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top of page Privacy Policy Last Updated: October 4, 2026 1. Introduction Volasim Ltd (“VOLASIM,” “Company,” “we,” “our,” or “us”) respects your privacy and is committed to protecting personal data. VOLASIM operates in more than one capacity within the digital ecosystem: as a developer and publisher of mobile applications and other digital properties; and as a Demand-Side Platform (“DSP”) and programmatic advertising technology provider, facilitating the purchase, delivery, measurement, optimization, security, and operation of digital advertising. This Privacy Policy explains how VOLASIM collects, receives, uses, shares, and otherwise processes personal data in connection with: our website at https://www.volasim.com; mobile applications developed or published by VOLASIM; our DSP and programmatic advertising services; advertising requests, impressions, clicks, conversions, and related programmatic advertising activity; and communications and business relationships with customers, publishers, advertisers, technology partners, and other users of our services. Where applicable, VOLASIM participates in or operates in accordance with the IAB Europe Transparency & Consent Framework (“TCF”) and processes applicable transparency and consent signals communicated through participating Consent Management Platforms (“CMPs”). The specific data we process and the purposes for which it is processed depend on the service, application, advertising environment, applicable law, and the privacy choices made by the user. 2. Our Roles in Processing Personal Data Depending on the circumstances, VOLASIM may act as a data controller, joint controller, or processor/service provider. A. VOLASIM as an App Developer and Publisher When users interact directly with a VOLASIM application or digital property, VOLASIM may act as the publisher or first party responsible for determining certain purposes and means of processing. Our applications may also integrate third-party advertising, analytics, attribution, fraud-prevention, measurement, or other technology providers. Where required, users are provided with transparency and choices regarding such third parties through an appropriate consent mechanism or CMP. B. VOLASIM as a DSP and Advertising Technology Vendor When VOLASIM provides DSP and programmatic advertising services, we may receive data from publishers, advertisers, ad exchanges, supply-side platforms (“SSPs”), CMPs, measurement providers, attribution partners, fraud-prevention providers, and other authorized advertising technology partners. In this context, VOLASIM may participate in real-time bidding (“RTB”) and other programmatic advertising processes and may receive privacy signals, including TCF Transparency and Consent Strings (“TC Strings”), indicating the choices made by users. Where the TCF applies, VOLASIM processes data only for the purposes and under the legal bases declared by VOLASIM in the applicable IAB Europe Global Vendor List (“GVL”) registration and in accordance with applicable user choices. 3. Information We Collect or Receive Depending on the relevant product or service, we may collect or receive the following categories of data. A. Information You Provide Directly This may include: name; email address; telephone number; company or business information; account details; information submitted through contact forms; customer support communications; and other information you voluntarily provide to us. B. Device and Technical Information This may include: IP address; device type and model; operating system and version; browser type and version; language settings; application identifier; SDK information; device configuration; network and connection information; timestamps; approximate location inferred from an IP address, where applicable; mobile advertising identifiers, where available and permitted, such as IDFA or Android advertising identifiers; and other technical identifiers or signals associated with a device or advertising request. C. Advertising and Programmatic Data In connection with our DSP and programmatic advertising services, we may process information including: bid requests and bid responses; advertising impressions; advertising opportunities; clicks and interactions; conversion events; campaign identifiers; creative identifiers; publisher or application identifiers; advertising placement information; contextual information relating to the website or application displaying an advertisement; device and browser information; advertising identifiers; frequency and recency information; fraud and invalid traffic signals; campaign performance data; attribution information; and consent, objection, and other privacy signals. D. Application Usage Data Where applicable, we may process: app launches and sessions; feature usage; interaction events; crash and diagnostic information; advertising interactions; application version; installation and attribution information; and other technical application events. E. Cookies, SDKs, Local Storage and Similar Technologies Our websites, applications, and advertising services may use or interact with cookies, software development kits (“SDKs”), mobile advertising identifiers, local storage, APIs, pixels, tags, or similar technologies. Where storing or accessing information on a user's device requires consent under applicable law, such processing will occur only where the required consent has been obtained. Our disclosures regarding device storage mechanisms and, where applicable, mobile SDK package identifiers are maintained in accordance with applicable IAB Europe TCF requirements. 4. How We Use Personal Data Depending on our relationship with the user and the applicable privacy choices, VOLASIM may process personal data for purposes including: Providing and Operating Our Applications and Services We may process information to: provide our website, apps, DSP, and related services; operate application functionality; deliver requested services; maintain accounts; provide customer support; and diagnose technical issues. Advertising Delivery Where permitted by applicable law and user choices, information may be processed to: receive and evaluate advertising opportunities; participate in programmatic auctions; deliver advertisements; select advertisements using limited or contextual data; control advertising frequency; prevent repetitive delivery; manage advertising campaigns; and facilitate media buying through our DSP. Personalised Advertising Where the required consent has been obtained, data may be used to: create or use advertising profiles; understand interests or likely preferences; and select personalised advertising. VOLASIM does not rely on legitimate interest under the IAB Europe TCF for purposes for which the TCF requires consent. Advertising Measurement We may process data, where legally permitted, to: determine whether an advertisement was delivered; measure impressions, clicks, and conversions; assess campaign performance; perform attribution; generate aggregated reports; and understand advertising effectiveness. Security and Fraud Prevention We may process data to: detect and prevent advertising fraud; identify invalid traffic (“IVT”); identify bots or automated traffic; prevent malicious activity; protect users, publishers, advertisers, and advertising budgets; secure our systems and infrastructure; and diagnose and resolve technical errors. Privacy Choices We may process privacy-related information to: receive, store, recognize, and communicate consent and objection choices; interpret TCF signals; respect users' privacy choices; demonstrate compliance; and avoid processing where a valid legal basis is unavailable. Analytics and Product Improvement Where permitted, we may analyze usage and technical information to understand how our services perform, troubleshoot issues, and improve our products and services. 5. IAB Europe Transparency & Consent Framework VOLASIM operates within the programmatic advertising ecosystem and may participate as an IAB Europe TCF Vendor. The TCF enables publishers, CMPs, and advertising technology vendors to communicate information regarding users' transparency and consent choices. When VOLASIM receives a TCF signal, including a TC String, we use that signal to determine whether the relevant processing may take place. Where required under the TCF, VOLASIM: recognizes and respects valid consent and objection signals; processes TCF signals, including information identifying Vendors disclosed to the user; processes data only for purposes and legal bases declared in our applicable Global Vendor List registration; does not store or access information on a user's device where consent is required unless that consent has been obtained; maintains information concerning applicable data processing purposes, legal bases, data categories, retention periods, device storage mechanisms, and other required Vendor disclosures; maintains applicable Device Storage and Operational Disclosures; and does not knowingly transfer personal data to another TCF Vendor for TCF purposes unless the receiving Vendor has an appropriate legal basis for that processing. Our TCF declarations and registration information should be read together with this Privacy Policy. Where there is a difference between a general description in this Privacy Policy and a specific declaration made through the IAB Europe TCF for a TCF processing activity, the applicable TCF declaration describes the processing performed within the Framework. 6. Legal Bases for Processing Where the GDPR applies, VOLASIM processes personal data only where an appropriate legal basis exists. Depending on the processing activity, the applicable legal basis may include: Consent – Article 6(1)(a) GDPR We rely on consent where required, including for certain advertising and device-access activities. Within the IAB Europe TCF, consent is required for certain purposes, including the creation and use of profiles for personalised advertising and personalised content where applicable. Users may withdraw consent at any time through the applicable CMP, privacy settings, application settings, or other mechanism provided to them. Withdrawal of consent does not affect the lawfulness of processing performed before consent was withdrawn. Contract – Article 6(1)(b) GDPR We may process information where necessary to provide a service requested by an individual or perform a contract with that individual. Legal Obligation – Article 6(1)(c) GDPR We may process information where necessary to comply with applicable legal or regulatory requirements. Legitimate Interests – Article 6(1)(f) GDPR Where permitted, we may process limited personal data when necessary for our legitimate interests or those of a third party, provided those interests are not overridden by the rights and freedoms of the individual. Such interests may include, where applicable: network and information security; fraud prevention; invalid traffic detection; protecting advertising transactions; technical troubleshooting; maintaining service integrity; preventing abuse; and establishing, exercising, or defending legal claims. Where VOLASIM relies on legitimate interest under the TCF, it does so only for purposes for which legitimate interest is permitted by the Framework and after assessing the necessity and proportionality of the processing. Legitimate interest does not replace consent where consent is required to store or access information on a user's device under applicable ePrivacy rules. 7. Consent and Privacy Choices in Our Applications VOLASIM applications may display advertising or use third-party technologies. Where required, users in the EEA, UK, or other applicable jurisdictions will be presented with a consent or privacy interface before technologies requiring consent are activated. Depending on the application and applicable law, users may be able to: accept or reject certain processing purposes; select individual purposes; select or object to specific vendors; withdraw previously provided consent; and revisit their privacy choices. Where we use an IAB Europe TCF-registered CMP, these preferences may be encoded in a TC String and communicated to participating advertising technology partners. Users may change their choices using the privacy or consent controls made available within the relevant application or digital property. 8. Data Sharing and Disclosure We do not sell personal data in the traditional sense of selling identifiable customer information for money. In connection with our applications and advertising business, however, information may be transmitted among participants in the digital advertising ecosystem where an appropriate legal basis exists. Recipients may include: advertisers; publishers; app developers; DSPs; SSPs; advertising exchanges; ad servers; CMPs; attribution and measurement providers; analytics providers; fraud-prevention and security providers; cloud and infrastructure providers; hosting providers; professional advisers; service providers processing information on our behalf; and competent public authorities where disclosure is legally required. When acting as a DSP, VOLASIM may receive data from supply-side and publisher partners and may transmit relevant information to advertisers, measurement partners, or other authorized technology providers as necessary to deliver and measure advertising. Where the IAB Europe TCF applies, transfers for TCF purposes are subject to the relevant Framework requirements and user signals. 9. Automated Processing and Programmatic Advertising Programmatic advertising is largely automated. Our DSP may automatically evaluate advertising opportunities using information contained in bid requests and campaign parameters. Automated systems may determine, for example: whether a particular advertising opportunity meets campaign criteria; whether to submit a bid; the value of a bid; which eligible advertisement to deliver; whether traffic appears fraudulent or invalid; and how campaign budgets should be allocated or optimized. Where personalised advertising is used, such processing will be subject to applicable consent requirements and user preferences. VOLASIM does not use automated decision-making that produces legal effects or similarly significant effects on individuals unless permitted by applicable law and appropriate safeguards are implemented. 10. Data Retention We retain personal data only for as long as reasonably necessary for the relevant purpose, taking into account: the purpose for which the information was collected; applicable contractual requirements; fraud-prevention and security needs; dispute resolution; legal and regulatory obligations; and applicable limitation periods. Different categories of information may have different retention periods. For processing covered by the IAB Europe TCF, applicable Vendor retention disclosures are maintained as part of our TCF registration and associated disclosures. We may retain aggregated or anonymized information that no longer identifies an individual for longer periods. 11. Data Security We maintain appropriate technical and organizational measures designed to protect personal data against accidental or unlawful: destruction; loss; alteration; unauthorized disclosure; or unauthorized access. These measures may include access controls, security monitoring, encryption where appropriate, infrastructure safeguards, and internal data-protection procedures. No system or transmission over the Internet can be guaranteed to be completely secure. 12. International Data Transfers VOLASIM and our technology and service partners may process personal data in countries outside Cyprus, the European Economic Area (“EEA”), or the jurisdiction in which the user resides. Where personal data subject to GDPR is transferred outside the EEA, we use an appropriate transfer mechanism where required, which may include: an adequacy decision adopted by the European Commission; Standard Contractual Clauses approved by the European Commission; another legally recognized transfer mechanism; or another applicable derogation or safeguard permitted by law. Where relevant to our TCF participation, information concerning international data transfers is also reflected in our IAB Europe Vendor registration. 13. Your Privacy Rights Depending on your location and applicable law, you may have rights including: the right to access personal data concerning you; the right to correct inaccurate or incomplete personal data; the right to request deletion of personal data; the right to restrict certain processing; the right to data portability; the right to object to processing based on legitimate interests; the right to withdraw consent at any time where processing relies on consent; and the right to lodge a complaint with a competent supervisory authority. Where you object to processing based on Article 6(1)(f) GDPR, we will cease the relevant processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defence of legal claims. For advertising preferences communicated through a CMP, you may also modify or withdraw choices through the relevant consent interface. To exercise your rights, contact: Contact@volasim.com We may request information reasonably necessary to verify your identity and process your request. 14. Children Our advertising technology services are not intended to knowingly collect personal data from children in circumstances where such processing is prohibited. Individual VOLASIM applications may be intended for different audiences. Where an application is directed to children or is reasonably likely to be accessed by children, we apply appropriate safeguards and comply with applicable requirements concerning children's privacy, advertising, tracking, and consent. Where required by applicable law, we do not use personal data for personalised advertising to children. Any application-specific privacy information concerning children will be provided in the relevant application's disclosures where appropriate. 15. Third-Party Services and Links Our websites and applications may contain links to, integrate with, or interact with third-party services. Third parties process information according to their own privacy policies and legal obligations. We encourage users to review the privacy policies and privacy controls provided by those third parties. 16. Device Storage and Operational Disclosures As an advertising technology provider participating in the IAB Europe TCF, VOLASIM maintains applicable disclosures regarding technologies used to store or access information on devices. These disclosures may include, where applicable: cookies; local storage or similar technologies; device identifiers; SDKs; SDK package identifiers; storage duration; purposes associated with particular storage mechanisms; and other information required by the applicable TCF technical specifications. The machine-readable Device Storage and Operational Disclosure associated with our TCF Vendor registration should be read together with this Privacy Policy. 17. Legitimate Interest Disclosure Where VOLASIM relies on legitimate interest for processing covered by the IAB Europe TCF, additional information about the interests pursued, necessity of the processing, balancing of those interests against user rights, and users' right to object is available through our Legitimate Interest Disclosure. Users have the right to object to processing based on legitimate interests at any time, subject to applicable law. 18. Changes to this Privacy Policy We may update this Privacy Policy to reflect: changes to our services; new applications or advertising technologies; changes in applicable law; changes to the IAB Europe Transparency & Consent Framework; or changes to our data-processing practices. Where required, we will provide appropriate notice of material changes. The date at the top of this Privacy Policy indicates when it was last updated. 19. Contact Us If you have questions about this Privacy Policy, our privacy practices, or wish to exercise a privacy right, please contact: Volasim Ltd Email: Contact@volasim.com Website: https://www.volasim.com bottom of page