PRIVACY POLICY

Last Updated: January 15, 2026

1. INTRODUCTION AND SCOPE

This Privacy Policy describes how Carty Nexus Inc ("Carty", "we", "us", or "our") collects, uses, and shares information when you interact with our advertising services (the "Services").

l  Applicability: This policy applies to (i) our business partners and Developers who integrate our SDK into their mobile applications ("Apps") ; and (ii) the end-users of such Apps ("End-Users").

l  Our Role: For the purposes of global data protection laws (such as GDPR), Carty generally acts as an Independent Data Controller. This means we determine the purposes and means of processing personal data to deliver, optimize, and secure our advertising network.

l  Developer Responsibility: Developers are responsible for providing clear notice and obtaining valid consent from End-Users before transmitting data to Carty.

2. INFORMATION WE COLLECT

l  Device and Technical Information: We collect hardware specifications including device manufacturer, brand, model, OS type/version, kernel version, screen resolution, orientation, DPI, memory size, CPU model, system settings (e.g., language, country and timezone), and User Agent (UA).

l  Identifiers: We collect IDFA, IFDV, GAID, User IDs, and Limit Ad Tracking (LAT) status.

l  Application Environment: We collect App package name, version, installation time, installation channel and sub-channel, App foreground/background status, crash data, and running process information (Android only, for anti-fraud purposes).

l  Network and Connectivity: We collect IP addresses (for city/country level location), Wi-Fi status, network type and mobile carrier information.

l  Consent Signals: We collect IAB TCF strings, which encode your privacy choices and consent status as defined by the IAB Europe Transparency and Consent Framework.

l  Event and Interaction Data (Optional): Depending on the specific Services integrated by the Developer, we may receive certain event data shared by the Developer at its discretion. This includes: demographic indicators (such as age and gender), and in-app purchase telemetry (such as amount, currency, and frequency). This information is used solely for ad targeting, conversion attribution, and performance analytics; we do not collect or store any sensitive financial credentials or real-world identities.. Please refer to the applicable Publisher’s privacy policy for more information about their usage of the above data.

3. HOW WE USE INFORMATION

l  Ad Targeting and Profiling: We use demographic and in-app purchase data to create audience segments and deliver personalized advertisements based on user interests.

l  Traffic Segmentation: We analyze App-level data (e.g., package names and versions) to categorize traffic and assist advertisers in reaching specific App categories.

l  Security and Stability: We use network and device information to monitor the stability of our Services and detect/prevent Invalid Traffic (IVT) through running process analysis and IP filtering.

l  Service Integrity and Ad Quality: We use interaction data to monitor the quality of ad creatives and ensure they do not contain malware, offensive content, or violate our advertising standards.

l  Research and Analytics: We create aggregated, anonymous data sets for industry benchmarking, market trend analysis, and improving our predictive machine-learning models. Once anonymized, this data does not identify you and is no longer subject to this Policy.

4. INFORMATION SHARING AND DISCLOSURE

We do not sell End-User personal data. We share information only with the following categories of recipients for the purposes described in Section 3:

l  Upstream Advertising Partners: We disclose necessary device identifiers and interaction data to Demand Side Platforms (DSPs), Ad Exchanges, and Advertisers to enable them to bid on ad inventory and serve ads.

l  Service Providers: We share data with trusted third-party vendors who provide services such as anti-fraud detection, cloud hosting, and data analytics. These providers are contractually obligated to protect your data.

l  Affiliates: We may share information with our corporate affiliates to improve our global service delivery.

l  Legal Requirements and Safety: We may disclose information if required by law (e.g., a court order or subpoena) or to protect the rights, property, and safety of Carty, our Developers, or End-Users.

5. INTERNATIONAL DATA TRANSFERS

Carty Nexus Inc is headquartered in the United States. Information collected through our Services will be transferred to and processed in the U.S. and other countries where our servers or service providers are located.

Legal Safeguards: For data transfers from the European Economic Area (EEA), UK, or Switzerland to countries not deemed to provide an adequate level of data protection, we rely on the Standard Contractual Clauses (SCCs) approved by the European Commission.

Developer Obligation: By using our Services, Developers agree to ensure that their data transfer to Carty complies with applicable laws, typically by incorporating our Data Processing Addendum (DPA) which includes these SCCs.

6. DATA RETENTION

We retain personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

l  Operational Data: Information used for ad delivery and attribution is typically retained in an identifiable form for up to 12 to 24 months to facilitate billing and reconciliation.

l  Anti-Fraud Data: Data processed for security and fraud prevention may be retained for longer periods to identify historical fraud patterns and protect our network.

l  Anonymization: After the retention period expires, we either delete the data or permanently anonymize it so that it can no longer be associated with a specific device or individual.

7. END-USER RIGHTS AND CHOICES

Depending on your jurisdiction (e.g., European Economic Area, United Kingdom, or California), you may have the following rights regarding your personal data:

l  Access and Portability: The right to request a copy of the personal data we hold about you.

l  Deletion (Right to be Forgotten): The right to request that we delete your personal data, subject to certain legal exceptions (e.g., fraud prevention or billing reconciliation).

l  Opt-out of Targeted Advertising: You can limit or opt-out of personalized advertising through your device settings:
iOS: Enable "Limit Ad Tracking" or "Ask App Not to Track."
Android: Enable "Opt out of Ads Personalization" or "Reset Advertising ID."

l  California Privacy Rights (CCPA/CPRA): If you are a California resident, you have the right to opt-out of the "sharing" of your personal information for cross-context behavioral advertising. Carty does not "sell" your personal information in exchange for monetary compensation.

l  Exercise of Rights: To exercise any of these rights, please contact us at ssp_support@carty.io.

8. CHILDREN’S PRIVACY

Carty is committed to protecting the privacy of children.

l  COPPA Compliance: We do not knowingly collect "personal information" (as defined by the U.S. Children’s Online Privacy Protection Act) from children under the age of 13 without verifiable parental consent.

l  Child-Directed Apps: For Apps designated by the Developer as "Child-Directed," the Carty SDK will automatically:
Disable the collection of persistent identifiers for behavioral targeting.
Serve only non-personalized, contextual advertisements.

l  Developer Duty: It is the Developer's sole responsibility to accurately flag Apps directed to children via the Carty SDK or Dashboard.

9. SPECIAL INSTRUCTIONS FOR DEVELOPERS

To ensure the lawful operation of our Services, Developers must:

l  Privacy Policy Disclosure: Maintain a privacy policy that accurately describes the collection and sharing of data with third-party advertising partners like Carty.

l  Consent Signals: For users in regions requiring opt-in consent (e.g., GDPR/TCF), Developers must accurately transmit the user's consent status to the Carty SDK. Carty relies on these signals to process data.

10. CONTACT US

For any privacy-related inquiries or to report a data breach, please contact us at ssp_support@carty.io.