Last Updated: 2026-06-10

Royalada Privacy Policy

1. Introduction

Royalada provides customer acquisition, advertising, lead generation, and customer engagement services that help businesses attract visitors, turn them into customers, and continue engaging with them through consent-based advertising and communications.

This Privacy Policy explains how Royalada collects, uses, shares, stores, and protects personal information when providing its services, operating its websites, and interacting with customers, business partners, publishers, advertisers, and individuals who engage with content delivered through our services.

We are committed to protecting personal information and processing it responsibly, transparently, and in accordance with applicable privacy and data protection laws, including the General Data Protection Regulation (GDPR), the UK GDPR, applicable United States privacy laws, and other relevant legal requirements where our services are offered. Please read this Privacy Policy carefully to understand how we process personal information, what rights you have, and how you can exercise those rights.

Simply put: We help businesses attract visitors, turn them into customers, and continue engaging with them through consent-based advertising and communications. This Privacy Policy explains what personal information we process, why we process it, and how we protect it.

2. Who We Are

Royalada LLC (“Royalada”, “we”, “our”, or “us”) provides customer acquisition, advertising, lead generation, and customer engagement services to businesses worldwide.

Our services help businesses deliver advertisements, generate customer leads, communicate with their audiences, and measure the effectiveness of their campaigns across digital channels. Royalada provides these services directly to its customers and business partners. Depending on the specific service, agreement, and processing activity, Royalada may act as a Data Controller, Joint Controller, or Data Processor under applicable privacy laws. More information about these roles is provided in the “Data Controller and Data Processor” section of this Privacy Policy.

If you have any questions about this Privacy Policy or how your personal information is processed, you can contact us using the details below: Royalada LLC, Dragise Misovica 163A, 32000, Cacak, Serbia. Email: [email protected]

Data protection and privacy reports: [email protected]

Simply put: Royalada provides advertising and customer engagement services. Depending on the situation, we may decide how certain data is processed, share responsibility with a business partner, or process data on behalf of a customer.

3. Scope

This Privacy Policy applies to personal information processed by Royalada in connection with:

• our websites and online services;
• our advertising, lead generation, and customer engagement services;
• advertisements, forms, messages, and content delivered through our services;
• communications with customers, publishers, advertisers, business partners, and website visitors; and
• any other services that reference or link to this Privacy Policy.

This Privacy Policy also explains how Royalada processes personal information when acting as a Data Controller, Joint Controller, or Data Processor, depending on the specific service, agreement, and processing activity.

This Privacy Policy does not apply to:

• websites, applications, or services operated by third parties, except for the personal information Royalada processes through its own services;
• third-party advertising platforms, publishers, advertisers, or partners that maintain their own privacy policies;
• products or services that have their own separate privacy notices; or
• personal information processed by our customers, publishers, advertisers, or business partners outside the scope of Royalada’s services.

When you interact with a third-party website, application, advertisement, form, message, or service, the privacy practices of that third party may also apply.

Simply put: This Privacy Policy explains how Royalada handles personal information when we provide our services. If another company operates the website, app, advertisement, or service you’re using, their privacy policy may also apply.

4. Our Services

Royalada provides managed advertising, lead generation, and customer engagement services to customers, publishers, advertisers, and business partners. Our services may include:

• displaying advertisements on websites, applications, or other digital properties;
• managing advertising placements, campaigns, and demand sources;
• helping customers generate leads through forms, modals, landing pages, or similar digital experiences;
• enabling consent-based communications with customers and leads through supported channels such as email, SMS, push notifications, messaging applications, and other digital communication channels;
• measuring campaign performance, delivery, engagement, and conversions;
• preparing reports and insights for customers and business partners; and
• supporting security, fraud prevention, quality control, and service optimization.

Depending on the agreement with a customer, Royalada may provide only advertising services, only customer engagement services, or a combination of both.

Our customers and business partners are responsible for ensuring that they have the necessary rights, notices, consents, and legal bases to use our services on their websites, applications, or other digital properties.

Simply put: Some customers use Royalada only to display advertisements. Others also use us to help collect leads and communicate with customers through consent-based channels such as email, SMS, push notifications, and messaging applications.

5. Our Role: Data Controller, Joint Controller and Data Processor

Royalada’s privacy role depends on the specific service, agreement, and processing activity. In some cases, Royalada acts as a Data Controller, meaning that we determine why and how personal information is processed. In other cases, Royalada may act as a Joint Controller together with a customer, publisher, advertiser, or business partner where both parties jointly determine certain purposes or means of processing. In limited cases, Royalada may act as a Data Processor, processing personal information on behalf of a customer and in accordance with their instructions.

When Royalada acts as a Data Controller

Royalada generally acts as a Data Controller when we process personal information for our own business purposes or when we independently determine how our services are provided.

This may include processing related to:

• operating and improving our services;
• managing advertising campaigns and delivery;
• selecting or managing demand sources and advertising partners;
• measuring campaign performance, delivery, engagement, and conversions;
• preventing fraud, abuse, invalid traffic, and security incidents;
• managing relationships with customers, publishers, advertisers, and business partners;
• preparing reports and commercial settlement information;
• billing, invoicing, accounting, and legal compliance; and
• responding to inquiries, support requests, legal requests, or privacy rights requests.

When Royalada may act as a Joint Controller

Royalada may act as a Joint Controller where Royalada and a customer, publisher, advertiser, or business partner jointly determine certain purposes or means of processing.

This may occur, for example, where a publisher uses Royalada’s advertising services on its digital properties, and both the publisher and Royalada have responsibilities related to the delivery, measurement, monetization, and compliance of advertising activities.

In such cases, each party is responsible for the privacy obligations that apply to its role, including providing appropriate notices, obtaining required consents, and respecting applicable privacy rights. The essence of our joint controller arrangements, where they exist, is available on request by contacting us at [email protected].

When Royalada acts as a Data Processor

Royalada may act as a Data Processor where we process personal information on behalf of a customer and in accordance with that customer’s documented instructions. This may include certain customer engagement activities, such as sending consent-based communications, managing customer lead data, or performing campaign operations where the customer determines the purpose of the processing and Royalada provides the service under applicable agreements. Customers are responsible for ensuring that they have a valid legal basis, including consent where required, for any personal information they provide to Royalada or ask Royalada to process on their behalf.

Customer and partner responsibilities

Customers, publishers, advertisers, and business partners using Royalada’s services are responsible for:

• providing clear and accurate privacy notices to individuals where required;
• operating an appropriate Consent Management Platform (CMP) where required by law;
• obtaining and maintaining legally required consents or other valid legal bases;
• ensuring that any personal information provided to Royalada was collected lawfully;
• honoring applicable opt-out, withdrawal, and privacy rights requests; and
• complying with the agreements they have with Royalada.

Royalada respects consent and privacy signals made available through supported standards and technologies, including consent signals provided by a publisher’s CMP.

Simply put: Royalada’s role depends on what service we provide. For advertising, we may decide or share responsibility for how data is used. For some engagement services, we may process data on behalf of a customer. In all cases, customers and partners must have proper notices, consents, and legal rights to use our services.

6. Information We Process

The personal information Royalada processes depends on the service being provided, the relationship we have with the relevant customer or partner, and how individuals interact with advertisements, forms, messages, websites, or other digital content delivered through our services. We may process the following categories of information.

Business contact information

When we communicate with customers, publishers, advertisers, business partners, suppliers, or other professional contacts, we may process:

• name and surname;
• business email address;
• business phone number;
• company name;
• job title or role;
• business address;
• communication history; and
• information provided during negotiations, onboarding, support, or account management.

We use this information to manage business relationships, provide services, respond to inquiries, prepare reports, manage contracts, and comply with legal and financial obligations.

Website and service interaction information

When someone visits our website or interacts with our online services, we may process:

• IP address;
• browser type and version;
• device type;
• operating system;
• referring URL;
• pages visited;
• date and time of access;
• approximate location derived from technical data;
• usage and diagnostic information; and
• information submitted through website forms or direct communications.

We use this information to operate our websites and services, maintain security, understand service usage, improve performance, and respond to inquiries.

Advertising and campaign information

When Royalada provides advertising services, we may process information necessary to deliver, measure, optimize, and report on advertisements. This may include:

• IP address;
• browser and device information;
• page URL or app context where an advertisement is displayed;
• advertisement impression, click, and interaction data;
• campaign identifiers;
• approximate location;
• consent and privacy signals;
• fraud prevention and invalid traffic signals;
• conversion or attribution information, where permitted; and
• other information required to provide advertising services in accordance with applicable law.

Where required by law, certain advertising activities depend on consent or other valid legal basis provided through the publisher, website, application, Consent Management Platform, or other applicable mechanism.

Lead generation information

When Royalada provides lead generation services, individuals may choose to submit information through forms, modals, landing pages, or similar digital experiences. Depending on the campaign, this may include:

• name and surname;
• email address;
• phone number;
• company name;
• country, city, or region;
• preferences or interests;
• responses submitted through forms; and
• any other information voluntarily provided by the individual.

We process this information to provide lead generation services, deliver requested communications, support customer follow-up, measure campaign performance, and comply with applicable legal requirements.

Customer engagement information

When Royalada provides customer engagement services, we may process information used to send or manage consent-based communications across supported digital channels. This may include:

• email address;
• phone number;
• messaging application identifiers;
• push notification identifiers;
• subscription status;
• consent status;
• communication preferences;
• message delivery, open, click, and interaction data;
• unsubscribe or opt-out information; and
• campaign engagement history.

We process this information to send, manage, measure, and optimize communications such as email, SMS, push notifications, messaging application messages, and other supported digital communications, where permitted by applicable law.

Consent and privacy preference information

Royalada may process information related to consent, privacy preferences, opt-outs, and privacy rights requests. This may include:

• consent status;
• consent timestamp;
• consent source;
• privacy preference signals;
• opt-out or unsubscribe status;
• withdrawal of consent;
• records of privacy rights requests; and
• information needed to verify and respond to such requests.

We use this information to respect privacy choices, demonstrate compliance, and ensure that services are provided in accordance with applicable privacy laws.

Security, fraud prevention, and compliance information

We may process information necessary to protect our services, customers, partners, and individuals from fraud, abuse, security threats, invalid traffic, and unlawful activity. This may include:

• IP address;
• device and browser information;
• logs and technical events;
• traffic quality signals;
• suspicious activity indicators;
• authentication and access logs;
• audit records; and
• information required to comply with legal, regulatory, or contractual obligations.

Payment and billing information

Where Royalada enters into commercial relationships with customers, publishers, advertisers, or business partners, we may process billing and payment-related information, such as:

• company name;
• billing contact;
• billing address;
• tax identification number;
• invoice details;
• payment status;
• bank or payment reference information; and
• commercial settlement information.

We use this information for invoicing, accounting, payment processing, revenue share calculations, contractual performance, tax compliance, and financial recordkeeping.

Sensitive personal information

Royalada does not intentionally seek to collect sensitive personal information unless it is necessary for a specific service, required by law, or voluntarily provided in a context where processing is permitted. Customers, publishers, advertisers, and business partners must not provide sensitive personal information to Royalada unless they have a valid legal basis and appropriate authorization to do so.

Simply put: The information we process depends on the service. For advertising, we usually process technical and campaign data. For lead generation and engagement, we may process contact details such as email or phone number, but only where there is a valid legal basis or consent where required.

7. How We Use Information

Royalada uses personal information only where we have a valid purpose and legal basis to do so under applicable privacy and data protection laws. Depending on the service, relationship, and processing activity, we may use personal information for the purposes described below.

To provide our services

We use personal information to provide advertising, lead generation, customer engagement, communication, reporting, and related services to our customers, publishers, advertisers, and business partners. This may include delivering advertisements, displaying forms or messages, collecting leads, sending consent-based communications, measuring performance, preparing reports, and supporting campaign operations.

To deliver and measure advertising

We use personal information and technical information to deliver advertisements, measure whether advertisements were displayed or interacted with, prevent invalid traffic, report campaign performance, and improve the effectiveness and quality of advertising services. Where required by law, personalized advertising, tracking, partner synchronization, or similar activities are performed only where an appropriate consent or other valid legal basis exists.

To support lead generation

We use information submitted through forms, modals, landing pages, or similar digital experiences to provide lead generation services, process inquiries, support customer follow-up, measure campaign performance, and maintain records required for compliance. Where required, lead generation activities are based on consent or another valid legal basis provided through the relevant website, campaign, customer, publisher, or business partner.

To provide customer engagement and communications

We use personal information to send, manage, measure, and optimize consent-based communications through supported channels such as email, SMS, push notifications, messaging applications, and other digital communication channels. This may include managing subscriptions, honoring communication preferences, recording opt-outs, measuring delivery and engagement, and ensuring that communications are sent only where permitted by applicable law.

To manage business relationships

We use business contact information to communicate with customers, publishers, advertisers, suppliers, service providers, and business partners. This includes negotiating and managing contracts, onboarding customers and partners, responding to inquiries, providing support, preparing commercial reports, managing payments, and maintaining business records.

To maintain security and prevent abuse

We use personal information and technical information to protect our services, customers, partners, and individuals from fraud, abuse, invalid traffic, unauthorized access, security incidents, and unlawful activity. This may include monitoring traffic quality, detecting suspicious activity, maintaining logs, enforcing contractual restrictions, and protecting the integrity of our services.

To comply with legal and regulatory obligations

We may use personal information where necessary to comply with applicable laws, regulations, court orders, government requests, accounting obligations, tax requirements, privacy obligations, and other legal or regulatory requirements. We may also use information to establish, exercise, or defend legal claims.

To improve our services

We may use information to analyze service performance, identify technical issues, improve reliability, develop new features, optimize campaigns, enhance reporting, and improve the quality and effectiveness of our services. Where possible, we use aggregated, anonymized, or de-identified information for analytics, reporting, and service improvement.

To respect privacy choices

We use consent, preference, opt-out, unsubscribe, and privacy rights request information to honor individual choices and ensure that personal information is processed in accordance with applicable law. This includes respecting consent signals, withdrawal of consent, communication preferences, advertising opt-outs, and other privacy choices where supported and required.

Simply put: We use personal information to provide our services, deliver and measure ads, collect leads, send consent-based communications, prevent fraud, comply with the law, improve our services, and respect privacy choices.

8. Legal Bases for Processing

Where applicable privacy laws require a legal basis for processing personal information, Royalada relies on one or more of the legal bases described below. The applicable legal basis depends on the specific service, relationship, processing activity, jurisdiction, and whether Royalada acts as a Data Controller, Joint Controller, or Data Processor. Where Royalada acts as a Data Processor, the relevant customer, publisher, advertiser, or business partner is responsible for determining the appropriate legal basis for the processing they instruct Royalada to perform.

Consent

We rely on consent where required by applicable law. This may include, for example:

• personalized advertising;
• use of advertising identifiers;
• certain cookies, pixels, tags, or similar technologies;
• partner synchronization or similar advertising activities;
• collection of leads through forms, modals, or similar experiences;
• sending marketing communications by email, SMS, push notifications, messaging applications, or other communication channels; and
• processing that requires consent under applicable privacy, electronic communications, or advertising laws.

Where consent is required, it must be freely given, specific, informed, and capable of being withdrawn. Royalada respects consent signals and privacy preferences made available through supported mechanisms, including Consent Management Platforms where applicable.

Performance of a contract

We process personal information where necessary to perform a contract or take steps before entering into a contract. This may include:

• providing services to customers, publishers, advertisers, and business partners;
• managing onboarding and service delivery;
• preparing reports;
• processing billing and payment information;
• managing support requests;
• communicating about services; and
• enforcing applicable agreements.

Legitimate interests

We may process personal information where necessary for Royalada’s legitimate interests or the legitimate interests of our customers, publishers, advertisers, or business partners, provided that those interests are not overridden by the rights and freedoms of the individuals concerned. This may include:

• providing and improving our services;
• delivering contextual advertising;
• measuring service performance;
• preparing campaign and business reports;
• detecting and preventing fraud, invalid traffic, abuse, and security threats;
• maintaining service reliability and security;
• protecting our legal and commercial interests;
• communicating with business contacts; and
• improving the quality and effectiveness of our services.

Where we rely on legitimate interests, we consider the nature of the processing, the impact on individuals, and the safeguards available to protect personal information.

Legal obligation

We process personal information where necessary to comply with legal or regulatory obligations. This may include:

• tax, accounting, and financial recordkeeping obligations;
• responding to lawful requests from courts, regulators, or public authorities;
• complying with privacy and data protection obligations;
• maintaining required business records;
• preventing unlawful activity; and
• establishing, exercising, or defending legal claims.

Customer instructions

Where Royalada acts as a Data Processor, we process personal information on behalf of a customer and in accordance with that customer’s documented instructions, applicable agreements, and applicable law. In such cases, the customer is responsible for ensuring that a valid legal basis exists for the processing and that individuals receive appropriate privacy notices and choices.

Legal basis by processing activity

Simply put: We only process personal information when there is a valid legal reason to do so. Depending on the situation, that may be consent, a contract, legal obligations, legitimate business interests, or instructions from a customer who is responsible for the data.

9. Advertising and Customer Engagement Services

Royalada provides advertising, lead generation, and customer engagement services that help businesses reach audiences, generate leads, and communicate with customers through digital channels. Depending on the service and applicable agreement, Royalada may support advertising campaigns, lead collection, customer communications, campaign measurement, reporting, and related services.

Advertising services

Royalada may deliver advertisements on websites, applications, or other digital properties operated by publishers, customers, or business partners. Advertising services may include:

• displaying advertisements;
• measuring impressions, clicks, conversions, and other campaign interactions;
• reporting campaign performance;
• preventing fraud, abuse, and invalid traffic;
• optimizing campaign delivery and quality;
• supporting contextual advertising;
• supporting personalized advertising where permitted by law; and
• working with advertisers, publishers, demand partners, and other advertising partners.

Where required by applicable law, personalized advertising, use of advertising identifiers, partner synchronization, or similar advertising activities are performed only where an appropriate consent or other valid legal basis exists. If consent is not available where required, advertising may still be delivered in a contextual or non-personalized manner, using only information necessary to deliver, measure, secure, and report the advertisement.

Publisher and partner responsibilities

Publishers, customers, and business partners that use Royalada services on their websites, applications, or digital properties are responsible for providing appropriate privacy notices and obtaining any legally required consents. Where required, publishers and partners must operate a suitable Consent Management Platform or other consent mechanism and make relevant consent and privacy signals available to Royalada. Royalada respects consent and privacy signals made available through supported standards and technologies.

Lead generation services

Royalada may help customers and partners collect leads through forms, modals, landing pages, or similar digital experiences. Individuals may voluntarily provide information such as name, email address, phone number, company name, preferences, interests, or other information requested in the relevant form or campaign. Lead generation information is used to provide the requested service, support follow-up communications, measure campaign performance, and comply with applicable legal requirements. Where required by law, lead generation activities are based on consent or another valid legal basis.

Customer engagement services

Royalada may help customers and partners communicate with leads, customers, or users through supported digital communication channels. These channels may include email, SMS, push notifications, messaging applications, on-site messages, and other digital communication channels. Customer engagement services may include:

• sending consent-based communications;
• managing subscriptions and communication preferences;
• recording opt-outs and unsubscribe requests;
• measuring delivery, opens, clicks, and interactions;
• supporting customer support, retention, upsell, and similar communications; and
• preparing engagement reports.

Royalada does not send marketing communications through these channels unless there is a valid legal basis and, where required, consent.

Third-party products and partner promotions

Royalada may promote products or services offered by third-party partners, including through affiliate, referral, or partner arrangements. Where Royalada receives compensation, commission, or another commercial benefit from such promotions, we will disclose this where required by applicable law. If partner promotions involve tracking links, conversion measurement, cookies, pixels, postbacks, or sharing information with third-party partners, Royalada will process such information only where permitted by applicable law and, where required, based on consent or another valid legal basis. Third-party partners may process personal information under their own privacy policies when individuals visit their websites, purchase their products, or interact with their services.

Simply put: We may show ads, collect leads, and help businesses communicate with people through consent-based channels. If the law requires consent, our services must respect that consent. If someone declines advertising consent, ads may still be shown in a contextual or non-personalized way.

10. Cookies, Consent and Similar Technologies

Royalada and its customers, publishers, advertisers, and partners may use cookies, pixels, tags, software development kits, local storage, device identifiers, server logs, and similar technologies in connection with websites, advertisements, lead generation forms, customer engagement services, analytics, security, fraud prevention, and campaign measurement. The specific technologies used depend on the service, the website or application, the customer configuration, and the applicable legal requirements. Detailed information about the specific cookies and similar technologies we use, including their names, purposes, storage types, and durations, is provided in our Cookie Policy, which should be read together with this Privacy Policy.

Royalada websites

When you visit Royalada websites, we may use cookies or similar technologies to:

• operate the website;
• remember preferences;
• maintain security;
• analyze website performance;
• understand how visitors interact with our website;
• respond to inquiries; and
• improve our services.

Where required by law, non-essential cookies or similar technologies are used only with consent.

Royalada advertising services

Royalada may use tags, pixels, scripts, server logs, and similar technologies to deliver advertisements, measure impressions and clicks, prevent fraud, report performance, and support advertising services. Where required by law, technologies used for personalized advertising, advertising identifiers, partner synchronization, or similar activities are used only where appropriate consent or another valid legal basis exists. If consent is not available where required, Royalada may still deliver contextual or non-personalized advertisements using information necessary to display, measure, secure, and report the advertisement.

Royalada customer engagement services

Royalada may use cookies, local storage, session storage, tags, pixels, push notification identifiers, and similar technologies to support customer engagement services such as on-site messages, lead forms, email, SMS, push notifications, messaging applications, analytics, and communication preference management. Where required by law, these technologies are used only with consent or another valid legal basis.

Consent Management Platforms

Publishers, customers, and business partners that use Royalada services on their websites, applications, or digital properties are responsible for providing appropriate notices and obtaining any legally required consents. Where required by law, they must operate a suitable Consent Management Platform or other consent mechanism and make relevant consent and privacy signals available to Royalada. Royalada respects supported consent and privacy signals, including the IAB Transparency and Consent Framework (TCF), the IAB Global Privacy Platform (GPP), and Global Privacy Control (GPC), where applicable and technically supported.

Third-party cookies and technologies

Advertisements, content, links, or partner promotions delivered through Royalada services may involve third parties, such as advertisers, demand partners, measurement providers, affiliate partners, or other advertising partners. These third parties may use their own cookies, pixels, tags, identifiers, or similar technologies, subject to their own privacy policies and applicable law. Royalada does not control third-party privacy practices, but we work with partners under appropriate contractual and compliance requirements where required.

Managing cookies and consent

You may be able to manage cookies and similar technologies through:

• the consent banner or preference center on the website or application you are using;
• your browser settings;
• device privacy settings;
• unsubscribe or opt-out links in communications;
• privacy controls provided by applicable platforms; or
• contacting the relevant website operator, customer, publisher, advertiser, or Royalada, depending on the context.

Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Simply put: Cookies, tags, pixels, and similar technologies may be used to run our services, show ads, measure performance, collect leads, send communications, and prevent fraud. Where the law requires consent, those technologies must respect your consent choices.

11. Sharing Personal Information

Royalada may share personal information where necessary to provide its services, operate its business, comply with legal obligations, protect its rights, or support customers, publishers, advertisers, and business partners. We do not sell personal information in the ordinary meaning of selling data for money. Where applicable privacy laws define “sale”, “sharing”, or similar terms more broadly, certain advertising, measurement, affiliate, or partner activities may be considered a sale or sharing of personal information. In such cases, Royalada provides applicable rights and choices as required by law.

Customers, publishers, advertisers, and business partners

We may share personal information with customers, publishers, advertisers, and business partners where necessary to provide advertising, lead generation, customer engagement, reporting, billing, settlement, or related services. For example, we may share campaign reports, lead information, communication performance, conversion information, billing records, or other service-related information with the relevant customer or partner.

Advertising and demand partners

When providing advertising services, Royalada may work with advertisers, demand partners, advertising exchanges, measurement providers, anti-fraud providers, and other advertising technology partners. Where permitted by applicable law and supported by appropriate consent or another valid legal basis where required, information may be shared with these partners to deliver advertisements, measure performance, prevent fraud, support attribution, manage campaigns, and improve advertising quality. If consent is not available where required, Royalada may limit advertising activities to contextual or non-personalized advertising.

Service providers and technology providers

Royalada uses trusted service providers and technology providers to support the operation, security, hosting, delivery, measurement, communication, reporting, and administration of its services. This includes a licensed technology and platform provider that Royalada uses to deliver its advertising, lead generation, and customer engagement services. Key providers are identified in our Service Provider and Subprocessor List. Service providers process personal information only as necessary to provide services to Royalada and are subject to contractual obligations designed to protect personal information.

Communication providers

Where Royalada provides customer engagement services, we may share information with communication providers, delivery partners, messaging platforms, telecommunications providers, email service providers, push notification providers, or similar vendors where necessary to send, deliver, measure, and manage communications. This may include information such as email address, phone number, messaging identifier, delivery status, opt-out status, and communication engagement information, depending on the channel and service.

Professional advisers and business operations

We may share personal information with professional advisers and business support providers, such as lawyers, accountants, auditors, consultants, insurers, banks, payment providers, and other advisers where necessary for business operations, compliance, accounting, auditing, legal advice, dispute resolution, or enforcement of agreements.

Legal, regulatory, and safety reasons

We may disclose personal information where we believe it is necessary to:

• comply with applicable law, regulation, court order, subpoena, or government request;
• respond to lawful requests from public authorities;
• protect the rights, property, or safety of Royalada, our customers, partners, users, or others;
• prevent, investigate, or respond to fraud, abuse, security incidents, invalid traffic, or unlawful activity;
• enforce our agreements and policies; or
• establish, exercise, or defend legal claims.

Business transfers

If Royalada is involved in a merger, acquisition, financing, reorganization, sale of assets, transfer of business, bankruptcy, or similar transaction, personal information may be disclosed or transferred as part of that transaction, subject to appropriate safeguards and applicable law.

Aggregated or de-identified information

Royalada may share aggregated, anonymized, or de-identified information that does not reasonably identify an individual, including for reporting, analytics, research, benchmarking, service improvement, or commercial purposes.

Simply put: We share personal information only when needed to provide our services, work with partners, use trusted providers, comply with the law, protect our services, or manage our business. The key providers we use are identified in our Service Provider and Subprocessor List.

12. International Data Transfers

Royalada may process and transfer personal information in countries other than the country where the individual is located. This may occur when we provide services internationally, work with customers, publishers, advertisers, demand partners, communication providers, service providers, technology providers, or other business partners located in different countries. Where personal information is transferred internationally, Royalada takes steps designed to ensure that the information receives an appropriate level of protection in accordance with applicable privacy and data protection laws. These steps may include, where applicable:

• transferring information to countries that have been recognized as providing an adequate level of data protection;
• using Standard Contractual Clauses or other approved contractual safeguards;
• relying on certified transfer frameworks where legally available;
• conducting transfer risk assessments where required;
• applying technical and organizational security measures;
• limiting the information shared to what is necessary for the relevant purpose; and
• requiring service providers and partners to protect personal information under appropriate contractual obligations.

Where Royalada acts as a Data Processor, international transfers may also be governed by the applicable agreement with the customer, including any data processing terms or transfer safeguards required by law. Where Royalada works with advertising, demand, measurement, communication, or technology partners located outside the European Economic Area, the United Kingdom, Switzerland, or other jurisdictions with transfer restrictions, we apply appropriate safeguards where required. Individuals may contact Royalada to request more information about the safeguards used for international transfers, where applicable.

Simply put: We may work with customers and partners in different countries. When personal information is transferred internationally, we use legal and security safeguards designed to protect it.

13. Data Security

Royalada takes reasonable and appropriate technical, organizational, and contractual measures designed to protect personal information against unauthorized access, loss, misuse, disclosure, alteration, or destruction. These measures may include, where appropriate:

• encryption of personal information during transmission and at rest;
• access controls and role-based permissions;
• authentication and authorization procedures;
• audit logging of access to personal information;
• segregation and isolation of customer data;
• monitoring, logging, and security review procedures;
• backup and recovery measures;
• contractual confidentiality obligations;
• staff and contractor access restrictions; and
• security requirements for service providers and technology providers.

Access to personal information is limited to authorized personnel, service providers, and technology providers who need access for legitimate business, security, legal, or service-related purposes. Where personal information includes sensitive or directly identifiable data, Royalada applies additional safeguards where appropriate. Access to decrypted personal information is restricted and, where manual access is required, such access is subject to authorization and logging. No method of transmission or storage is completely secure. However, Royalada works to maintain safeguards appropriate to the nature of the personal information processed and the risks associated with the processing.

Simply put: We use security measures such as encryption, access controls, and audit logs to protect personal information. Only authorized people or systems may access personal information when needed to provide services, comply with the law, or protect the platform.

14. Data Retention

Royalada keeps personal information only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law. The retention periods below apply unless a shorter period is required by law, agreed with a customer, configured for a specific service, or requested through a valid deletion request.

Where Royalada processes personal information on behalf of a customer, retention may also be determined by the applicable agreement, customer instructions, service configuration, or legal requirements. When personal information is no longer needed, Royalada will delete, anonymize, de-identify, or securely retain it only where permitted or required by applicable law.

Simply put: We keep different types of data for different periods. Advertising logs are usually kept for months, consent and legal records may be kept for years, and accounting records may need to be kept longer under law.

15. Your Privacy Rights

Depending on where you are located and which privacy laws apply, you may have certain rights regarding your personal information. This section describes rights that may apply under laws such as the General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), other applicable United States state privacy laws, and other applicable privacy laws.

European privacy rights — GDPR and UK GDPR

If the GDPR, UK GDPR, or similar privacy laws apply to you, you may have the right to:

• request access to personal information we hold about you;
• request correction of inaccurate or incomplete personal information;
• request deletion of personal information;
• request restriction of processing;
• object to certain processing activities;
• request portability of personal information;
• withdraw consent where processing is based on consent; and
• lodge a complaint with a competent data protection authority.

Right to object to direct marketing: where personal information is processed for direct marketing purposes, you have the right to object at any time, free of charge. If you object, we will stop processing your personal information for direct marketing purposes. Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

United States privacy rights — CCPA/CPRA and other state privacy laws

If you are located in the United States, certain state privacy laws may provide you with additional rights regarding your personal information. Depending on the state where you live and the law that applies, these rights may include the right to:

• know whether we process your personal information;
• access personal information we hold about you;
• receive a copy of your personal information in a portable format;
• correct inaccurate personal information;
• request deletion of personal information;
• opt out of the sale of personal information;
• opt out of the sharing of personal information for cross-context behavioral advertising;
• opt out of targeted advertising;
• opt out of certain profiling activities that produce legal or similarly significant effects;
• limit the use or disclosure of sensitive personal information, where applicable;
• designate an authorized agent to submit a request on your behalf, where applicable;
• appeal a decision we make regarding your privacy request, where applicable; and
• not be discriminated against for exercising your privacy rights.

Sale, sharing, targeted advertising, and profiling

Royalada does not sell personal information in the ordinary meaning of selling data for money. However, some privacy laws, including CCPA/CPRA and other United States state privacy laws, define “sale”, “sharing”, “targeted advertising”, “cross-context behavioral advertising”, or similar terms broadly. Under those laws, certain advertising, measurement, affiliate, or partner activities may be considered a sale, sharing, targeted advertising, or profiling, even if no money is exchanged for personal information. Where applicable, Royalada provides the rights and choices required by those laws.

Global Privacy Control and opt-out preference signals

Where required by applicable law, Royalada honors Global Privacy Control (GPC) or similar legally recognized opt-out preference signals when they are received and can be applied to the relevant processing activity. Such signals may be treated as a request to opt out of certain sale, sharing, targeted advertising, or similar processing activities, depending on applicable law.

China and other international privacy laws

Where other privacy laws apply, including China’s Personal Information Protection Law (PIPL) or similar laws, individuals may have additional rights depending on their location and the nature of the processing. These rights may include access, correction, deletion, withdrawal of consent, explanation of processing rules, or other rights provided by applicable law. Royalada will respond to such requests in accordance with applicable legal requirements.

Exercising your rights

You may exercise your privacy rights by contacting us at: Email: [email protected] When you submit a request, we may need to verify your identity or confirm that you are authorized to act on behalf of another person. We will use the information provided in the request only to verify and respond to the request, unless otherwise permitted by law. We will respond to privacy rights requests within the period required by applicable law — for example, within one month under the GDPR and UK GDPR, or within 45 days under the CCPA/CPRA, subject to extensions permitted by law.

Requests relating to our customers or partners

In some cases, Royalada processes personal information on behalf of, or in cooperation with, a customer, publisher, advertiser, or business partner. If your request relates to personal information collected or controlled by one of our customers or partners, we may direct you to that customer or partner, cooperate with them, or respond in accordance with our legal and contractual obligations.

Consent withdrawal and communication preferences

Where processing is based on consent, you may withdraw your consent at any time. You may also unsubscribe from marketing communications or change communication preferences by using the unsubscribe link, opt-out mechanism, consent preference tool, or other instructions provided in the relevant communication or website.

Advertising choices

Where applicable, you may be able to manage advertising-related choices through:

• the consent banner or preference center on the website or application you are using;
• your browser or device privacy settings;
• industry opt-out tools;
• Global Privacy Control or similar browser-based privacy signals where legally required and technically supported;
• communication unsubscribe or opt-out mechanisms; or
• contacting the relevant website operator, publisher, advertiser, partner, or Royalada.

Opting out of personalized or targeted advertising does not necessarily mean that no advertisements will be displayed. It means that advertisements may be delivered in a contextual or non-personalized manner where permitted by law.

Authorized agents and appeals

Where applicable law allows, you may designate an authorized agent to submit a privacy request on your behalf. We may require the agent to provide proof of authorization and may also require you to verify your identity directly with us, where permitted by law. If applicable law gives you the right to appeal a decision we make regarding your privacy request, you may submit an appeal by contacting us at: Email: [email protected] We will review and respond to appeals within the period required by applicable law.

Complaints

If you believe that your personal information has been processed unlawfully or that your privacy rights have not been respected, you may contact us first so we can try to resolve the issue. You may also have the right to lodge a complaint with the competent data protection or privacy authority in your country, state, or region.

Simply put: Depending on where you live, laws such as GDPR, UK GDPR, CCPA/CPRA, other US state privacy laws, PIPL, or similar laws may give you rights over your personal information. These may include the right to access, correct, delete, copy, move, object, withdraw consent, opt out of certain advertising or data sharing, use an authorized agent, appeal certain decisions, or complain to a privacy authority.

16. Children’s Privacy — COPPA and Similar Laws

Royalada’s services are not intended for children, and we do not knowingly collect personal information from children in a manner that would require parental consent under applicable law. Royalada does not knowingly sell or share the personal information of consumers under 16 years of age, and does not knowingly process children’s personal information for targeted advertising. Customers, publishers, advertisers, and business partners must not use Royalada’s services to knowingly collect personal information from children, target children with advertising, or send marketing communications to children unless they have all required rights, notices, consents, and legal bases under applicable law. If we become aware that personal information from a child has been collected or processed through our services in a way that is not permitted by applicable law, we will take appropriate steps to delete, restrict, or otherwise handle that information in accordance with legal requirements and our contractual obligations. If you believe that a child has provided personal information to Royalada or that our services have been used in a way that involves children’s personal information unlawfully, please contact us at: Email: [email protected]

Simply put: Our services are not meant for children. Customers and partners must not use Royalada to collect data from or market to children unless the law allows it and all required consents are in place.

17. Automated Decision-Making and Profiling

Royalada may use automated systems to provide, measure, optimize, secure, and improve its advertising, lead generation, and customer engagement services. This may include automated processing used to:

• select or prioritize advertisements;
• measure campaign performance;
• prevent fraud, abuse, invalid traffic, or security threats;
• personalize content or communications where permitted by law;
• segment audiences where permitted by law;
• manage communication frequency and preferences;
• optimize campaign delivery; and
• generate reports and insights for customers and business partners.

Where required by applicable law, profiling, personalized advertising, targeted advertising, or similar automated processing is performed only where there is a valid legal basis, including consent where required. Royalada does not intentionally use automated decision-making that produces legal or similarly significant effects on individuals unless permitted by applicable law and subject to appropriate safeguards. Individuals may have the right to object to, opt out of, or request more information about certain profiling or automated decision-making activities, depending on applicable law.

Simply put: We may use automated systems to help show ads, measure campaigns, prevent fraud, and manage communications. We do not use these systems to make decisions that legally or significantly affect people unless the law allows it and proper safeguards apply.

18. Privacy Signals and Opt-Outs

Royalada supports privacy choices and opt-out mechanisms where required by applicable law and technically available in the relevant service. Depending on the context, individuals may be able to manage privacy choices through:

• consent banners or preference centers on websites and applications;
• Consent Management Platforms used by publishers or partners;
• unsubscribe links or opt-out instructions in communications;
• browser or device privacy settings;
• industry opt-out tools;
• Global Privacy Control or similar legally recognized browser-based signals; and
• direct privacy requests submitted to Royalada or the relevant customer, publisher, advertiser, or partner.

Global Privacy Control

Where required by applicable law, Royalada honors Global Privacy Control or similar legally recognized opt-out preference signals when they are received and can be applied to the relevant processing activity. Such signals may be treated as a request to opt out of certain sale, sharing, targeted advertising, or similar processing activities, depending on applicable law.

Do Not Track

Some browsers may offer a “Do Not Track” setting. Because there is no uniform industry standard for responding to Do Not Track signals, Royalada does not currently respond to Do Not Track signals unless required by applicable law. Where legally recognized privacy preference signals are required, Royalada will handle them in accordance with applicable law.

Communication opt-outs

Individuals may opt out of marketing communications by using the unsubscribe link, stop instruction, preference center, or other opt-out mechanism provided in the relevant communication. Even after opting out of marketing communications, individuals may still receive non-marketing communications where permitted by law, such as service, transactional, security, legal, or account-related messages.

Advertising opt-outs

Where applicable, individuals may opt out of certain personalized advertising, targeted advertising, sale, sharing, or profiling activities through available consent tools, privacy controls, browser-based signals, or other mechanisms required by law. Opting out of personalized or targeted advertising does not necessarily mean that no advertisements will be displayed. It means that advertisements may be delivered in a contextual or non-personalized manner where permitted by law.

Simply put: You may be able to opt out of certain advertising, tracking, or marketing activities. If you opt out of personalized ads, you may still see ads, but they should not be personalized where the law requires your choice to be respected.

19. Service Providers and Subprocessors

Royalada uses trusted service providers, technology providers, and subprocessors to help operate, secure, deliver, measure, support, and improve its services. These providers may process personal information only where necessary to provide services to Royalada or to support the services Royalada provides to customers, publishers, advertisers, and business partners. Service providers and subprocessors may support activities such as:

• technology platform services;
• hosting, CDN, network, and infrastructure services;
• data storage and processing;
• security, monitoring, and fraud prevention;
• campaign delivery and measurement;
• customer engagement and communication delivery;
• analytics and reporting;
• traffic quality and invalid traffic detection;
• billing, accounting, and payment processing;
• customer support;
• legal, compliance, and business operations.

Some service providers may use their own subprocessors where necessary to provide their services. Where required by applicable law or contract, Royalada requires appropriate contractual safeguards for such processing. Royalada maintains a separate Service Provider and Subprocessor List that identifies key providers, their role, location, service category, and whether they act as direct or indirect providers. That list is updated from time to time as providers change, without requiring an update to this Privacy Policy. Where required by applicable law or contract, customers will be notified of relevant subprocessor changes. Royalada requires service providers and subprocessors to apply appropriate technical, organizational, and contractual safeguards to protect personal information.

Simply put: We use trusted providers to help run our services. They may support hosting, security, delivery, reporting, communications, billing, or business operations. These providers may process data only as needed and must protect it under contract.

20. Third-Party Links, Advertisements and Partner Services

Royalada services may include or display advertisements, links, forms, offers, content, or other materials provided by third parties, including advertisers, publishers, affiliate partners, demand partners, business partners, and other third-party services. When you click on an advertisement, submit information to a third-party form, visit a third-party website, purchase a third-party product, or interact with a third-party service, that third party may process your personal information under its own privacy policy and terms. Royalada is not responsible for the privacy practices, content, security, or legal compliance of third-party websites, applications, products, or services that are not operated by Royalada. We encourage you to review the privacy policy of any third-party website, application, product, or service before providing personal information or making a purchase. Where Royalada shares personal information with third parties in connection with its services, such sharing is described in this Privacy Policy and is subject to applicable law.

Simply put: If you click an ad or visit a third-party website, that third party may collect and use your information under its own privacy policy. Royalada’s Privacy Policy covers what Royalada does with personal information, not what third parties do on their own services.

21. Changes to this Privacy Policy

Royalada may update this Privacy Policy from time to time to reflect changes in our services, business practices, legal requirements, technology, or privacy practices. When we update this Privacy Policy, we will revise the “Last Updated” date at the top of the document. If we make material changes, we will provide additional notice where required by applicable law. This may include notice through our website, direct communication, contractual notice, or another appropriate method. Your continued use of Royalada services after an updated Privacy Policy becomes effective means that the updated Privacy Policy applies to personal information processed after that date, subject to applicable law. We encourage you to review this Privacy Policy periodically.

Simply put: We may update this Privacy Policy when our services, laws, or privacy practices change. If the changes are important, we will provide notice where the law requires it.

22. Contact Us

If you have any questions about this Privacy Policy, how Royalada processes personal information, or how to exercise your privacy rights, you may contact us at: Royalada LLC, Dragise Misovica 163A, 32000, Cacak, Serbia. Email: [email protected] Data protection and privacy reports: [email protected] If your request relates to personal information processed through a website, application, advertisement, form, message, or service operated by one of our customers, publishers, advertisers, or business partners, we may ask you to contact that organization directly or we may cooperate with them to handle your request, depending on Royalada’s role and applicable legal requirements. For privacy rights requests, please include enough information for us to identify the relevant service, campaign, website, communication, or interaction, and to verify and respond to your request where required by law.