Page 1 | Introduction and scope of application
NovaGlobe Media highly values your privacy. We are committed to safeguarding the personal data of advertisers, platform users, and all individuals who access our services or website (hereinafter referred to as “you” or “users”), and we handle data in a transparent, legal, and fair manner. This privacy policy will detail how we collect, use, share, and protect your information, as well as your rights under relevant laws.
1.1 Applicable objects of this Policy
This Privacy Policy applies to the following usage scenarios and objects:
All advertisers who register accounts and use services through the NovaGlobe Media advertising platform;
All commercial users who upload advertising materials and participate in content cooperation on our platform;
All users who visit our website, apply for cooperation or receive service recommendation information;
All audience users who receive our ads through third-party channels (only at the level of behavior statistics, not involving personal identity information).
1.2 Jurisdictional law and compliance framework
NovaGlobe Media strictly complies with the following laws and regulations when processing user information:
General Data Protection Regulation (GDPR);
UK Data Protection Act 2018 (UK DPA 2018);
Other applicable data privacy, advertising and communications regulations.
All data processing mentioned in this policy is based on the premise of legality, fairness and necessity, and will not be used beyond the purpose of the service.
1.3 Description of data control party
NovaGlobe Media is the “data controller” of your personal data and is responsible for deciding the way and purpose of data processing. We only collect information on the basis of clear business needs, and our processing behavior is subject to the dual supervision of internal data governance mechanism and external legal constraints.
1.4 Reading and acceptance
Please read and understand this Privacy Policy in full before you start using our Platform services or submit any information. By using our services, you agree to all the terms of this Privacy Policy and authorize us to process your relevant data according to law.
If you do not agree with any part of this Policy, you should stop using NovaGlobe Media’s platform and services.

Page 2 | Types of information we collect
In order to provide you with accurate, efficient and compliant advertising media services, NovaGlobe Media will collect different categories of information related to you during the service process. We will only collect the minimum and reasonable amount of data when necessary, in order to perform advertising placement, customer support, effect optimization and technical support functions.
2.1 Basic account information
When you register as an advertiser or partner with NovaGlobe Media, we may collect the following information:
Company name and industry category
Name and position of the authorized representative
Log in to the account (user name) and encrypted password
Business requirements and target market description
Advertising budget preference, service subscription record
This information helps us build customer profiles and customize personalized services.
2.2 Advertising and delivery data
During the delivery process, we automatically record the following data related to the AD campaign:
Impressions (impressions), click-through rate (CTR), conversion path and frequency
Material usage status, investment budget and actual consumption
Release time, geographical coverage and audience behavior response
Terminal type (mobile phone/computer), operating system and browser information
This data is used to optimize AD performance, generate reports and measure ROI (return on investment).
2.3 Technology and access information
When you visit our website or use the features of the Platform, we may collect technical information through the log system, including but not limited to:
IP address and geographic location estimation
Browser type, language Settings, operating system information
Page view behavior, dwell time, click path
Referral source website or advertising channel
Device identifiers (such as cookie ID, user agent UA)
This data helps us protect the security of the platform, improve the interface experience, and perform functional monitoring.
2.4 Behavioral and preference data (in anonymous or de-identified form)
When you interact with the Platform, we may collect the following types of behavioral data through third-party tools:
User response to AD content (click, jump, interactive behavior)
Clicks and conversions on external platforms where we place ads
Page visits and repeat visits tracked by cookies or pixels
We will not directly bind these actions to your real identity, and we will obtain your authorization before collecting them.

Page 3 | How we collect data
All information collected by NovaGlobe Media comes from legal sources and follows the principles of “minimum necessity” and “clear purpose”. When collecting data, we rely on platform technology, customer operation behavior and third-party integration tools to ensure that the collection method is transparent, compliant and controllable.
3.1 Customer initiative
We will collect information that you voluntarily provide in the following scenarios:
Company information and business objectives entered when registering an account, filling out a service application form, and creating an advertising project;
Submit advertising materials and set advertising parameters (such as advertising cycle, target population, budget);
Demand information and communication records provided when interacting with account managers and support teams;
Feedback content filled in during participation in a questionnaire, survey or marketing activity.
3.2 Platform automatic collection
When you use our advertising platform, management interface or view reports, the system will automatically collect the following technical and operational information:
Page access record, advertising management action, material upload log;
Device information (e.g. browser type, operating system, screen resolution);
IP address, language Settings, access time and time zone;
User interaction path (such as click, jump, stay time);
A unique identifier generated by Cookies and other tracking technologies.
This information helps us evaluate the user experience, optimize advertising configurations, and ensure that the platform is secure and stable.
3.3 Third-party channels and integration
We may also obtain information related to you from third parties in the following ways:
Click feedback and delivery performance data from advertising channels (e.g., Google, Meta, TikTok);
You authorize the external account or system connected (such as CRM, API interface, advertising data center);
The material parameters and effect data provided by the producer or strategic partner of the cooperation;
User behavior data (anonymized) provided by third-party analytics services (such as Google Analytics).
All data obtained through third parties is based on your authorization or relevant service contract, and the platform is only used for predetermined purposes, and access control and data isolation are set up technically.
3.4 Use of Cookies and Tracking Technologies
We use Cookies, pixel tags and local storage technologies to enhance the functionality of our platform and analyze the effectiveness of our advertising. These technologies allow us to:
Remember your preferences on the platform;
Track the frequency of advertising reach and user behavior response;
Implement cross-device and cross-platform advertising data synchronization;
Targeted delivery and remarketing campaigns will be implemented with your consent.
You can limit or remove Cookies through your browser Settings and manage your privacy preferences on your first visit.

Page 4 | How we use this data
The data collected by NovaGlobe Media is used only for clear business purposes. Our core purpose is to provide customers with a more efficient, personalized and measurable advertising experience through data-driven methods, and to ensure the safety of platform operation and service quality.
4.1 Provide and execute advertising services
We use your data to:
Allocate and execute advertising display tasks (including material selection, channel delivery and frequency control);
Identify the target audience and conduct behavior matching to achieve accurate advertising reach;
Manage advertising budget, set delivery cycle and regional distribution rules;
Assist customers to set placement strategies and generate implementation plans.
These actions are based on the delivery requirements submitted by you and the instructions set by the platform.
4.2 Effect monitoring and strategy optimization
To ensure the best return on our customers’ advertising, we will use advertising data and behavioral data to:
Real-time analysis of click-through rate, display volume, conversion path and cost indicators (such as CTR, CVR, ROI, etc.);
Automatically adjust budget allocation, material performance priority and touch frequency;
Implement A/B testing and creative material rotation to find the best version;
Generate visual reports and launch reviews to help customers review launches and plan budgets.
4.3 Content personalization and advertising customization
With the help of the system’s built-in user behavior model and audience tagging capabilities, we may:
Show more relevant advertising content for different terminals, languages or access habits;
Recommend the matching advertising style and communication scene according to the user’s behavior history;
Provide creative suggestions and communication rhythm that meet the business objectives of different industry customers.
This process is completed under the premise of anonymity or desensitization, and does not involve direct identification of users’ personal identity.
4.4 Platform maintenance and function improvement
We use technical logs and access data to:
Ensure the security of the platform system, prevent abuse, fraud and data injection;
Monitor performance issues and respond quickly to errors or exceptions;
Analyze user interaction path to optimize the platform interface and operation process;
Develop new features or enhance existing service modules to meet the needs of the advertising industry.
4.5 Compliance Obligations and Risk Control
We may also process data for compliance and risk control purposes, including:
Respond to government regulations, legal agencies and industry organizations’ requirements for advertising transparency and data flow;
Comply with GDPR, UK DPA and advertising regulations (such as CAP Code);
Establish anti-cheating model and launch authenticity verification mechanism;
Support platform content review and media transparency report generation.

Page 5 | Legal basis
In accordance with the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018 (UK DPA), we must provide a legal basis for each data processing activity. NovaGlobe Media conducts all kinds of data collection and use activities based on the following basis, and ensures that each processing behavior has a clear and traceable legal reason.
5.1 Contract performance
When you register to use NovaGlobe Media’s advertising platform or enter into a service agreement with us, we will process your basic account information, placement instructions and project execution data to ensure that:
Provide normal services such as advertising display, strategy execution and report delivery;
Track the effect of the investment and adjust the project configuration according to the agreement;
Send you platform notifications, cooperation updates and task arrangements.
These data processing is necessary to fulfill the contract with you.
5.2 Legitimate interests
We will process the data for legitimate business purposes without prejudice to your rights and freedoms:
Improve the effect of advertising placement, identify technical problems and system loopholes;
Preventing fraud or abuse of the platform;
Conduct user behavior statistics and interface improvement;
Promote product optimization and new function research and development.
When using this basis, we always assess the impact on user privacy to ensure that the processing is within a reasonable range.
5.3 User Consent (Consent)
In the following circumstances, we will seek your explicit consent before processing the data:
Using Cookies and tracking technology to collect behavioral data for purposes such as remarketing, personalized recommendations, etc.;
Using the data to send marketing messages or promote content on the platform;
Provide data to third-party platforms to display targeted advertising;
Use non-essential third-party analytics tools (such as deep profiling).
You have the right to revoke any granted consent at any time and can do so through the Cookie Settings or account preferences interface.
5.4 Legal Obligations (Legal Obligation)
We may process or share your information based on legal obligations in the following circumstances:
Respond to court subpoenas, regulatory requirements and government investigations;
Comply with legal requirements for financial audit, data retention and information disclosure;
Comply with data submission obligations as required by UK advertising regulators (such as ASA) or EU data management authorities.
Such processing will be performed to the minimum necessary and will prioritize data security.
5.5 Protection of vital interests (Vital Interests)
In extremely rare cases, such as to protect the important legitimate rights and interests of customers, platforms or third parties, we may conduct data processing related to security or fraud prevention and control, but such processing must be based on explicit authorization or legal framework.

Page 6 | Data sharing and third party access
In the process of advertising placement, strategy optimization and service delivery, NovaGlobe Media may share some data with certain types of third parties within a controlled scope. However, we always adhere to the principle of “clear authorization, legal purpose and controllable protection” to ensure that all sharing behaviors comply with the requirements of regulations such as GDPR and UK DPA.
6.1 The objects we may share include:
(1) Advertising distribution channels and media platforms
In order to execute the advertisement, some data will be shared to the media channels you specify or we configure on your behalf, such as:
Google Ads / Meta / YouTube / TikTok / Local Portal and OHH advertising system
The data content includes the delivery material, audience parameters, behavior transformation indicators, etc
All platforms are authorized under your account, and NovaGlobe Media is not responsible for any operations outside the scope of use of third-party platforms
(2) Creative and content service providers
When a client commissions NovaGlobe Media to perform content customization, advertising creation, or video design services, we share with the entrusted content team:
Non-sensitive information such as customer brand style guide, creative direction statement, target audience characteristics, etc
The partner shall sign a confidentiality agreement and shall not use the relevant data or materials outside the project
(3) Data analysis and security technology service providers
In order to enhance the platform optimization capability and data security, we may integrate the following services:
Third-party data validation platforms (such as click anti-cheating systems, traffic visibility tools)
Data visualization and behavior analysis plug-ins (such as Google Analytics)
This type of integration is connected through the platform API, and access is controlled by permission grading, log recording, and data isolation mechanisms
(4) Regulatory compliance agencies and legal agencies
Subject to legal requirements, we may disclose data to the following institutions:
British Advertising Standards Board (ASA) or other compliance regulator
When a court, an investigating agency or an administrative law enforcement unit receives a formal legal request
The scope of disclosure is limited to data fragments necessary for the performance of legal obligations, and we will try our best to inform customers of the relevant processing
6.2 We will not share data with the following institutions:
Commercial alliances, data providers outside the platform or unrelated third parties that have not been authorized in writing by customers
Any original data that directly identifies the user
Any use of data for purposes unrelated to NovaGlobe Media advertising services (such as resale of advertising, data trading, data repositioning, etc.)
6.3 Compliance guarantee of third-party data processing
All partners, suppliers and service platforms must sign the Data Processing Agreement (DPA);
Data sharing behavior should follow the “minimum available principle”, and the scope of sharing is limited to the needs of business purposes;
Enable access log recording, encrypted transmission, authentication and access permission audit;
Conduct regular data security review of partners and reserve the right to terminate cooperation.

Page 7 | Data storage and protection measures
NovaGlobe Media is well aware of the sensitivity of advertising data and customer information. Therefore, we have established a comprehensive data security and compliance protection mechanism to ensure the confidentiality, integrity and availability of customer information throughout its life cycle. The following are our core measures in terms of data storage and security control:
7.1 Data storage mode and physical location
All customer data is stored in a controlled environment on the cloud server, and the infrastructure complies with international information security standards such as ISO/IEC 27001, SOC 2 or equivalent level;
The physical location of the data centre is in the UK and EU to ensure compliance with GDPR requirements for “data retention in the region”;
The specific analysis model and log system use remote backup mechanism to prevent catastrophic loss.
7.2 Data access permission management
The platform system uses the minimum permission principle to configure the access level of accounts to ensure that unauthorized users cannot access sensitive data;
Internal employees who access customer data need to be approved by the security team, and bind unique identity and log tracking mechanism;
The customer can set the permissions of its sub-account within the platform to determine which members can view, modify or export data.
7.3 Data transmission and processing security
All data transmission processes are encrypted end-to-end using TLS 1.2/1.3 protocol;
In the process of data processing and algorithm execution, hierarchical encryption, sandbox isolation and real-time verification mechanism are enabled;
Advertising materials are uniformly transcoded and standardized in the system to prevent code injection and executable script attacks.
7.4 Intrusion defense and security monitoring
Enable real-time firewall, intrusion detection (IDS) and malicious request interception system;
Use intelligent anomaly detection model to identify abnormal access behavior, repeated clicks, account collision, etc.;
The system deploys daily security scans to repair potential vulnerabilities and configuration risks in a timely manner.
7.5 Data retention period
Customer advertising data and behavior logs are usually retained for 12 months for effect analysis and report generation;
Some data related to compliance, settlement or historical reconciliation may be retained for up to 24 months as required;
After the data retention period expires, the platform will perform an automatic cleanup procedure or delete it in advance at the customer’s request.
7.6 Data loss and response mechanism
Once a potential data breach is detected, we will notify affected customers through the platform notification mechanism within 72 hours;
The platform security team will immediately start the emergency response process and cooperate with relevant regulatory agencies to report;
All event processing processes are fully audited, and customers can apply to view a summary of the event analysis results.

Page 8 | User rights statement
As a data subject, you have a number of clear rights under the UK Data Protection Act 2018 and the European Union’s General Data Protection Regulation (GDPR). NovaGlobe Media respects and protects these rights and provides easy access to them to ensure that your data is always in your control.
8.1 Right of Access
You have the right to request confirmation from us whether your personal data is being processed and to request:
Description of the type and purpose of data we hold;
The source and recipient of the data;
Data retention period;
Notes relating to automated decision making (if applicable).
We will provide a copy free of charge within 30 days of receipt of the request (unless there are complex circumstances).
8.2 Right to Rectification (Right to Rectification)
If you believe that any information we hold about you is inaccurate or incomplete, you have the right to request us to correct or supplement the data. We will complete the modification of the data as soon as possible after verification of identity and notify all parties sharing the data simultaneously.
8.3 Right to Erasure (Right to Erasure)
In the following circumstances, you may request us to delete your data:
Data is no longer used for the original purpose of collection;
You withdraw your original consent and we have no other legal basis to retain the data;
Data is illegally processed or violates privacy laws;
You object to the processing and there is no higher priority legitimate reason for continuing the processing.
If there is no legal obligation to reserve, we will complete the deletion within 30 days.
8.4 Right to Restrict Processing (RTRP)
In some cases, you may request us to temporarily freeze the processing of data, such as:
When you are verifying the accuracy of the data;
Data processing may be illegal but you want us to keep it rather than delete it;
We no longer need the data, but you still need to keep it in order to exercise your legal rights.
8.5 Right to data portability (Right to Data Portability)
If data processing is based on your consent or contract and is automated, you may request that the data be exported in a structured, common, readable format and transmitted to a third party system of your choice.
8.6 Right of objection (Right to Objection)
You may at any time object to our data processing based on “legitimate interests” or “public interest”, especially in relation to:
Data analysis or behavior tracking for direct marketing purposes;
Create user profiles (Profiling) or targeted advertising.
Once rejected, we will immediately stop processing the relevant data without affecting your service experience.
8.7 Right to object to automated decision-making (Right to Objection to Automated Decision-Making)
If the platform uses a certain algorithm to automate your evaluation (such as advertising content matching), you can request human intervention and have the right to state your personal position, so as to avoid being completely determined by the system.
8.8 Mode of exercise of rights
You may exercise the above rights in the following ways:
Submit requests through the platform account management interface;
Privacy for NovaGlobe Media

Page 9 | Cookies and Tracking Technology Description
To optimize advertising performance, enhance the platform’s user experience, and support content personalization and behavior analysis, NovaGlobe Media uses a variety of Cookies and tracking technologies. We are committed to complying with the ePrivacy Directive (ePrivacy Directive) and GDPR’s Cookie regulations throughout all relevant data processing processes, and provide users with clear control.
9.1, What are Cookies?
Cookies are small text files stored on your device when you visit a website. They identify browsers, save Settings, analyze visits and improve the interactive experience. Cookies themselves do not contain personally identifiable data, but can be combined with other data to form a behavioral portrait.
9.2 Types of Cookies we use
The NovaGlobe Media platform and website may use the following types of Cookies:
Necessary type Cookies (Strictly Necessary)
Used to ensure the normal operation of basic functions of the platform, such as login verification, form submission, access security control, etc. Cannot be closed.
Functional Cookies (Functional)
Helps us remember your preferences on the platform, such as language, interface layout, advertising target area, etc.
Performance Cookies (Performance/Analytics)
Collect user behavior and interaction patterns on the platform, such as click frequency, page jump path, access duration, etc., to optimize system performance.
Advertising Cookies (Targeting / Marketing)
Record information such as click, display frequency and conversion behavior of advertisements to help us and our advertising partners provide more relevant advertising content.
9.3 Third-party tracking technology
We integrate some third-party tools (such as Google Analytics, Meta Pixel, etc.) into the platform to support:
Advertising effect monitoring and conversion tracking
Unified view of multi-platform delivery data
Re-marketing of audience and modeling of behavioral segmentation
The activation of all third-party Cookies will be with your explicit authorization and in accordance with the unified Cookie management policy of the Platform.
9.4 User control and management
You can manage your Cookie Settings by:
When you first visit the website, select accept, reject or customize Cookie type in the pop-up window;
Clear or block all Cookies in your browser Settings;
Update the authorization status through the “Privacy Preferences Center” of the platform whenever applicable;
Use the Do Not Track (DNT) feature (supported by some browsers).
Please note: Turning off certain Cookies may affect the normal use of some functions of the platform.
9.5 Cookie retention period
The storage period of different Cookies may range from session (Session) to up to 12 months. The detailed list of Cookies and their retention period can be viewed on the platform’s Cookie policy page.

Page 9 | Cookies and Tracking Technology Description
To optimize advertising performance, enhance the platform’s user experience, and support content personalization and behavior analysis, NovaGlobe Media uses a variety of Cookies and tracking technologies. We are committed to complying with the ePrivacy Directive (ePrivacy Directive) and GDPR’s Cookie regulations throughout all relevant data processing processes, and provide users with clear control.
9.1, What are Cookies?
Cookies are small text files stored on your device when you visit a website. They identify browsers, save Settings, analyze visits and improve the interactive experience. Cookies themselves do not contain personally identifiable data, but can be combined with other data to form a behavioral portrait.
9.2 Types of Cookies we use
The NovaGlobe Media platform and website may use the following types of Cookies:
Necessary type Cookies (Strictly Necessary)
Used to ensure the normal operation of basic functions of the platform, such as login verification, form submission, access security control, etc. Cannot be closed.
Functional Cookies (Functional)
Helps us remember your preferences on the platform, such as language, interface layout, advertising target area, etc.
Performance Cookies (Performance/Analytics)
Collect user behavior and interaction patterns on the platform, such as click frequency, page jump path, access duration, etc., to optimize system performance.
Advertising Cookies (Targeting / Marketing)
Record information such as click, display frequency and conversion behavior of advertisements to help us and our advertising partners provide more relevant advertising content.
9.3 Third-party tracking technology
We integrate some third-party tools (such as Google Analytics, Meta Pixel, etc.) into the platform to support:
Advertising effect monitoring and conversion tracking
Unified view of multi-platform delivery data
Re-marketing of audience and modeling of behavioral segmentation
The activation of all third-party Cookies will be with your explicit authorization and in accordance with the unified Cookie management policy of the Platform.
9.4 User control and management
You can manage your Cookie Settings by:
When you first visit the website, select accept, reject or customize Cookie type in the pop-up window;
Clear or block all Cookies in your browser Settings;
Update the authorization status through the “Privacy Preferences Center” of the platform whenever applicable;
Use the Do Not Track (DNT) feature (supported by some browsers).
Please note: Turning off certain Cookies may affect the normal use of some functions of the platform.
9.5 Cookie retention period
The storage period of different Cookies may range from session (Session) to up to 12 months. The detailed list of Cookies and their retention period can be viewed on the platform’s Cookie policy page.