information, some of which are located outside of the European and UK Countries.

These countries (including the United States) may have data protection or other laws that differ from those in European and UK Countries. We ensure that where Lupon Media or third-party service providers receive Personal Information outside of the European and UK Countries, appropriate safeguards are in place under European and UK data protection legislation.

Lupon Media may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

IAB Europe Transparency and Consent Framework

Lupon Media supports and encourages our clients to use the IAB Europe Transparency and Consent Framework (the “IAB Industry Framework”) to provide data subjects with dynamic transparency into and choice about the various vendors our clients use to serve ads, including Lupon Media Services. When visiting a website, the IAB Industry Framework is designed to allow a Publisher the means to choose which registered vendors they wish to allow to access a device and process Personal Information, and provide dynamic transparency and choice about each of these vendors (either an opportunity for an individual to consent to the vendor or opt out of data processing by the vendor, depending on that vendor’s legal basis and processing activities).

Questions or Complaints

Individuals located in one of the European and UK Countries who have questions or concerns about how we process Personal Information may contact our Data Protection Officer at [email protected]. If we are not able to resolve the issue, individuals have the right to lodge a complaint with their local data privacy authority. For contact details of local Data Protection Authorities, please visit the European Data Protection Board member list.

IT Governance Europe Limited acts as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, please email [email protected] Please ensure to include our company name (“Lupon Media”) in any correspondence.

Information for California Consumers: Privacy Rights

This section contains disclosures for Readers required by the California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.). This section applies to the collection, use, and disclosure of “personal information” collected from California “consumers” (as those terms are defined by the CCPA) that are subject to the CCPA. (Publisher personal information is not “sold” under the CCPA and is otherwise exempt from the CCPA at this time.)

Personal Information We Collect, Disclose for a Business Purpose, and Sell

As described in this Privacy Policy, Lupon Media collects, discloses and sells consumer personal information for our commercial and business purposes (as defined by the CCPA). The following outlines each practice in more detail by providing the categories of personal information collected, disclosed, or sold in the previous 12 months. To request information on specific pieces of personal information we may hold about a California consumer, please follow the instructions provided in the Exercising California Consumer Rights section below.

Personal Information we collect about consumers, and from Publishers, service providers, affiliates not under the Lupon Media brand, or consumer data resellers:

Online identifiers
Commercial information (such as records of personal property or products or services purchased, obtained or considered)
Internet or other electronic network activity (such as browsing history, search history, interactions with a website, email, application, or advertisement)
Geolocation information
Professional or employment-related information

Personal information we disclose for business purposes in performing Lupon Media Services:

Online identifiers
Commercial information (such as records of personal property or products or services purchased, obtained or considered)
Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)
Geolocation information
Professional or employment-related information

We disclose each category of personal information identified above to the following categories of recipients: service providers; affiliates not under the Lupon Media brand; and advertising networks and other partners (such as Demand Side Platforms (DSPs) who buy ad space from Publishers).

Personal Information we sell to third parties:

Online identifiers
Characteristics of protected classifications under California or federal law (such as demographic information like age, gender, and race)
Commercial information (such as records of personal property or products or services purchased, obtained or considered)
Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)
Geolocation information
Professional or employment-related information
Inferences drawn from the above information about your predicted characteristics and preferences

We sell each category of personal information identified above to the following categories of recipients: advertising/marketing companies; advertising networks; marketing data companies; data analytics providers; social networks; consumer data resellers; and publishing product companies.

California consumers may opt-out of the sale of their personal information at any time. Please see “Exercising California Consumer Rights” below for more information.

We use and disclose the personal information we collect for our commercial and business purposes (as defined by the CCPA), as further described in this Privacy Policy. These commercial and business purposes include, without limitation:

Providing Interest-based Advertising for and to Consumers; providing our Services to our Publishers as described in this Policy; and marketing our Services.
Auditing related to our interactions with Publishers;
Legal compliance;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging;
Performing services (either by us or our service providers, as that term is defined by the CCPA) such as account servicing, processing orders and payments, and analytics;
Internal research for technological improvement;
Internal operations;
Activities to maintain and improve our services; and
Other one-time uses.

Lupon Media does not knowingly sell the personal information of minors under 16 years of age.

Exercising California Consumer Rights

California consumers have certain rights with respect to the personal information collected by businesses. California consumers may exercise the following rights regarding personal information, subject to certain exceptions and limitations:

The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell, the categories of sources from which we collected personal information, our purposes for collecting or selling personal information, the categories of personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
The right to request that we delete the personal information that we have collected or maintain;
The right to opt out of our sale(s) of personal information. Please note that, when opting out of certain types of sales, we will be unable to provide the services that rely on such sales.
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us [email protected] providing the requested information.

Verification Process and Required Information

We may require additional information to verify a consumer’s identity or understand the scope of the request, depending on how we are contacted. We will only ask for information needed to verify a consumer’s identity, such as a different email address, mobile identifier, or cookie ID.

Authorized Agent

Consumers may designate an authorized agent to exercise California data rights under the CCPA on your behalf by (i) verifying the consumer’s identity and (ii) providing evidence of the consumer’s written permission authorizing an agent to make a request on their behalf.

Changes in this Privacy Policy

We may modify or amend this Privacy Policy from time to time at our discretion. When we make material changes to this Privacy Policy, we will amend the revision date at the top of this page and such modified or amended Privacy Policy shall be effective as to the Personal Information governed by this Privacy Policy as of that revision date. We encourage periodic review of this Privacy Policy to view any updates, as well as the revision log found at the end of this page.

Contact Us

Please contact us at [email protected] with questions or concerns regarding our Privacy Policy or how we process your data.

Lupon Media will respond in good faith to all privacy inquiries but may not be able to provide complete information if the request requires Lupon Media to release confidential information of third parties, or otherwise imposes an undue burden or expense.

Lupon Media - U.A.E Headquarters

Creative Tower

Fujairah

Revision Log

Section	Revision summary	Version
Entire Policy	Consolidated Website and Service Privacy Policies, reordered sections, and updated internal links.	March, 2022
Information We Collect	Added ‘Universal ID’ to the list of Personal Information types	Juny, 2020