Serafino Privacy Statement
Last updated: September 23, 2025
We, Serafino Pte. Ltd., have issued this Privacy Statement to describe how we collect, use, disclose and otherwise process your personal data when you use mobile apps operated by organizations that participate in our ad exchange or receive mediation services (collectively, “Publishers”). This Privacy Statement also includes information about statutory rights you may have with respect to our processing of your personal data and how to exercise them.
Publishers separately and independently operate their own online mobile apps and determine the means and purposes of processing your personal data when you use their apps. Publishers participate in our ad exchange and use our mediation services to help deliver digital advertisements to you and show ads in the available ad spaces within their apps. Publishers use our ad exchange to offer to advertisers the opportunity to place ads in these ad spaces, and advertisers compete in auctions held on our ad exchange to place their ads in Publishers’ apps. Our mediation services act as a bridge or mediator between different ad networks and Publishers, thereby expanding the pool of advertisers that can participate in auctions on our ad exchange.
Publishers may disclose to us some of the personal data they collect from you when you use their apps so that we can provide the services described above. In these cases, we process your personal data for the purposes described in this Privacy Statement. Please also refer to Publishers’ own privacy statements for information about how they process your personal data when you use their respective apps and your choices with respect to such processing.
We may collect various types of personal data about you depending on how you interact with Publishers’ apps. These types of personal data include the following:
· Identifiers: This includes an identifier associated with the app you are using, and your instance IDs (which are randomly generated codes that may be used to identify a specific app session or installation and are not stored for long periods), Apple Identifier for Advertisers (IDFA), Android Advertising ID (GAID), Identifier for Vendors (IDFV), and other ad identifiers that may be assigned by mobile or digital platforms to help deliver and measure the performance of ads.
· Device Information: This includes data about the device and network you use to access the Publisher’s app, including your device’s name, hardware model, manufacturer, operating system and version, screen size, screen orientation, language preferences, time zone settings, physical memory, total and available storage capacity, disk size, system boot time, system file time, device initiation time, and whether your device is using a modified operating system (such as one that has been jailbroken to bypass standard security controls), information about your mobile network operator and network type (e.g., Wi-Fi or cellular), your IP address, and your inferred country or region-level location data (but not precise geolocation data derived from global positioning system technologies).
· Demographic Data: We may receive your
year of birth and gender.
· Consent and Preference Data: This includes information about your decisions, and those of your parent or guardian if you are a minor, about how third parties may process your personal data.
· Interactions: This includes data about how you interact with ads shown in Publishers’ apps, such as whether you viewed or clicked an ad, the date and time of those actions, impression IDs, click IDs, whether you were redirected to another app or page, download completion status, and any redirection or bounce events related to the ad.
· Correspondence Data: This includes any information that you voluntarily provide to us if you contact us directly, such as if you email us with a question or request. This data may include your name, email address and any other information you voluntarily include in your correspondence with us.
When you use a Publisher’s mobile app, the Publisher collects personal data from your device and may disclose to us some or all of the categories of personal data described above at Section 1. Publishers determine the types of data they collect and are responsible for obtaining any required consents to process that data under applicable law.
We may process your personal data for the following purposes depending on your Consent and Preference Data.
· Deliver ads: We may process your Identifiers, Device Information, Demographic Data, and Interactions to help Publishers deliver digital advertisements in their mobile apps.
· Measure and report on the performance of ads: We may process your Identifiers, Device Information, Demographic Data, and Interactions to analyze the performance of digital ads, including measuring impressions, clicks, installs and conversions. We may aggregate and disclose this data to Publishers and other third parties to help them evaluate advertising effectiveness and optimize future campaigns.
· Detect and prevent fraud: We may process your Identifiers and Interactions to help identify and block suspicious or invalid traffic, such as fake clicks or spoofed devices. This protects advertisers from being charged for fraudulent activity and helps ensure ads reach real users.
· Improve our products and services and develop new ones: We may process any personal data we have collected to operate,
maintain and improve our services, including debugging, resolving technical
issues and enhancing service functionality.
· Comply with legal obligations and respond to lawful requests: We may process any personal data we have collected to comply with applicable laws, regulations, legal processes or government requests.
· Establish, exercise or defend legal claims: We may process any personal data we have collected where necessary to protect our rights, resolve disputes, enforce our agreements, or participate in legal proceedings.
· Support corporate transactions: We may use any personal data we have collected to evaluate or effectuate an actual or potential merger, acquisition, financing, asset sale, bankruptcy, or other corporate transaction involving our business. Where appropriate, we will take steps to ensure that personal data remains subject to confidentiality and data protection obligations.
We may disclose your personal data to the following categories of third parties. In all cases, we will take steps to ensure that personal data remains subject to confidentiality and data protection obligations as required by applicable laws.
· Advertisers: We disclose Identifiers,
Device Information and Demographic Data to advertisers when they participate in
our ad exchange to facilitate ad delivery.
· AdTech Providers: We may disclose Identifiers, Device Information and Interactions to the AdTech Providers listed below to facilitate ad delivery and measure ad performance when providing mediation services to Publishers. AdTech Providers act independently and may process your personal data according to their own privacy policies, which we encourage you to review:
o Meta Audience Network. Privacy Policy: https://developers.facebook.com/docs/audience-network/optimization/best-practices/an-policy
o Google Admob. Privacy Policy: https://policies.google.com/privacy?hl=en
o AppLovin. Privacy Policy: https://www.applovin.com/privacy/
o Pangle. Privacy Policy: https://www.pangleglobal.com/privacy
o Mintegral. Privacy Policy: https://www.mintegral.com/en/privacy
· Service Providers: We may disclose personal data to affiliated and unaffiliated service providers that process the data on our behalf and under our instructions. These include cloud hosting and infrastructure providers. These service providers are contractually obligated to protect the personal data we disclose to them and are not permitted to use it for their own purposes.
· Authorities: We may disclose personal data if required to do so by law or legal process, or in response to valid requests from government authorities, courts or regulators. We may also disclose personal data where necessary to protect our legal rights or the rights of others, or to investigate potential violations of law or our agreements.
· Parties to Corporate Transactions: We may disclose personal data to evaluate or effectuate an actual or potential merger, acquisition, financing, asset sale, bankruptcy, or other corporate transaction involving our business. Where appropriate, we will take steps to ensure that personal data remains subject to confidentiality and data protection obligations.
· Third Parties with Your Consent or Direction: We may disclose your personal data to third parties when you direct us to do so or otherwise provide your consent.
We also disclose aggregated data to Publishers and other third parties, such as the total number of impressions of ads delivered through our services. In addition, when you click on an ad, you may yourself cause the advertiser to receive personal data about you. This is because clicking the ad may redirect you to the advertiser’s own online services, where the advertiser receives your IP address and other personal data.
We are located in Singapore and rely on service providers in Singapore. Publishers and advertisers may be located around the world. The locations of AdTech providers are located in their respective privacy policy. When we transfer your personal data internationally, we enter into data protection and processing agreements with the recipients to protect your data in accordance with applicable laws. We also maintain technical, administrative, and organizational measures data security intended to protect your personal data from unauthorized access, loss, misuse, alteration or destruction. These include access controls, data encryption, network firewalls, and internal data security protocols.
In general, we retain your personal data for up to 3 years from when we collected it, unless you request that we delete it, in which case we will delete the data as soon as required by applicable laws. We may also retain personal data for longer than the period mentioned above if it is necessary for us to do so to comply with applicable laws or to establish, exercise or defend our legal rights in the context of an anticipated or actual dispute. Once the personal data is no longer necessary for such purposes, we will delete it or permanently convert it into non-personally identifiable information.
We contractually require Publishers that disclose personal data to us to comply with laws that apply to any collection and further processing of minors’ personal data. If we know that you are a minor, we use this information to help ensure that you only receive ads that are appropriate for minors and to comply with applicable laws. If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us using the information provided in Section 10 of this Privacy Statement.
There are various ways in which you can exercise control over the personal data processing activities described in this Privacy Statement, including by using the online mechanisms or exercising the statutory rights described below.
·
The Choices AdTech Providers
Give You: Some AdTech Providers may offer their own
tools to manage how they use your personal data. To learn more about such
tools, please refer to their respective privacy policies listed in Section 4
above.
·
The Choices Publishers Give You:
When you access an app operated by a Publisher, the
Publisher may present you with notices about how it collects, uses, discloses
and otherwise processes your personal data, and your consent to engage in such
activities as required under applicable law. These consent interfaces may give
you the option to agree to, decline, or opt out of, the processing of your
personal data for certain purposes such as personalized advertising. We rely on
Publishers to provide these notices and collect any required consents on our
behalf.
·
Device-Level Settings: Many mobile device platform and software providers provide options
for limiting the use of advertising identifiers. For example:
o
On iOS devices, you can go to “Settings”
> “Privacy & Security” > “Tracking” to manage whether apps can track
your activity across other companies’ apps and websites.
o
On Android devices, you can go
to “Settings” > “Security and Privacy” > “Privacy Controls” > “Ads” to
delete your advertising ID or adjust your ad personalization settings.
In addition, depending on the privacy laws that apply to our processing of your personal data and the conditions that apply under these laws, you may have some or all of the following rights with respect to your personal data:
· Access: You may have the right to access information about how we process your personal data and copies of such data.
· Correction: You may have the right to ask us to correct or complete your personal data if it is wrong or incomplete.
· Deletion: You may have the right to ask us to delete your personal data when certain conditions apply.
· Restriction on processing: You may have the right to ask us to restrict the use of your personal data when certain conditions apply.
· Object to processing: You may have the right to object to us processing your personal data when certain conditions apply.
· Portability: You may have the right to receive your personal data in a structured and commonly used format so you can use this data with another company when certain conditions apply.
· Opt-out of targeted advertising: Some jurisdictions give you the right to opt out of targeted advertising where opt-in consent is not otherwise required. You may opt out by following the instructions following the sub-heading “The Choices We Give You” above.
· Non-discrimination: You may have the right not to receive discriminatory treatment for exercising your statutory rights over your personal data.
· Consent Withdrawal: There are certain circumstances where we rely on your consent to process your personal data. If you have provided consent, you may have the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.
To submit a request to exercise your statutory rights over your personal data, you can contact us by any method described in Section 10 of this Privacy Statement.
From time to time, we may update this Privacy Statement if applicable laws or changes to our practices require changes. When we make changes to this Privacy Statement, we will change the date at the beginning of the document. We may work with Publishers to address any notice and consent requirements that apply to our Privacy Statement updates.
If you have any questions about our
privacy practices, personal data processing activities, or would like to
exercise your rights under privacy laws, you may email us at dataprotection@bucoup.com, complete
our data subject rights request form Serafino
DSR Request Form, or write to us at Serafino Pte. Ltd., 10 Anson
Road, #21-07, International Plaza, Singapore 079903.
In your request, please describe how you would like us to assist or what rights you are exercising. We may need to request specific information from you to help us verify your identity and that you have the right to request what you are requesting. These are security measures to ensure that we do not disclose personal data to any person who has no right to receive it or otherwise process the data in unauthorized ways. We may also contact you to ask for further information about your request to clarify the scope of your request and speed up our response. We will respond to requests to exercise statutory rights according to applicable laws.