VOISE TECH LTD – GLOBAL PRIVACY POLICY

Effective Date: March 12, 2026
Last Updated: March 12, 2026

This Privacy Policy (this “Policy”) describes how Voise Tech Ltd, a company incorporated in England and Wales with its registered office at 4 Station Avenue, Coventry, CV4 9HS, United Kingdom (“Voise Tech,” “Company,” “we,” “us,” or “our”), collects, uses, discloses, transfers, stores, and otherwise processes information that relates to an identified or identifiable individual (“Personal Data”) in connection with:

·    the website located at www.voisetech.com and any associated domains or subdomains (the “Site”); and

·    our advertising technology platforms, infrastructure, integrations, software, APIs, services, and related tools enabling programmatic advertising transactions (collectively, the “Services”).

This Policy is intended to support compliance with applicable privacy and data protection laws and self-regulatory standards, including (as applicable): the EU General Data Protection Regulation (GDPR), UK GDPR and the UK Data Protection Act 2018, the California Consumer Privacy Act (CCPA) as amended by the CPRA, other U.S. state privacy laws (including Colorado, Connecticut, Utah, Virginia, and others as enacted), the India Digital Personal Data Protection Act, 2023 (DPDP Act), and industry frameworks such as the IAB Transparency & Consent Framework (TCF), IAB Europe TCF Policies, and OpenRTB.

Adtech role notice (important): Voise Tech is an infrastructure provider in the programmatic advertising ecosystem. Depending on the context:

·    Voise Tech may act as an independent controller (typically for Site operations, security, compliance, and B2B relationship management);

·    Voise Tech may act as a processor/service provider/contractor processing data on behalf of publishers, apps, SSPs, exchanges, DSPs, advertisers, measurement providers, and other participants (“Partners”) who determine the purposes and means of processing.

Where we act as a processor/service provider/contractor, the relevant Partner’s privacy notice governs the relationship with end users and explains Partner-specific purposes, legal bases, and choices.

No advice: This Policy is informational and does not constitute legal advice.

1. Definitions

·    “Personal Data” includes “personal data,” “personal information,” or analogous concepts under Applicable Law. Pseudonymous identifiers may be Personal Data under certain laws.

·    “Processing” means any operation performed on Personal Data (collection, storage, use, disclosure, transfer, deletion, etc.).

·    “Applicable Law” means all privacy and data protection laws applicable to our processing activities.

·    “Partner” means any publisher, app, SSP, exchange, DSP, advertiser, agency, measurement provider, brand safety provider, fraud detection vendor, or other ecosystem participant that integrates with the Services.

2. Scope, Who This Policy Applies To

This Policy applies to:

·    Site visitors;

·    business contacts (representatives of customers, partners, suppliers, and prospects);

·    end users whose devices/browsers generate ad-tech signals processed via the Services (typically on behalf of Partners).

This Policy does not cover third-party websites, apps, devices, operating systems, or services that may be linked to or integrated with our Services. Their privacy practices are governed by their own notices.

3. Controller / Processor Roles (Allocation)

3.1 When We Act as a Processor / Service Provider / Contractor

Where we process Personal Data on behalf of a Partner:

·    the Partner is the controller/business and determines the purposes and means of processing;

·    Voise Tech processes Personal Data only on documented instructions, consistent with contract and law;

·    Voise Tech supports consent/choice signals (including TCF) as received, subject to technical feasibility;

·    data subject requests should generally be directed to the Partner, though Voise Tech will provide assistance to the extent required by law and contract.

Voise Tech does not determine the independent processing purposes of Partners once advertising signals are transmitted through the programmatic auction process. Each Partner remains solely responsible for its own compliance with applicable privacy laws, including the lawful collection of user consent and provision of transparency notices to end users.

3.2 When We Act as an Independent Controller

We act as an independent controller for certain activities such as:

·    operating and securing the Site;

·    managing B2B relationships and communications;

·    compliance, audit, legal holds, and regulatory engagement;

·    maintaining security logs and detecting/mitigating fraud or abuse affecting our systems.

4. Personal Data We Process

4.1 Business Contact Data

·    name; business email; company; job title; business phone; communications records.

4.2 Site Usage Data

·    IP address; device type; browser type; operating system; referring URLs; pages visited; time spent; navigation paths; approximate location derived from IP; cookie data.

4.3 Adtech / Bidstream Data (OpenRTB)

·    cookie IDs; mobile ad IDs (IDFA/GAID); IP address (may be truncated/minimized); device IDs; user agent; browser/OS/device model; timestamps; ad request and auction identifiers; bid response metadata; impression/click events; contextual URL/app bundle; content category.

Bidstream signals may be transmitted between ecosystem participants in accordance with the OpenRTB protocol. Once such signals are transmitted to third-party participants in the advertising auction, Voise Tech does not control how those participants independently process the signals and shall not be responsible for the downstream processing activities of such third parties.

4.4 Sensitive Data

We do not intentionally collect or use special category/sensitive data for advertising auctions. Partners must not provide such data to Voise Tech unless explicitly agreed in writing and legally permitted.

4.5 Data Minimization

We apply data minimization and proportionality controls appropriate to our role and the purposes of processing.

5. Sources

We may obtain Personal Data from:

·    you;

·    the Site and its technical logs;

·    Partners and their vendors;

·    our service providers.

6. Purposes of Processing

We process Personal Data for:

·    Site operation, performance, and security;

·    B2B communications, relationship management, and account administration;

·    providing, operating, maintaining, securing, and improving the Services;

·    facilitating advertising auctions and ad delivery;

·    frequency capping;

·    measurement, reporting, attribution, and analytics (including aggregated/de-identified reporting);

·    invalid traffic detection, anti-fraud, brand safety, and abuse prevention;

·    debugging and quality assurance;

·    legal compliance, audit, and recordkeeping;

·    establishing, exercising, or defending legal claims.

·    implementation of privacy-by-design and data minimization principles in the architecture and operation of advertising infrastructure.

7. Legal Bases (GDPR/UK GDPR)

Where GDPR/UK GDPR applies and we act as a controller, we rely on:

·    Consent (where required);

·    Legitimate interests (security, fraud prevention, service integrity, and improvement);

·    Contract (performance of a contract or steps at the request of the data subject);

·    Legal obligation;

·    Establishment/exercise/defense of legal claims (where applicable).

Where we act as a processor, legal bases are determined by the controller/Partner.

7.1 Legitimate Interests Assessment

Where we rely on legitimate interests, we consider the necessity of processing and balance our interests against individuals’ rights and expectations, and implement safeguards.

8. Cookies; Consent Signals; IAB TCF

We use cookies and similar technologies as described in the Cookie Policy below.

Where applicable:

·    consent is collected through Partner CMPs;

·    consent and transparency signals may be communicated via the IAB TCF;

·    we process such signals as received, subject to technical feasibility and our role.

9. Disclosures and Recipients

We may disclose Personal Data to:

·    Partners and ecosystem participants necessary to facilitate auctions, delivery, measurement, and fraud prevention;

·    service providers (cloud hosting, security monitoring, analytics, professional advisors) bound by appropriate obligations;

·    authorities and third parties where required by law or necessary to protect rights, safety, and security;

·    acquirers/successors in corporate transactions.

·    Voise Tech may participate in industry transparency initiatives designed to improve visibility across programmatic advertising supply chains, including but not limited to ads.txt, app-ads.txt, sellers.json, and OpenRTB SupplyChain objects where applicable.

10. Targeted Advertising; Opt-Outs; “Sale/Share” (U.S.)

Voise Tech may support targeted advertising using pseudonymous identifiers.

Opt-outs:

·    NAI: https://optout.networkadvertising.org

·    DAA: https://optout.aboutads.info

·    EDAA: https://www.youronlinechoices.eu

GPC: Where required, we honor GPC signals as opt-outs of certain processing, subject to role and technical feasibility.

Do Not Sell/Share: In adtech ecosystems, some disclosures may be considered “sale” or “sharing” under broad statutory definitions. Where applicable, Voise Tech supports opt-out signals and contractual controls consistent with its role.

Where Voise Tech acts as a processor or service provider on behalf of a Partner, responsibility for presenting opt-out mechanisms and honoring user choice signals rests primarily with the relevant Partner operating the website or application through which advertising signals originate.

11. Automated Decision-Making

RTB and ad delivery may involve automated decisions based on bid values and contextual/technical signals. We do not intend to conduct solely automated decision-making that produces legal or similarly significant effects as described in GDPR Article 22 in the ordinary course.

12. International Transfers

Personal Data may be transferred to countries that may not provide the same level of protection.

Where required, we implement safeguards such as:

·    EU SCCs;

·    UK IDTA and/or UK Addendum;

·    supplementary measures (encryption in transit, access control, minimization, vendor diligence).

13. Retention

We retain Personal Data only as necessary for the purposes in this Policy.

Typical periods:

·    bidstream event data: up to 90 days;

·    aggregated reporting: up to 24 months;

·    security/fraud logs: up to 24 months;

subject to legal holds, disputes, or legal obligations.

14. Security

We maintain safeguards appropriate to risk (administrative, technical, organizational), including access controls, encryption in transit, logging/monitoring, vulnerability management, and incident response.

Our security program incorporates controls aligned with recognized industry frameworks such as SOC 2 and ISO 27001 security principles and may include encryption in transit, access control management, infrastructure segmentation, monitoring systems, vulnerability scanning, and incident response procedures.

15. Your Rights

Depending on jurisdiction, you may have rights including access, correction, deletion, restriction, objection, portability, withdrawal of consent, and opt-out of targeted advertising.

Submit requests: privacy@voisetech.com

We may verify identity/authority. If we act as processor, we may refer you to the Partner/controller.

Appeals (where applicable): You may appeal a denial by emailing privacy@voisetech.com with the subject “Privacy Request Appeal.”

16. Children

Not directed to children under 16 (or local age). We do not knowingly collect children’s data.

17. India (DPDP Act)

Where applicable and acting as Data Fiduciary, we will provide notice, implement reasonable security safeguards, and support rights and grievance redressal.

Grievance Contact: privacy@voisetech.com
Grievance Officer (if/when required): Lokesh Singh

18. Supervisory Authorities (GDPR/UK GDPR)

You may have the right to lodge a complaint with your local supervisory authority. In the UK, the supervisory authority is the Information Commissioner’s Office (ICO).

19. Changes

We may update this Policy. Updates will be posted with a revised “Last Updated” date. Where required by law, we will provide additional notice or obtain consent.

20. Contact

Voise Tech Ltd
4 Station Avenue, Coventry, CV4 9HS, United Kingdom
Email:
privacy@voisetech.com
Privacy Contact: Lokesh Singh

21. Disclaimers; Limitation of Liability (Maximum Extent Permitted by Law)

This Policy describes our practices and does not create contractual rights beyond what is required by Applicable Law.

To the maximum extent permitted by law, Voise Tech disclaims all warranties and will not be liable for indirect, incidental, special, consequential, exemplary, or punitive damages, or for lost profits, revenues, goodwill, data, or use, arising from or relating to this Policy.

Voise Tech does not control and is not responsible for the content of advertisements delivered by advertisers or demand partners, the data collection practices of publishers, or third-party tracking technologies implemented by ecosystem participants.

Nothing in this Policy excludes liability that cannot be excluded under law.

22. Governing Law

Unless required otherwise by Applicable Law, this Policy is governed by the laws of [ENGLAND AND WALES].