Privacy Notice

Effective as of April 21, 2025

Lutkan B.V. ("Lutkan," "we," "us," or "our") is committed to protecting the privacy of our users, partners, and customers. This Privacy Notice describes how we collect, use, disclose, and protect personal data when you use our media buying platform, NeuBids, and our monetization product, NeuPubs.

We have prepared this Privacy Notice to describe the types of data we collect from you and explain how, why, and when we collect this data to provide our Services to our Customers. In this Privacy Notice, the term ‘Customer’ refers to any business, advertiser, or publisher using Lutkan’s NeuBids or NeuPubs platforms. This Privacy Notice also identifies what rights you have concerning the collection of this data, such as the right to opt-out of interest-based advertising (also commonly referred to as targeted or personalized advertising).

Please note that this Privacy Notice does not apply to data we collect when you visit a Lutkan website, including https://www.lutkan.com/, www.neubids.com, and https://www.neupubs.com/. To learn how we handle data collected through our websites, please refer to the Lutkan Website Privacy Notice.

About Lutkan's Services

Lutkan provides media buying and monetization technologies designed to help advertisers and publishers improve performance through data-driven optimization.

With our proprietary technology, NeuBids (for programmatic media buying) and NeuPubs (for publisher monetization), Lutkan helps businesses identify high-value audiences, improve ad relevance, and optimize return on ad spend (ROAS). By leveraging real-time data insights, neural-driven optimizations, and transparent programmatic strategies, Lutkan enables advertisers to reach the right users at the right time while providing publishers with higher yield and sustainable revenue growth.

Lutkan has two different products:

NeuBids

NeuBids is a neural-powered (‘Neural-powered’ refers to our use of machine learning and AI algorithms for real-time decision making and optimization) media buying platform designed for advertisers looking to maximize their reach and engagement across digital channels. Whether you're a brand, agency, or performance marketer, NeuBids makes it seamless and efficient to execute high-impact programmatic campaigns.

By leveraging neural-driven optimizations and real-time data insights, NeuBids enables advertisers to target the right audience, refine bidding strategies, and improve ad performance across multiple channels. The platform helps businesses attract new customers, re-engage existing audiences, and drive conversions through connected, personalized ad experiences.

In addition, NeuBids provides advanced measurement and attribution tools, allowing advertisers to gain deep insights into their campaign performance, optimize their media spend, and make data-driven decisions for continuous growth.

NeuPubs

NeuPubs is a neural-powered monetization platform designed for publishers and media owners who want to maximize their advertising revenue and optimize their digital inventory. Whether you operate a website, app, or digital platform, NeuPubs helps you connect with high-value advertisers, increase fill rates, and improve overall yield through intelligent, data-driven monetization strategies.

With NeuPubs, publishers gain access to advanced audience insights, enabling them to attract premium demand partners and deliver high-performing ad placements. The platform leverages neural-driven optimizations to match the right ads with the right audiences, ensuring higher engagement and better revenue outcomes.

Additionally, NeuPubs provides transparent reporting and measurement tools, allowing publishers to track revenue performance, analyze ad effectiveness, and refine their monetization strategies. By integrating seamlessly with multiple demand sources, NeuPubs ensures publishers can efficiently monetize their inventory while maintaining a high-quality user experience.

Interest-Based Advertising with Our Products

Lutkan’s neural-powered technology helps advertisers and publishers deliver highly relevant ads to users based on their interests and online behavior. This approach, known as interest-based advertising, ensures that ads are shown to people most likely to engage with them, improving both user experience and campaign effectiveness.

Many of these ads appear on websites and mobile apps that rely on advertising revenue to offer free content. When you visit a website or app (a “Digital Property”) that partners with Lutkan, or see an ad delivered through NeuBids on a third-party platform, we may collect certain non-personal data from your device, as outlined in our Privacy Notice. Our platform then processes this data—along with additional insights—to help advertisers serve ads that are more relevant to you.

Interest-based advertising benefits both users and businesses:

• For users: Ads are better tailored to your interests, reducing irrelevant or intrusive experiences.
• For publishers: Websites and apps can optimize revenue by delivering ads that are more likely to be clicked.
• For advertisers: Brands can reach high-intent audiences in real time, making their campaigns more effective.

By leveraging neural-driven optimizations, NeuBids ensures that advertisers of all sizes—from startups to global brands—can compete effectively, reaching the right audience without requiring massive budgets. At the same time, NeuPubs empowers publishers to maximize their ad revenue while maintaining a high-quality user experience.

Example of Interest-Based Advertising

Imagine you’re researching new running shoes for your workout routine. You visit Google and search for “best running shoes for long distances.” A list of websites appears, including one from XYZ Sportswear. You browse their site, looking at different shoe models, but you don’t make a purchase just yet.

Since XYZ Sportswear uses NeuBids for its advertising campaigns, our neural-powered technology recognizes that your device visited their website and showed interest in specific products.

Later, as you browse the web, you see ads from XYZ Sportswear reminding you about the running shoes you viewed—perhaps with a limited-time discount or a special offer for first-time buyers. Additionally, you may see ads from other retailers offering related sports gear, such as athletic wear or smart fitness accessories, to complement your purchase.

This interest-based advertising approach helps brands reconnect with potential customers, improves ad relevance for users, and enables publishers to monetize their digital properties more effectively through NeuPubs.

Measurement and Attribution

Beyond interest-based advertising, Lutkan provides advanced measurement and attribution tools that help advertisers and publishers understand the impact of their campaigns and optimize their strategies.

Using neural-powered analytics, NeuBids enables advertisers to track key performance indicators (KPIs), such as conversions, engagement rates, and return on ad spend (ROAS). By collecting unique identifiers (e.g., cookie IDs, device IDs, or anonymized session data), Lutkan can measure whether users who saw an ad or visited a Digital Property later took a specific action, such as making a purchase, signing up for a newsletter, or returning to the website.

NeuBids: Media Buying Attribution

• Tracks the effectiveness of ad campaigns across multiple channels.
• Identifies which audience segments are most engaged with specific ads.
• Measures conversion paths to help advertisers refine their targeting and budget allocation.

NeuPubs: Monetization Insights

• Provides publishers with in-depth reporting on ad performance and revenue generation.
• Uses neural-driven optimizations to determine which ad formats and placements generate the highest engagement.
• Helps publishers understand audience behavior and improve inventory yield.

Example Use Case

A sporting goods retailer using NeuBids may want to know whether users who saw an ad for running shoes eventually made a purchase. By tracking unique identifiers from ad impressions to completed sales, NeuBids helps the retailer measure ad effectiveness and refine targeting strategies.

With real-time reporting and deep attribution analysis, Lutkan ensures that advertisers and publishers have the data-driven insights needed to make informed decisions and maximize the value of every ad impression.

1. Legal Basis for Processing Personal Data

Under the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA) (as amended by the California Privacy Rights Act (CPRA)), we must have a lawful basis for processing personal data. Lutkan processes data based on the following legal bases:

1.1 Consent (Article 6(1)(a) GDPR & CCPA Opt-In Requirements)

Lutkan relies on user consent for specific data processing activities, including:

• Setting cookies related to advertising and analytics.
• Processing data for personalized ad targeting.
• Users in jurisdictions where consent is required (e.g., California) may withdraw consent at any time through publisher-controlled consent tools or browser settings.
• Participation in the IAB Europe’s Transparency & Consent Framework (TCF): Lutkan adheres to the IAB TCF standards to ensure compliance with GDPR and other global privacy laws. Our partners use TCF-compliant consent management platforms (CMPs) to facilitate user opt-in and consent preferences.

1.2 Contractual Necessity (Article 6(1)(b) GDPR)

Lutkan process data to fulfill contractual obligations and provide services, such as:

• Delivering advertising and monetization services via NeuBids and NeuPubs.
• Measuring campaign performance and optimizing ad delivery.

1.3 Legitimate Interests (Article 6(1)(f) GDPR)

Lutkan processes certain data based on our legitimate business interests, provided that these do not override users' rights. Examples include:

• Fraud detection and security monitoring.
• Frequency capping to avoid excessive ad repetition.
• Aggregated reporting and analytics for advertisers and publishers.
• Under CCPA/CPRA: We ensure that all data classified as "personal information" (as defined under CCPA) is processed in accordance with users' rights.

1.4 Legal Obligations (Article 6(1)(c) GDPR & CCPA Business Compliance Requirements)

Lutkan may process personal data to comply with legal and regulatory obligations, such as:

• Responding to regulatory or governmental requests.
• Ensuring compliance with applicable data protection laws, including CCPA/CPRA provisions related to consumer rights.

1.5 Vital Interests (Article 6(1)(d) GDPR) (If Applicable)

In rare cases, we may process data to protect someone’s life or safety when legally required.

2. Data Transfers & Safeguards

Lutkan B.V. is based in the European Union and aims to keep personal data within the EEA whenever feasible. However, in providing our media buying and monetization services (e.g., through integrations with demand partners, fraud detection tools, or analytics platforms), personal data may occasionally be transferred to third countries, including the United States. When such transfers occur, we implement appropriate safeguards in accordance with applicable data protection laws. These may include Standard Contractual Clauses (SCCs) approved by the European Commission, adequacy decisions for countries deemed to provide an adequate level of protection, or—where required—explicit consent. We also evaluate our subprocessors and partners regularly to ensure ongoing compliance with GDPR and other international privacy standards.

3. Children’s Privacy (COPPA Compliance)

Lutkan does not knowingly collect, process, or store personal data from individuals under the age of 13 (or under 16 where applicable under GDPR). If we become aware that we have collected personal data from a minor without parental consent, we will take immediate steps to delete the information.

If a publisher or advertiser using NeuBids or NeuPubs operates a website or application directed toward children under the age of 13, they are responsible for ensuring compliance with the Children’s Online Privacy Protection Act (COPPA) and other applicable child data protection laws. Lutkan requires its partners to confirm that they are not collecting or processing children’s personal data without appropriate consent mechanisms in place.

If you believe that a child has provided us with personal information without parental consent, please contact us immediately at [email protected], and we will promptly investigate and remove the data as necessary.

4. CCPA/CPRA Compliance & Consumer Rights

California residents have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These rights include:

• Right to Know: You have the right to request details about the personal information we collect, process, and share.
• Right to Delete: You can request that we delete the personal information we have collected about you, subject to certain exceptions.
• Right to Opt-Out of Sale or Sharing of Personal Data: Lutkan does not sell personal data, but if we ever engage in data sharing under CCPA’s definition of “sale,” you have the right to opt out.
• Right to Correct Inaccuracies: You can request that we correct any inaccurate personal data we have about you.
• Right to Limit Use of Sensitive Personal Information: If applicable, you can request limitations on how we process sensitive personal data (e.g., precise geolocation).
• Right to Non-Discrimination: Exercising your privacy rights will not result in discriminatory treatment (e.g., denial of services or higher pricing).

How to Exercise These Rights

California residents can submit requests to exercise their rights under CCPA/CPRA by contacting us at:

• Email: [email protected]
• Physical Address: Lutkan B.V.,  Burgemeester Pabstlaan 10 C3, 2131 XE Hoofddorp Netherlands

To verify your identity, we may request additional information before processing your request.

5. How Users Can Manage Cookies & Tracking (Including CCPA Opt-Out)

Users can manage their advertising preferences and cookie settings through publisher-controlled consent tools, by adjusting their browser privacy settings, or by using the following opt-out mechanisms:

• U.S. Users (including California): DAA Opt-Out
• European Users (GDPR-compliant options): Your Online Choices
• Mobile Users: Adjust settings via Apple’s Limit Ad Tracking (iOS) or Android’s Opt-Out of Ads Personalization.
• IAB Europe TCF Opt-Out: Users in the EU can manage their ad preferences through IAB TCF-compliant consent management platforms (CMPs) available on publisher websites.

6. What Data We Collect

We collect the following categories of data in the provision of our Services for the purposes explained below.

Data We Automatically Collect from Your Device

When you interact with websites or applications that use NeuBids (for media buying) or NeuPubs (for monetization), Lutkan may automatically collect certain non-personal data from your device—unless you have opted out or declined to provide consent. This data is used to improve ad relevance, optimize campaign performance, and enhance user experience.

6.1 Cookies

We assign a unique identifier (cookie ID) to your device when you visit a Digital Property (website or app) that uses Lutkan’s technology. This helps us understand your online behavior and allows advertisers to serve relevant ads when you visit other sites.

6.2 Device Information

Technical details about the device you use to access a Digital Property, including:

• Operating system (e.g., Windows, macOS, iOS, Android)
• Device type (e.g., smartphone, tablet, desktop)
• Mobile device advertising identifiers (e.g., Apple IDFA, Android Advertising ID)
• Other unique identifiers (e.g., Android ID, UDID for older iPhones)

6.3 IP Address

We collect the IP address of your device when you access a Digital Property. This helps in fraud prevention, security checks, and geo-targeting for ad delivery.

6.4 Location Data

Based on your IP address, we determine non-precise geographic information, such as:

• Country, state, city, and postal code
• Language preferences (e.g., showing German ads if you're in Germany)
  Lutkan does not collect precise GPS coordinates.

6.5 Browser Data

Technical information about the browser you are using, including:

• Browser type (e.g., Chrome, Firefox, Safari)
• Browser version and capabilities (for ad rendering)

6.6 Activity on Digital Properties

We collect behavioral data about your activity on sites or apps that use Lutkan’s technology. This may include:

• Pages visited and time spent on each page.
• Buttons or links clicked.
• Products viewed, added to cart, or purchased.
• What site or ad led you to the Customer’s website

6.7 Ad Data

Information about ads you have been shown or interacted with, such as:

• The number of times an ad was displayed.
• The website or app where the ad appeared.
• Whether you clicked, viewed, or engaged with the ad.

Why We Collect This Data

This data allows Lutkan to:

• Deliver relevant ads tailored to your interests.
• Optimize campaign performance for advertisers and publishers.
• Improve ad targeting without using personally identifiable information (PII)
• Provide better user experience with meaningful content.

We prioritize data privacy and transparency and ensure compliance with GDPR, TCF, and other global privacy regulations.

Data We Collect from Third-Party Sources

In addition to the data, we collect automatically from devices, Lutkan also receives data from third-party sources to enhance campaign effectiveness and provide deeper insights for advertisers and publishers.

6.8 Campaign Performance Data

We collect data related to the performance of advertising campaigns, whether served through NeuBids or other advertising platforms. This includes:

• Impressions, clicks, and conversions on ads served.
• Engagement metrics (e.g., time spent on landing pages, interactions with ads)
• Attribution data (e.g., determining which ads led to a purchase or site visit)
• Cross-platform ad effectiveness (e.g., how ads perform across different channels such as web, mobile, and CTV)

This information helps advertisers optimize their bidding strategies, improve audience targeting, and maximize return on ad spend (ROAS) while allowing publishers to better understand ad revenue potential.

6.9 How We Use the Data We Collect

At Lutkan, we leverage neural-powered insights to create a seamless, data-driven advertising and monetization ecosystem that benefits both advertisers and publishers. Our two core products—NeuBids (for programmatic media buying) and NeuPubs (for publisher monetization)—work to ensure that advertisers reach the right audience with optimal campaign performance, while publishers maximize their ad revenue without compromising user experience.

Our data-driven approach helps businesses deliver relevant and effective advertising while ensuring ad-supported content remains free for users.

6.10 Optimized Ad Delivery & Performance

Our platform analyzes browser, device, and network data to ensure ads are delivered efficiently and optimized for performance:
NeuBids ensures ads load quickly, display correctly, and are served in viewable placements
NeuPubs maximizes fill rates, ensuring that publishers earn the highest possible revenue from each ad impression.

For example, if a publisher’s website receives mobile-heavy traffic, NeuPubs prioritizes mobile-friendly ad formats, while NeuBids ensures that advertisers serve properly formatted ads that fit those placements.

6.11 Audience Segmentation & Smart Targeting

• Lutkan uses advanced neural algorithms to segment audiences into different behavioral groups, such as:
• High-intent buyers (users likely to make a purchase)
• Casual browsers (users still researching)
• Frequent content consumers (users engaging with specific types of content)

This segmentation allows:
Advertisers to refine their targeting and bid more effectively
Publishers to better understand their audience and attract premium advertisers.

For example, a travel publisher can use NeuPubs to identify users researching vacation destinations and connect them with advertisers selling travel packages through NeuBids.

6.12 Frequency Capping & Ad Sequencing

To avoid ad fatigue, NeuBids and NeuPubs work together to:
Control how often a user sees the same ad (frequency capping)
Deliver ad sequences in the correct order, ensuring a smooth advertising journey.

For instance, if a user sees an initial brand awareness ad, NeuBids ensures they later receive a follow-up offer ad, leading to a higher conversion rate.

6.13 Reporting, Attribution & Yield Optimization

Lutkan provides real-time analytics to both advertisers and publishers:

NeuBids helps advertisers track ad performance through:

• Impression and click tracking.
• Conversion analysis (identifying which ads lead to purchases or sign-ups)
• Attribution modeling (determining which touchpoints drive sales)

NeuPubs helps publishers improve monetization with:

• Revenue reporting, including fill rates and CPM trends.
• Yield optimization, adjusting bid floors to maximize revenue
  

For example, if NeuBids detects that an ad has low conversions, it can adjust targeting. Similarly, if NeuPubs detects high engagement on a certain ad placement, it will prioritize higher-paying advertisers for that slot.

6.14 Fraud Prevention & Privacy Compliance

Lutkan ensures that all advertising activity is safe, transparent, and compliant with privacy regulations, including GDPR, TCF, and CCPA.

Fraud detection – Identifies and blocks invalid traffic (IVT), click fraud, and bot activity
Brand safety – Ensures that advertisers do not appear on inappropriate or low-quality websites
User privacy protection – Adheres to industry-standard consent frameworks and ensures compliance with user preferences.

For example, if NeuPubs detects suspicious traffic patterns from a website, it can prevent advertisers from wasting budget on fake impressions.

6.15 Data Sharing

At Lutkan, we are committed to transparency and privacy when it comes to how we share data. We only share non-personal, pseudonymous, and aggregated data with trusted third parties to ensure effective ad delivery, platform functionality, and compliance with legal requirements.

We may disclose data about you in the following cases:

6.15.1  With Customers (Advertisers & Publishers)

We may share data on how users interact with a Customer’s Digital Properties or ads to help them optimize campaigns.
This includes performance insights, such as impressions, clicks, engagement, and conversions to allow advertisers to refine targeting strategies.
Publishers using NeuPubs may receive audience insights to understand how users interact with their content and ad placements.

6.15.2 With Advertising Partners

We may share cookie ID data and ad-serving details with DSPs, SSPs, ad exchanges, and demand partners to ensure successful ad delivery to your device.
This data allows real-time ad bidding and ensures that the most relevant ad is shown based on user behavior.

6.15.3 With Service Providers

We work with trusted third-party vendors to support our business operations. These service providers help us with:
Data hosting & cloud storage (to securely store and process data)
Fraud detection & prevention (to identify and filter out invalid traffic)
Viewability & ad measurement (to ensure ads are displayed properly)

Example: If NeuPubs detects an increase in bot-driven traffic, it may share anomalous data patterns with a fraud prevention partner to block low-quality impressions.

7. In Connection with Legal Proceedings

We may share data when legally required to comply with binding court orders, subpoenas, or regulatory requests.
If necessary, we may disclose data to exercise, establish, or defend our legal rights or to protect the rights of our customers or third parties.

Example: If a regulator requests advertising logs to investigate potential privacy violations, we may provide relevant non-personal data in compliance with the law.

8. In Connection with a Business Sale or Merger

If Lutkan undergoes a merger, acquisition, or asset sale, data may be shared during the due diligence process and transferred as part of the transaction.
Any data shared in such a case would be handled in accordance with applicable privacy laws and security protocols.

Example: If a larger ad tech firm acquires Lutkan, they may receive aggregated performance data to assess the effectiveness of NeuBids and NeuPubs before finalizing the acquisition.

What We Don’t Do:

We do not sell personal data to third parties.
We do not share personally identifiable information (PII) such as names, emails, or phone numbers.
We do not enable cross-site tracking outside of legitimate advertising purposes.

9. Cookies and Tracking Technologies Used by Lutkan

Lutkan provides programmatic media buying (NeuBids) and monetization (NeuPubs) solutions, enabling advertisers and publishers to optimize their digital advertising performance. To support these services, we use a minimal number of tracking technologies to measure ad effectiveness, user engagement, and referral sources, while ensuring compliance with privacy regulations.

Cookies Used by Lutkan (NeuBids & NeuPubs)

These cookies enable advertisers to track performance metrics and help publishers optimize revenue while maintaining a positive user experience.

Category	Cookie Name	Purpose
Tracking Cookies	__lutkan_ad	Tracks ad impressions, clicks, and conversions
	__lutkan_shared	Logs referral sources and cross-session user activity
	__lutkan_fpc	First-party cookie for tracking session activity (referrer, timestamps, engagement)

9.1 How Lutkan Uses These Cookies

Ad Performance & Attribution

• NeuBids tracks ad exposure and conversions to measure campaign effectiveness.
• NeuPubs logs where users come from and how they interact with ads on publisher websites.
• Session data helps determine which sources drive the most valuable traffic.

Audience Insights & Optimization

• These cookies help understand ad engagement patterns and improve ad delivery strategies.
• Advertisers benefit from insights on which audiences respond best to their campaigns.
• Publishers gain better revenue opportunities by serving high-performing ad placements.

Privacy & Data Protection

• Lutkan does not collect personally identifiable information (PII) through cookies.
• User privacy is respected through publisher-controlled consent mechanisms.
• Tracking is limited to permitted use cases, ensuring data security and compliance.

9.2 What We Don’t Do with Cookies

We do not store personal data such as names, emails, or phone numbers.
We do not set cookies for frequency capping or bid optimization.
We do not sell or share user data with unauthorized third parties.

9.3 How Users Can Manage Cookies

Users can manage their advertising preferences and cookie settings through publisher-controlled consent tools or by adjusting their browser privacy settings.

9.4 Data Retention Policy

Lutkan is committed to ensuring responsible data management by retaining information only for as long as necessary to provide our services and comply with legal and business obligations. Below is an outline of how long we retain different types of data within our NeuBids (media buying) and NeuPubs (monetization) platforms.

9.5 Customer Data (CRM Data)

• If either the Customer or Lutkan explicitly terminates the services, Customer CRM Data will be deleted within 90 days from the termination date.
• If a customer’s account has been inactive for 365 days, and no product usage or media spend has occurred in the past 30 days, the Customer CRM Data will be deleted on the 366th day of inactivity.
• If a customer account is suspended for 90 days or more, the Customer CRM Data will be deleted.

Customers may request deletion of CRM Data at any time by contacting [email protected].

9.6 Mobile Identifiers and Cookie Identifiers

• Cookies set by Lutkan expire after 13 months from the last interaction with a Digital Property using our technology.
• If a user visits another Digital Property using Lutkan’s technology within the 13-month period, the expiry period resets from that date.
• Mobile identifiers’ expiration periods are controlled by the user’s device settings.

9.7 Personal Data Associated with Mobile and Cookie Identifiers (Browsing History)

• Browsing history data (e.g., websites visited, ads clicked) is retained for 12 months before deletion.

9.8 Personal Data Related to Advertising Bidding Requests

• Data logged from an advertising bid request (e.g., cookie identifier, IP address, requesting domain URL, browser information) is deleted after 60 days.
• Data related to bids placed to display an advertisement (e.g., cookie identifiers, mobile identifiers, ad bid details) is deleted after 90 days.

9.9 Personal Data Related to Ad Display

• Data related to ad impressions and interactions (e.g., cookie identifiers, ad viewed or clicked) is retained for 12 months before deletion.

10. Security

Lutkan is committed to ensuring the security and integrity of the data we collect and process. We implement technical, administrative, and organizational safeguards to protect against:

• Accidental or unlawful destruction
• Loss, alteration, or unauthorized access
• Unauthorized disclosure or transmission of data

These security measures are particularly critical when processing involves the transmission of data over a network, ensuring protection against unauthorized access and unlawful data processing. Lutkan continuously evaluates its security protocols and compliance standards to maintain a secure and privacy-focused advertising ecosystem.

If you suspect unauthorized access to your data, contact us at [email protected].

Data Breach Notification Policy

In the event of a security breach that compromises personal data, Lutkan follows a structured incident response plan to mitigate risks and ensure regulatory compliance. If a data breach occurs:

• Notification Timeline: We will notify affected users within 72 hours of detecting a breach, as required by GDPR Article 33 and other applicable laws.
• Method of Notification: Users will be informed via email, website notices, or other appropriate communication channels based on the severity of the breach.
• Information Provided: The breach notification will include:
• The nature and scope of the breach.
• The type of data affected.
• Steps Lutkan is taking to address the incident.
• Recommended security measures for affected users.
• Regulatory Reporting: If required, we will report the breach to data protection authorities and cooperate with investigations.

For security concerns or inquiries, users can contact [email protected].

11. Third-Party Processors We Use

To provide our advertising services through NeuBids (media buying) and NeuPubs (publisher monetization), we work with trusted third-party vendors that process data on our behalf. These include:

For NeuBids (Media Buying Platform)

Third-Party Processor	Purpose of Processing	Location
Amazon Web Services (AWS)	Cloud hosting, data storage, and security	Various (EEA & U.S.)
Beeswax (Owned by FreeWheel, a Comcast Company)	Programmatic advertising bidding and campaign execution	U.S.
Beeswax-Integrated Services (e.g., DoubleVerify, IAS, Moat)	Ad verification, fraud detection, brand safety, viewability tracking	U.S. (via Beeswax)

Note: Certain Beeswax-integrated services (e.g., DoubleVerify, IAS) process data under Beeswax’s account, not Lutkan’s direct control. Any data handling by these services is subject to Beeswax's policies.

For NeuPubs (Publisher Monetization Platform)

Third-Party Processor	Purpose of Processing	Location
Amazon Web Services (AWS)	Cloud hosting, data storage, and security	Various (EEA & U.S.)
Google AdSense	Monetization, ad delivery, programmatic advertising	Various (Global)
Google Ad Manager (GAM)	Ad serving, auction management, header bidding	Various (Global)
Improve SSP	Supply-side platform (SSP) for publisher inventory monetization	Various (Global)
Xandr SSP	Programmatic ad selling, real-time bidding (RTB), ad exchange	U.S.

Note: NeuPubs relies on AWS for cloud hosting and server infrastructure in addition to ad exchanges and SSPs for monetization. Ads served through these platforms may involve automated decision-making, real-time bidding (RTB), and targeting based on publisher-controlled consent mechanisms.

12. Your Rights Regarding Your Personal Data

Lutkan is committed to respecting your rights under the General Data Protection Regulation (GDPR) (Regulation No. 2016/679/EU) and other applicable data protection laws. You have the following rights regarding the personal data we process about you.

If you have any questions about how we process your personal data or wish to exercise your rights, you can contact our Data Protection Officer (DPO) at:

• Email: [email protected]
• Postal Address: Lutkan B.V., Burgemeester Pabstlaan 10 C3, 2131 XE Hoofddorp, Netherlands

12.1 Right of Access and Data Communication

You have the right to request access to the personal data we hold about you. Upon request, we will provide a copy of your personal data and details on how it is being processed.

12.2 Right to Object to Processing

If we process your personal data based on our legitimate interest, you have the right to object to this processing for reasons related to your particular situation. If you object, we will stop processing your data unless we can demonstrate compelling legitimate grounds to continue processing.

12.3 Right to Withdraw Consent

When processing is based on your consent, you have the right to withdraw your consent at any time. Once withdrawn, we will stop processing your personal data unless we have a lawful reason to continue.

12.4 Right to Deletion ("Right to Be Forgotten")

You may request the deletion of your personal data in certain cases, such as:

• If you have withdrawn your consent for processing.
• If you have objected to processing and there are no overriding legitimate grounds for continuing it.
• If your data has been processed unlawfully.

12.5 Right to Rectification

If the personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it.

12.6 Right to Restrict Processing

You have the right to request the restriction of processing in the following cases:

• You contest the accuracy of your personal data, and we need time to verify it.
• The processing is unlawful, but you prefer restriction over deletion.
• We no longer need the data, but you require it for legal claims.
• You object to processing, and we are assessing whether our legitimate grounds override your rights.

While processing is restricted, we will not use your data unless you give explicit consent, or it is required for legal reasons.

12.7 Right to Data Portability

You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, allowing you to transmit it to another data controller.

12.8 Right to Lodge a Complaint

If you believe your rights have been violated or that your data has been processed unlawfully, you have the right to lodge a complaint with the relevant data protection authority in your country.

For complaints in the European Union, you can contact your local Data Protection Authority (DPA).

12.9 Response Time for Requests

We will respond to all data requests within a reasonable timeframe, which will not exceed one month from the date of receipt. If your request is complex or requires additional verification, we may extend the response period but will notify you accordingly.

To exercise any of your rights, contact us at: [email protected]

13. Changes to this Privacy Notice

Lutkan reserves the right to update or modify this Privacy Notice at any time at our discretion. When changes are made, we will:

Publish the updated Privacy Notice online
Update the notice’s effective date.

We encourage you to review this Privacy Notice periodically to stay informed about how we collect, use, and protect your data.

If applicable law requires us to obtain your explicit consent before implementing material changes, we will do so in accordance with legal requirements.