Lacuna

PRIVACY POLICY

Effective date: July 28, 2026

Introduction

Welcome to Lacuna Infinite State Pte. Ltd. (“Lacuna”, "we", "our" or "us"), having its principal office and place of business at 6A Shenton Way #05-02 Downtown Gallery Singapore 068815, provides advertising technology that enables websites, apps, and other internet-connected digital properties to generate revenue by displaying advertisements to their users, via our advertising platform (the “Platform”) and related advertising tools (e.g., Lacuna Product, collectively the “Ad Services”).

This Privacy Policy (“Policy”) covers the information that we may process about the individuals (“End Users”, “consumers” or “you”) who access websites, apps, or other digital properties that are being monetized through our Ad Services and information submitted by individuals (“you”) via our corporate website accessible at lacunads.com or any other corporate official websites (“Lacuna Websites”).

Depending on the specific scenario, Lacuna may act either as a data controller or a data processor when handling your Personal Information. We act as an independent data controller where we autonomously determine the purposes and means of processing Personal Data, including building user profiles, conducting bid optimization and implementing algorithmic strategies to operate our advertising services. By contrast, we act as a data processor when processing Personal Information solely on behalf of our clients or business partners to deliver our services. When you visit Lacuna Websites, Lacuna acts as an independent data controller with respect to the personal information we collect, and such processing activities are described separately in “Privacy Practices for Lacuna’s Websites” of this Policy.

We acknowledge the importance of maintaining the confidentiality of users’ personal information in today’s digital ecosystem. We are dedicated to the protection of your privacy, and we process your personal information transparently, responsibly and respectfully. For this purpose, We hereby provide this Privacy Policy to explain how we collect, use, and share your personal information and how you can exercise the privacy rights available to you, as described in this Policy.

1. Privacy Practices for Lacuna Ad Services

1.1 Data that we collect

Our Platform allows publishers to make space available on their Digital Properties available for purchase and allows media buyers to purchase the opportunity to display an Ad on a digital property. We do not interact directly with End Users when providing services. Our clients, including ad exchange platforms and supply-side platforms, may share user information with us upon sending ad requests to our demand-side platforms. Our advertisers or their third-party attribution platforms may also share user information with us.

The categories of data we may receive include the following:

  • Mobile advertising identifiers, such as iOS IDFAs and Google Advertising IDs, IDFV and other identifiers that may be associated with an End Users' device, including identifiers provided by Clients or their service provider;
  • Network information, such as carrier, network type;
  • Location information, such as IP, Country, city, and general geographical location from which an End User is viewing an advertisement;
  • Device information such as device model, mobile browser, operating system, system language and region, bundle information of the apps where advertisements are displayed;
  • information about end user engagement with ads, such as end user behavior on digital properties, Web browsing history from advertising impressions, information that you have viewed or clicked an ad.
  • other information transferred by the advertisers or their attribution measurement partners, ad exchange platform or supply-side platform, required for ad delivery, attribution calculation and reporting, subject to detailed stipulations in our partner agreements.

We DO NOT collect sensitive information, such as insurance plan numbers, financial account numbers, or information about medical conditions.

1.2 How we use the data collected through Ads Services

The Ad Services processes the data we collect for advertising purposes, including：

  • Customized Ad delivery. The collection and processing of information about your use of this Ads service to subsequently personalize advertising and/or content for you in other contexts, such as on other websites or apps, over time. Typically, the content of the site or app is used to make inferences about your interests, which inform future selection of advertising and/or content. You have the right to object at any time to the processing of your data for the above-mentioned interest profiling and targeted advertising purposes. You may exercise this right by using the methods described in the "Opt-out Options" section below. Upon your objection, we will cease processing your data for such advertising purposes.
  • Information storage and access. The storage of information, or access to information that is already stored, on your device such as advertising identifiers, device identifiers, cookies, and similar technologies.
  • Selecting, delivering, and reporting ads. The collection of information, and combination with previously collected information, to select and deliver advertisements for you, and to measure the delivery and effectiveness of such advertisements.
  • Limiting the number of times, you see an ad, so you don’t see the same ad or type of ad too many times.
  • Provide Clients analytical statistics regarding ad inventory sourced from our advertising solutions.
  • Detect and defend against technical failures and prevent malicious, fraudulent or illegal activity.
  • Offer customer, technical and operational support for our ad platform.
  • Settle disputes and enforce our terms of service and proprietary rights.
  • Improving our Ad Services.

If you are located within the European Economic Area, we may process your personal information, where necessary, based on the legitimate interests ground under the GDPR. Our legitimate interests include monitoring and preventing fraudulent conduct, resolving technical operational issues, and maintaining the overall stability, security and proper operation of our systems and workflows.

Consent for the collection and use of personal information is obtained through our business partners, including mobile app developers, website developers and advertisers. To comply with applicable legal requirements, our agreements with partners oblige them to guarantee lawful data sources. Partners must inform End Users about our personal information processing activities in compliance with applicable laws, secure valid consent (separate consent shall be acquired if legally required), and ensure users may withdraw consent at any moment.

1.3 How we share the data collected through Ads Services

We may share data that we collect with:

  • Advertisers, advertising agencies, ad attribution service providers and demand-side advertising platforms to carry out ad attribution and settlement, monitor ad delivery quality, and support precise targeting;
  • Media buyers to allow publishers to offer advertising inventory in their Digital Properties to media buyers to bid on and fill that inventory with relevant ads.
  • Clients and business partners to help them improve the effectiveness of their and their client’s ads.
  • Service providers for those service providers to perform business functions for us or on our behalf.
  • Our affiliate companies, joint venture partners, and other partners or collaborators for the purposes of processing, analyzing, or storing your information or otherwise as needed to provide the services to you or achieve other purposes for which we collect information, in each case, consistent with the terms of this Policy.
  • Law enforcement agencies, courts, other government authorities (whether in your jurisdiction or abroad) or other third parties where we or any of our affiliates believe it's necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
  • Potential transaction partners, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer you and your End Users’ personal data to use it in a manner consistent with this Policy.

We entrust the cloud service providers to handle advertising requests, maintain stable and secure operation of our systems and workflows, and facilitate data storage.

Except as explicitly set forth in this Policy, we will not disclose users’ personal information to any third parties without obtaining users’ consent. We contractually require our business partners who have direct contact with End Users to notify users of such third-party information and secure separate consent from users.

2. Privacy Practices for Lacuna Websites

2.1 Data we collect from Lacuna Websites visitors

When you visit Lacuna Websites, Lacuna is the data controller of your personal information. We collect the following personal information during your visits: Information you voluntarily submit to us via our official Lacuna Websites, including data entered through our online contact forms, such as your full name, corporate name, email address, and the textual content of your inquiries. You may additionally share business-related details or personal information pertaining to other third parties with us at your discretion.

We refrain from utilizing cookies, local storage, tracking pixels and similar tracking mechanisms across our official website, and no personal data or device-specific information will be automatically captured solely from your general website browsing activity. Should we deploy cookies or other tracking technologies in the future, we will update this Policy and furnish legally required notices and consent options.

2.2 How we use information collect through Lacuna Websites

We process website visitor data to fulfill your requests, address business consultations and customer service inquiries, verify the identities of business partners, and serve other purposes requested by you. Such data will not be utilized for ADX ad bidding or personalized advertising delivery. Where requested by you, we may send you information regarding our advertising services, including marketing communications.

2.3 How we share information we collect through Lacuna Websites

We may disclose website-collected information under the following circumstances:

  • With your consent, consistent with this Policy;
  • To our affiliated companies;
  • To third-party service providers supporting our operations, including technical support, customer service, marketing and operational vendors;
  • In connection with corporate transactions such as mergers, acquisitions, divestments, investment, change of control, asset transfer, restructuring, bankruptcy or related pre-transaction due diligence;
  • To comply with mandatory legal obligations or formal legal demands and cooperate with government and law enforcement authorities for national security and regulatory purposes;
  • Where disclosure is needed to avert potential physical, financial or other harm, loss or injury;
  • To safeguard our legitimate interests, rights, property or safety, or those of any individual or third party, or to investigate suspected or confirmed illegal conduct.

3. Data Storage and Transfer

The data we collect stored in Singapore, Germany, or the United States. As set forth in this Policy, your personal information may be transferred to and stored in jurisdictions outside the country where you use our Services to fulfill the purposes described herein.

For users located in the United States, we adhere to the Data Security Practices and all applicable U.S. laws and regulations, and will not unlawfully transfer, share, or otherwise disclose your personal information.

If you are located within the European Economic Area (“EEA”), the personal information we collect from you may be transferred to, or remotely accessed by, recipients located outside the EEA. Such recipient countries may not have received an adequacy decision from the European Commission and may not offer an equivalent level of data protection. We implement legally required safeguards to ensure adequate protection of your personal data during such cross-border transfers. Where required by applicable law, our Business Partners will obtain your valid consent to facilitate the transfer of your personal information to overseas recipients, including our affiliates and other third parties. You may withdraw your previously provided consent at any time.

4. Your Data Protection Rights

You may have the following rights, subject to applicable law:

  • Access: request a copy of your data and information relating to how it is processed.
  • Rectify request any inaccuracies in the data we hold about you be corrected.
  • Erase: request that we erase your data from our records.
  • Restrict: request that your data is no longer processed by us to the full extent set out in this Policy.
  • Object: object to certain ways that we process your data.
  • Transfer: request that your data be shared with a third party.
  • Withdraw consent: where we are relying on the consent to process your data, then you can withdraw the consent at any time.

If you are a resident of the European Economic Area (EEA) or the UK, you may also have the following rights:

  • The right to object to processing your personal data, restrict processing of your personal data, or request portability of your personal data.
  • The right to complain to a data protection authority about our collection and use of your personal data.

If you are a resident of California, United States, you may request disclosure of the following information regarding our collection and use of your personal information within the preceding 12 months:

  • the categories of personal information we have collected about you;
  • the categories of sources from which we collected such personal information;
  • the business and commercial purposes for collecting, selling, or sharing your personal information; the categories of third parties to whom we have disclosed your personal information;
  • the specific categories of personal information that we have sold, shared, or disclosed for business purposes;
  • and the categories of third parties that received your personal information for our business purposes.

You can submit a request under your right of access to receive a copy of the personal information we have collected about you over the last 12 months. You may also make a deletion request to ask us to erase your personal data. In addition, you can ask us to correct any inaccurate personal information we store, pursuant to your right of correction.

You may exercise your rights to personal information as described above by sending email to us. You may need to provide us with additional information to enable us to identify the personal data we hold about you and ensure that we accurately fulfill your request, because most of the information we store can only identify a particular browser or device and cannot directly identify you personally.

5. Opt-out Options

You may manage or limit interest-based personalized advertising through a range of system, app and browser privacy controls, though the availability of such options may differ depending on your device type, system version and software features.

Android devices may provide an “Opt out of Ads Personalization” setting in Google Settings or the device's privacy menu. Where this feature is available and enabled, we will generally refrain from using data collected from that device to develop user interest profiles or serve interest-based advertisements.

IOS devices running version 14.5 or above may allow you to restrict tracking via the “Ask App Not to Track” option, accessible through in-app prompts or system privacy settings. If you enable this restriction, our ability to access your advertising identifiers and deliver personalized ads based on inferred interests may be limited.

You may also adjust your personalized advertising preferences within the privacy settings of individual installed applications, where such controls are made available.

In addition, your mobile browser may support a “Do Not Track” preference. When this setting is turned on, we will not use browsing activity data from that browser to infer user interests or serve targeted advertising.

Any opt-out preference you enable may correspondingly restrict our personalized advertising activities applicable to your device or browser.

6. Data Security

The security of information is our utmost priority. We use strict organizational, technical, administrative, and physical safeguards to protect the personal data we collect and process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data. We evaluate these measures on a regular basis to ensure the security of the processing. However, as no system is 100% secure, we make no guarantees on the safety or security of any data transmitted to or from our site or through our services.

The inclusion of a link through the Ad Services does not imply endorsement of the linked site or service by us. We are not responsible for, the privacy, information, or other practices of any third parties, including our vendors or any other third party operating any site or service to which the Ad Services link.

We are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations (e.g., app developers, app providers, social media platform providers, operating system providers, wireless service providers or device manufacturers), including any personal data you disclose to other organizations through or in connection with the Ad Services.

We ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership) on or through Ad Services or otherwise to us.

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.

7. Data Retention

We will retain personal data for the period necessary to fulfill the purposes outlined in the Policy and where we have ongoing legitimate business needs to do so (for example, to provide Ad Services, to comply with applicable legal).

After our relationship has ended, we retain the information as long as required by law. We may also retain records to investigate or defend against potential legal claims, deal with any complaints or official enquiries or investigations regarding the Services or maintain business records for analysis and/or audit purposes.

If we de-identify information we collect through the Ad Services, we may retain that information, in an aggregated format. In such cases, we commit to not re-identifying the information.

8. Children’s Information

Our products and services are not designed nor intended for anyone aged below 13 years (or user who is deemed as minor under applicable law). We do not intentionally collect information from anyone under the age of 13 (or such legally required age of consent as defined under applicable laws).

If we are notified that we have collect personal data from a child of or under the age of 13 (or such legally required age of consent as defined under applicable laws), we will administer all reasonable efforts to locate and delete that information from our records.

9. Privacy Policy Updates

We will review and update this Policy periodically and will note the date of its most recent revision at the top of this Policy. We reserve the right to change, modify, add or remove any portion of this policy, therefore we encourage you to visit this page from time to time to review any changes.

10. Contact Us

If you have questions or concerns about the Policy or our privacy practices, please contact us at: contact@lacunads.com.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.

Please note that email communications are not always secure, so please do not include sensitive information in your emails to us.