Goldfish Ads Services Privacy Policy

What do our Services do?

Our Services help our clients identify where and when to place advertisements on mobile and digital out-of-home ("DOOH") media and then measure the effectiveness of that advertising.

Definitions of Personal Data

At Goldfish Ads, we act as a Business-to-Business (B2B) software provider. Because of this, it is important to distinguish between the business data required to run our platform and consumer data.

"Personal Information" (or Personal Data) refers to any information that identifies, relates to, or could reasonably be linked to an individual person.

What We Do NOT Collect

We do not collect, process, or store consumer-level Personal Information as part of our core advertising and measurement Services. Specifically, we do not collect:

• Consumer names, email addresses, or phone numbers.
• Mobile advertising identifiers (e.g., Apple IDFA or Android Ad ID).
• Raw or individual-level device location histories.

What We DO Collect (B2B Data)

The only Personal Information we collect is strictly related to our B2B clients and website visitors. This includes:

• Account Information: Names, business email addresses, job titles, and billing details of the individuals authorized to log into and use our platform.
• Platform Usage Data: Browser types, IP addresses, and interaction metrics collected via our analytics provider (Amplitude) to help us maintain and improve our software.
• Client-Uploaded Data: Clients may upload their own first-party data into our platform for campaign planning. We mandate that all such data be strictly pre-aggregated (e.g., scoring metrics at the zip-code level) and completely de-identified. Client-uploaded data is not considered Personal Information under this policy.

User Choice and Opt-Out Mechanisms

Because our platform relies entirely on pre-aggregated, de-identified data for campaign planning, we do not track individual consumers across mobile devices or applications. Therefore, consumer-level advertising opt-outs do not apply to our core Services.

However, for visitors to our website and B2B clients using our platform, we offer the following choices regarding your data:

1. Platform Analytics (Amplitude) and Cookies

We use Amplitude to track how our clients use our SaaS platform. If you are a client or website visitor and wish to limit this tracking, you can:

• Adjust your web browser settings to block or delete cookies.
• Use browser extensions designed to block analytics scripts.

Please note that blocking cookies may impact the functionality of our platform and website.

2. Marketing Communications

If you receive marketing or promotional emails from Goldfish Ads, you may opt out at any time by clicking the "Unsubscribe" link located at the bottom of the email, or by contacting us directly.

How We Share Information (Data Sharing Guardrails)

We know that the campaign and planning data you bring to Goldfish Ads is proprietary and highly sensitive. We do not sell your Personal Information or your uploaded campaign data, nor do we share your proprietary data with other clients or competing ad networks.

We only share information in the following limited circumstances:

1. Essential Service Providers

We share B2B account information and platform usage data with trusted third-party service providers who act on our behalf to help us operate our business. This includes:

• Cloud hosting and data storage providers.
• Analytics providers (such as Amplitude) to monitor platform health and usage.
• Customer support and CRM tools.

These providers are bound by strict confidentiality agreements and are prohibited from using your data for any purpose other than providing services to Goldfish Ads.

2. Legal Compliance and Protection

We may disclose information if we believe in good faith that it is necessary to:

• Comply with a legal obligation, such as a subpoena, court order, or lawful request from government authorities.
• Protect and defend the rights, property, or safety of Goldfish Ads, our clients, or the public.
• Investigate or prevent fraud, security breaches, or other illegal activities.

3. Business Transfers

If Goldfish Ads is involved in a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of its assets, your B2B account information and platform data may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your data.

State and International Privacy Rights

Even though Goldfish Ads operates as a B2B software platform and does not collect consumer tracking data, privacy laws such as the California Consumer Privacy Act (CCPA), the EU/UK General Data Protection Regulation (GDPR), and other global frameworks grant specific rights to individuals acting in a business capacity (such as our clients and website visitors).

Depending on your jurisdiction, you may have the following rights regarding the B2B Personal Information (like your name, work email, and platform usage data) that we hold:

1. Your Data Privacy Rights

• Right to Access/Know: You have the right to request a copy of the Personal Information we have collected about you, our business purpose for collecting it, and the categories of third parties with whom we shared it.
• Right to Correction (Rectification): You have the right to request that we correct any inaccurate or incomplete Personal Information we hold about you.
• Right to Deletion (Erasure): You have the right to request that we delete your Personal Information, subject to certain legal exceptions (such as data required to complete a transaction, comply with legal obligations, or maintain platform security).
• Right to Opt-Out of Sale or Sharing: Under laws like the CCPA, you have the right to direct a business not to sell or share your Personal Information. Goldfish Ads does not sell or share your B2B Personal Information or client-uploaded campaign data.
• Right to Non-Discrimination: We will not discriminate against you (e.g., by denying services or altering pricing) for exercising any of your privacy rights.

Note: Some US state privacy laws (such as the Virginia Consumer Data Protection Act, or VCDPA) explicitly exempt B2B data. However, we strive to honor reasonable privacy requests from all our B2B clients regardless of their state of residence.

2. Additional Information for EU/UK Residents (GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your B2B Personal Information under the following lawful bases:

• Performance of a Contract: To provide our SaaS platform and fulfill our obligations to you or your company.
• Legitimate Interests: To improve our platform via analytics, secure our systems, and communicate with you about our Services.
• Data Processor vs. Data Controller: When a client uploads pre-aggregated, de-identified campaign data into our platform, the client acts as the "Data Controller" and Goldfish Ads acts purely as a "Data Processor." When we collect your account login details to grant you access to the platform, we act as the Data Controller of that specific B2B contact information.

3. How to Exercise Your Rights

To exercise any of the rights listed above, please contact our privacy team by email at: privacy@goldfishads.com

We will verify your request by matching the identifying information you provide (such as your work email address) with the information we maintain in our systems. We will respond to your request within the timeframes required by applicable law.

Security

We implement standard security safeguards designed to protect your information. However, no data transmission or storage system is completely secure, and we cannot guarantee the security of your information.

Modifications to this policy

We may update this policy from time to time. When we make changes, we will update the "Last updated" date at the top of this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us at privacy@goldfishads.com