Privacy Policy

Effective Date: April 6, 2026
Last Updated: April 6, 2026

1. Introduction

This Privacy Policy ("Policy") describes how TRAFFIC SHARK LP ("AppGrade," "we," "us," or "our"), a limited partnership organized under the laws of Ontario, Canada, collects, uses, discloses, and protects information in connection with:

• Our website located athttps://appgrade.pro (the "Website");
• Our demand-side advertising platform accessible athttps://ads.appgrade.pro(the "Platform");
• Our advertising technology services, including real-time bidding, ad serving, campaign optimization, and related services (collectively, the "Services").

By accessing or using our Website, Platform, or Services, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use our Website, Platform, or Services.

2. Definitions

• "Advertiser" means a business entity that uses the Platform to purchase in-app advertising inventory.
• "Consumer" means an end user of a mobile application who may be served advertisements through our Services.
• "Device Identifier" means a unique identifier associated with a mobile device, including but not limited to Apple's Identifier for Advertisers (IDFA), Google Advertising ID (GAID), and Android ID.
• "Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device.
• "Post-Back Data" means information received from advertising partners and supply-side platforms related to ad delivery events, including impressions, clicks, installs, and post-install events.
• "SSP" (Supply-Side Platform) means a technology platform that manages and sells mobile in-app advertising inventory on behalf of app publishers.

3. Information We Collect

3.1 Information from Website Visitors

When you visit our Website, we may collect:

• Contact Form Data: Name, email address, entity type (Advertiser, SSP, DSP, or Other), and message content that you voluntarily submit through our contact form.
• Automatically Collected Data: IP address, browser type and version, operating system, referring URL, pages visited, date and time of access, and general geographic location (city/country level).
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to enhance your browsing experience, analyze site traffic, and understand user behavior. See Section 8 (Cookies and Tracking Technologies) for more details.

3.2 Information from Platform Users (Advertisers)

When you register for and use our Platform, we may collect:

• Account Information: Company name, contact person name, email address, phone number, billing address, and payment information.
• Campaign Data: Ad creatives, targeting parameters, bid settings, budget allocations, and campaign performance data.
• Usage Data: Login activity, feature usage, Platform preferences, and interaction logs.
• Communications: Support requests, chat messages (via our live chat provider), and correspondence with our team.

3.3 Information from Consumers (via Advertising Services)

In the course of delivering advertisements through our Services, we may process the following Consumer data received from SSPs and advertising partners:

• Device Identifiers: IDFA, GAID, Android ID, or other advertising identifiers.
• Device Information: Device make, model, operating system and version, screen resolution, language settings, and carrier information.
• Network Information: IP address, connection type (Wi-Fi, cellular), and MCC-MNC (Mobile Country Code - Mobile Network Code).
• Geographic Data: Country, region, and city derived from IP address (we do not collect precise GPS coordinates).
• Ad Interaction Data: Impressions served, clicks, installs, and post-install events received via Post-Back Data from attribution partners.
• Contextual Data: App bundle ID, app category, app name, and ad placement information.

Important: We do not directly collect Personal Information from Consumers. All Consumer data is received through programmatic ad exchanges, SSPs, and attribution partners in the course of real-time bidding transactions. We do not have a direct relationship with Consumers.

3.4 Information from Third Parties

We may receive information from:

• SSP Partners: Including but not limited to BetweenX, Algorix, Unity Ads, and Chartboost, who provide bid request data containing device and contextual information pursuant to the OpenRTB 2.5 protocol.
• Attribution Partners: Including but not limited to Adjust, AppsFlyer, AppMetrica, and Kochava, who provide Post-Back Data regarding campaign performance.
• Fraud Detection Services: Data related to traffic quality, bot detection, and fraud indicators.

4. How We Use Information

4.1 Website and Platform Operations

We use information collected from Website visitors and Platform users to:

• Respond to inquiries and contact form submissions;
• Create and manage Advertiser accounts;
• Provide, maintain, and improve the Platform and Services;
• Process payments and manage billing;
• Communicate about account activity, service updates, and support matters;
• Ensure Platform security and prevent unauthorized access;
• Comply with legal obligations.

4.2 Advertising Services

We use Consumer data to:

• Deliver Advertisements: Evaluate bid requests and serve relevant in-app advertisements in Banner, Video, Native, and Playable formats.
• Campaign Optimization: Optimize ad delivery, bidding strategies, and target Cost Per Install (tCPI) performance using machine learning algorithms and statistical models.
• Frequency Capping: Limit the number of times a particular advertisement is shown to the same device.
• Fraud Prevention: Detect and prevent ad fraud, including invalid traffic, device farms, click injection, and other fraudulent activities through our anti-fraud system.
• Measurement and Reporting: Measure campaign performance, generate reports for Advertisers, and provide aggregated analytics.
• Model Development: Develop, train, and improve our machine learning models, algorithms, and optimization technologies using aggregated and de-identified data.

4.3 Legal Bases for Processing (for applicable jurisdictions)

Where required by applicable law, we process Personal Information on the following legal bases:

• Legitimate Interest: For advertising delivery, fraud prevention, service optimization, and model development, where our interests are not overridden by the data subject's rights.
• Contractual Necessity: To perform our obligations under agreements with Advertisers and partners.
• Consent: Where required, such as for cookie-based tracking on our Website.
• Legal Obligation: To comply with applicable laws, regulations, and legal processes.

5. How We Share Information

We do not sell Personal Information in personally identifiable form. We may share information as follows:

5.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Cloud hosting and infrastructure providers;
• Payment processors;
• Live chat and customer support tools (Tawk.to);
• Email service providers;
• Analytics providers.

These providers are contractually obligated to use Personal Information only for the purposes of providing services to us and in accordance with this Policy.

5.2 Advertising Ecosystem Partners

In the course of delivering our Services, we exchange data with:

• SSPs and Ad Exchanges: We submit bid responses containing ad creative information and bid prices in response to bid requests.
• Advertisers: We provide campaign performance reports, which may include aggregated and de-identified metrics.
• Attribution Partners: We share device-level identifiers with attribution providers to enable conversion tracking and campaign measurement at the direction of our Advertisers.

5.3 Legal and Compliance

We may disclose information if required to do so by law or in the good faith belief that such disclosure is necessary to:

• Comply with a legal obligation, regulation, or governmental request;
• Protect and defend the rights or property of TRAFFIC SHARK LP;
• Prevent or investigate possible wrongdoing in connection with the Services;
• Protect the personal safety of users or the public.

5.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Website of any change in ownership or uses of your Personal Information.

6. International Data Transfers

TRAFFIC SHARK LP is based in Canada. Our Services operate globally across 150+ countries. Information we collect may be transferred to, stored, and processed in Canada and other countries where we or our service providers maintain facilities.

6.1 Canada (PIPEDA)

We comply with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. We process Personal Information in accordance with the principles of accountability, identifying purposes, consent, limiting collection, limiting use, accuracy, safeguards, openness, individual access, and challenging compliance.

6.2 European Economic Area and United Kingdom

If we process personal data of individuals located in the European Economic Area ("EEA") or the United Kingdom ("UK"), we rely on appropriate safeguards for international transfers, including the European Commission's Standard Contractual Clauses (SCCs) or other approved transfer mechanisms under the General Data Protection Regulation ("GDPR") and UK GDPR.

6.3 California (CCPA/CPRA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"). These include:

• Right to Know: You may request the categories and specific pieces of Personal Information we have collected about you.
• Right to Delete: You may request deletion of your Personal Information, subject to certain exceptions.
• Right to Opt-Out of Sale/Sharing: We do not sell Personal Information. To the extent our sharing of data for cross-context behavioral advertising constitutes "sharing" under the CCPA, you may opt out by contacting us atpartners@appgrade.pro.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

6.4 Brazil (LGPD)

If you are located in Brazil, you may have rights under the Lei Geral de Proteção de Dados ("LGPD"), including the right to confirmation of processing, access, correction, anonymization, portability, deletion, and information about sharing.

6.5 Other Jurisdictions

We are committed to complying with applicable data protection laws in all jurisdictions where we operate. If you have questions about our compliance with the laws of your jurisdiction, please contact us at partners@appgrade.pro.

7. Your Rights and Choices

7.1 Platform Users (Advertisers)

If you are a registered Platform user, you may:

• Access and update your account information through the Platform settings;
• Request a copy of your Personal Information;
• Request deletion of your account and associated data;
• Opt out of non-essential communications.

7.2 Consumers

Because we do not have a direct relationship with Consumers, we recommend that Consumers exercise their privacy rights with the apps and services they use directly. If you are a Consumer and wish to exercise your rights regarding data processed through our Services, you may:

• Adjust Device Settings: Reset or limit your Device Identifier through your device's privacy settings:
  • iOS: Settings > Privacy & Security > Tracking
  • Android: Settings > Privacy > Ads > Delete advertising ID
• Industry Opt-Out Tools:
  • YourAdChoices(United States)
  • Your Online Choices(European Union)
• Contact Us: Emailpartners@appgrade.prowith your Device Identifier and we will process your opt-out request. Please note that opting out will stop targeted advertising but may not prevent you from seeing non-personalized ads.

7.3 Do Not Track Signals

Our Website does not currently respond to "Do Not Track" (DNT) browser signals, as there is no industry-standard technology for recognizing or honoring DNT signals.

8. Cookies and Tracking Technologies

8.1 What We Use

We use the following categories of cookies and tracking technologies on our Website:

8.2 Your Cookie Choices

When you first visit our Website, you will be presented with a cookie consent banner that allows you to accept or reject non-essential cookies. You may also manage your cookie preferences at any time through your browser settings:

• Chrome: Settings > Privacy and Security > Cookies
• Firefox: Settings > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Manage Website Data
• Edge: Settings > Cookies and Site Permissions

Please note that disabling certain cookies may affect the functionality of our Website.

8.3 Third-Party Tracking

Our Website may include third-party services that set their own cookies, including our live chat provider (Tawk.to). These services are governed by their own privacy policies.

9. Data Security

We implement appropriate technical and organizational measures to protect Personal Information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit (TLS/SSL) and at rest;
• Access controls and authentication requirements;
• Regular security assessments and monitoring;
• Employee training on data protection practices.

However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee its absolute security.

10. Data Retention

We retain Personal Information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.

• Account Data: Retained for the duration of the account relationship and for a reasonable period thereafter for legal and business purposes.
• Consumer Data: Device-level data processed through our advertising Services is retained for a maximum of 24 months, after which it is aggregated or deleted.
• Website Analytics: Retained for up to 24 months.
• Legal and Compliance: Certain records may be retained longer as required by applicable law.

11. Children's Privacy

Our Website, Platform, and Services are not directed to individuals under the age of 18. We do not knowingly collect Personal Information from children under 18. If we become aware that we have collected Personal Information from a child under 18, we will take steps to delete such information promptly. If you believe that a child under 18 has provided us with Personal Information, please contact us atpartners@appgrade.pro.

12. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last Updated" date at the top of this Policy;
• Post the revised Policy on our Website;
• Notify registered Platform users by email for material changes.

Your continued use of our Website, Platform, or Services after the effective date of the revised Policy constitutes your acceptance of the changes.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

TRAFFIC SHARK LP
120 Newkirk Rd, Suite 34
Richmond Hill, ON L4C 9S7
Canada

Email:partners@appgrade.pro

For privacy-specific inquiries, including data access, correction, or deletion requests, please emailpartners@appgrade.prowith the subject line "Privacy Request."