Legal

Privacy Policy

English 日本語
EFFECTIVE DATE: OCTOBER 21, 2026

This Privacy Policy explains how DAIROS PTE. LTD. ("DAIROS", "we", "us" or "our") collects, processes, uses, and discloses personal information in connection with our websites (the "Sites") and the related content, products, services, and other functionality offered on or through our online services, including where you interact with DAIROS through mobile applications and/or websites that have integrated with DAIROS's advertising platform either directly or via an advertising exchange (collectively, the "Services"). It does not address our privacy practices relating to DAIROS job applicants, employees and other personnel.

1. About DAIROS

DAIROS PTE. LTD. is a company incorporated in Singapore (UEN: 202630174M), with its registered office at 152 Beach Road, #23-02, Gateway East, Singapore 189721. DAIROS operates an advertising platform (demand-side platform) that enables advertisers to serve advertisements on third-party mobile applications and/or websites owned or operated by partners or to which a partner has the right to serve advertising.

For the purposes of this Privacy Policy:

  • "Customers" means business entities (and their business representatives) that use our Services, including advertisers, publishers and other advertising business partners.
  • "Authorized Users" means individuals who have been granted access to a Customer's account on our Services by such Customer.
  • "Users" means individuals who visit, access or otherwise interact with websites, mobile applications or other digital properties operated by our Customers or partners where our advertising technology is integrated.
  • "Website Visitors" means individuals who visit the websites operated directly by DAIROS, including dairos.net.
  • "Personal Data" or "personal information" means any information that, alone or in combination with other information, identifies or is reasonably capable of being linked, directly or indirectly, to an identified or identifiable individual, as further defined under applicable law.

Where our Customers use the Services to process data under their own control, we process such information on behalf of and under the instruction of the respective Customer, who is the data controller. This Privacy Policy does not apply to such processing; we recommend that you read the privacy notice of the respective Customer if their processing concerns your personal information.

2. Information We Collect

2.1 Personal Data We Collect About Users

Our Services enable Customers to tailor and measure the performance of advertisements displayed on Customers' and partners' websites and apps. In that connection we may automatically collect:

  • Identifiers, such as cookie IDs, mobile advertising IDs, session IDs and other digital or proprietary identifiers assigned to your device, used for serving advertisements and measuring attribution;
  • Approximate location data, derived from your device's IP address;
  • Activity information on Customer websites and apps where our technology is integrated, such as pages visited, referral sources and exit destinations, time spent, products or content viewed, and interactions with content;
  • Device data, including device type and model, operating system and version, browser type and version, screen dimensions, language settings, mobile network information and IP address;
  • Advertising measurement data, including information about the advertisements served, viewed or clicked, frequency of exposure, and subsequent visits or actions used to measure campaign effectiveness.

For more information about these practices and your choices, please see the Cookie Notice below.

2.2 Information We Collect From Customers and Authorized Users

  • Contact details, such as name, business email address, company name, job title and communication preferences;
  • Account information, such as login credentials, profile and dashboard information, campaign details (ad content, platform specifications, budgets), billing addresses, payment history and transaction information;
  • Usage data collected automatically when Authorized Users access the Services, such as IP address, browser and operating system information, timestamps, pages visited and actions taken.

2.3 Information From Third Parties

We may receive personal information from third parties, including our Customers, advertising partners, service providers (such as payment processors), publicly available sources and third-party data providers, and we may combine it with information we collect directly.

3. How We Use Your Information

We use the information we collect for the following purposes:

  • To provide the Services — making our advertising platform available to Customers; serving relevant and, where permitted, personalized advertisements; measuring, optimizing and reporting on campaigns; auditing; providing analytics to Customers; coordinating account access; responding to requests and providing support; and processing payments.
  • To personalize experiences — tailoring the content displayed on our Sites and the advertisements delivered through the Services.
  • To improve and develop our products and services — analyzing statistics and trends, understanding how the Services are used, resolving issues, and developing new features and services.
  • For marketing — communicating with Customers and prospective Customers about features, updates, products and offers, in accordance with applicable law.
  • To protect our business and comply with the law — detecting and preventing fraud, invalid traffic and security incidents; enforcing our terms and agreements; establishing, exercising or defending legal claims; and complying with applicable laws, regulations, court orders and lawful requests by public authorities. We may also use information in connection with a corporate transaction such as a merger, acquisition, financing, reorganization or sale of assets.
  • For other purposes with your consent, at your direction, or where notice is otherwise provided.

4. How We Disclose Your Information

We may disclose personal information to:

  • DAIROS group companies, for intragroup services and administration;
  • Service providers performing work on our behalf, such as cloud hosting, analytics, payment processing and professional advisers, under contracts requiring appropriate protection of personal information;
  • Customers and advertising partners, including advertisers, publishers, advertising exchanges and other platforms, in connection with serving, measuring and reporting on advertising;
  • Parties to a corporate transaction, such as a merger, acquisition, reorganization, financing, sale of assets, insolvency or receivership;
  • Law enforcement, regulators, courts and other third parties where required or permitted by law, to enforce our terms, to protect the rights, property or safety of DAIROS, our Customers, Users or others, or to detect and prevent fraud or crime;
  • Other parties with your consent or at your direction.

We may also share aggregated or anonymized information that does not reasonably identify any individual.

5. Data Retention

We retain personal information only for as long as necessary for the purposes for which it was collected, including to satisfy legal, accounting, tax or reporting requirements and our legitimate business interests. In determining retention periods we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes of processing and applicable legal requirements. When retention is no longer necessary, we delete, de-identify or securely isolate the information.

6. Third-Party Links

The Services operate on third-party websites and may contain links to third-party websites, including those of our Customers and partners. These websites have their own privacy policies, and we do not accept any responsibility or liability for them. Please review the applicable policies before you submit any information to those websites.

7. Children's Personal Information

Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 13. If you believe that a child under 13 has provided personal information to us, please contact us using the details below, and we will promptly delete such information.

8. Regional Privacy Disclosures

We may provide different or additional disclosures relating to the processing of personal information about residents of certain jurisdictions:

9. Contact Us

If you have questions about this Privacy Policy or our handling of personal information, please contact us at: [email protected] (Attention: Data Protection Officer).

10. Updates to This Privacy Policy

We reserve the right to modify this Privacy Policy from time to time. If we make changes, we will update the "Effective Date" above and post the updated version on this page. If the changes are material, we will provide more prominent notice.

11. Language

This Privacy Policy is prepared in English. Any translation into Japanese or any other language is provided for reference purposes only. In the event of any inconsistency between the English version and a translated version, the English version shall prevail.

Additional Singapore Privacy Disclosures (PDPA)

These disclosures supplement the Privacy Policy and apply to individuals located in Singapore, in accordance with the Personal Data Protection Act 2012 of Singapore ("PDPA").

1. Data Protection Officer

We have appointed a Data Protection Officer ("DPO"). You may contact our DPO at: [email protected] (Attention: Data Protection Officer). Please provide sufficient detail for us to identify you and respond to your request.

2. Purposes of Collection, Use and Disclosure

We collect, use and disclose personal data only for purposes that a reasonable person would consider appropriate in the circumstances and for which we have provided notification, as described in Sections 2–4 of the Privacy Policy, including providing and operating our advertising platform; serving, measuring and reporting on advertising; analytics and fraud detection; communications; billing; service improvement; marketing where permitted; protection of our rights; and legal compliance.

3. Consent and Withdrawal

We collect, use and disclose personal data on the basis of consent (including deemed consent under the PDPA), or in reliance on the legitimate interests, business improvement or other exceptions under the First and Second Schedules to the PDPA. You may withdraw consent at any time by contacting our DPO. We will inform you of the likely consequences and will cease the relevant collection, use or disclosure within a reasonable period, unless continued processing is required or permitted by law. Withdrawal does not affect the lawfulness of processing before withdrawal.

4. Accuracy, Protection and Retention

We make reasonable efforts to ensure personal data is accurate and complete where it is likely to be used to make a decision affecting you or disclosed to another organisation. We have implemented reasonable technical, organisational and contractual security arrangements to protect personal data against unauthorized access, collection, use, disclosure, copying, modification or disposal. We cease to retain personal data, or anonymize it, when retention is no longer necessary for legal or business purposes.

5. Cross-Border Transfers

We may transfer personal data outside Singapore, including to jurisdictions where our affiliates, service providers and advertising partners are located. Where we do so, we take appropriate steps (including legally enforceable contractual obligations) to ensure the transferred personal data is afforded a standard of protection comparable to that under the PDPA.

6. Your Rights Under the PDPA

Subject to the conditions and exceptions in the PDPA, you may request: (a) access to your personal data and information about how it has been used or disclosed within the past year; (b) correction of errors or omissions; (c) withdrawal of consent; and (d) to the extent in force, data portability. To exercise these rights, submit a written request to our DPO. We may need to verify your identity, may charge a reasonable fee for access requests, and will respond within the timeframes prescribed by the PDPA.

7. Do Not Call; Data Breach; Complaints

We comply with the Do Not Call provisions of the PDPA for specified marketing messages to Singapore telephone numbers. We maintain data breach response procedures and will notify the Personal Data Protection Commission ("PDPC") and affected individuals of notifiable data breaches as required by the PDPA. If you are not satisfied with our response to a concern, you may lodge a complaint with the PDPC (www.pdpc.gov.sg).

Additional Japan Privacy Disclosures (APPI)

These disclosures supplement the Privacy Policy and apply to the handling of personal information of individuals in Japan in accordance with the Act on the Protection of Personal Information of Japan ("APPI").

1. Business Operator Handling Personal Information

DAIROS PTE. LTD., 152 Beach Road, #23-02, Gateway East, Singapore 189721. Representative contact for personal information matters: [email protected] (Attention: Data Protection Officer).

2. Purposes of Use

We use personal information for the purposes stated in Section 3 of the Privacy Policy, including delivery, measurement and optimization of advertising; provision and improvement of the Services; communications with Customers; billing; security and fraud prevention; and legal compliance.

3. Provision to Third Parties

Except as permitted under the APPI, we do not provide personal data to third parties without the prior consent of the individual. Information shared with service providers acting on our behalf is handled as entrustment under Article 27(5)(i) of the APPI, subject to our supervision.

4. Provision to Third Parties Located in Foreign Countries

DAIROS is located in Singapore, and personal information may be processed in Singapore and other foreign countries where our service providers and partners are located (including the United States). Where we provide personal data to third parties in foreign countries, we do so in accordance with Article 28 of the APPI, including, where required, obtaining the individual's consent after providing information on the country, its personal information protection system and the measures taken by the recipient, or ensuring the recipient has established a system of standards equivalent to those under the APPI.

5. Retained Personal Data; Requests for Disclosure, etc.

With respect to retained personal data, individuals may request, in accordance with the APPI: notification of purposes of use; disclosure; correction, addition or deletion; cessation of use; cessation of provision to third parties; and disclosure of records of third-party provision. Requests may be submitted to [email protected]. We will verify the identity of the requester and respond without undue delay in accordance with the APPI. A reasonable fee may be charged for requests for notification of purposes of use or disclosure.

6. Security Control Measures

We implement necessary and appropriate security control measures for personal data, including establishment of internal policies, organizational measures (designation of responsible personnel, handling rules), human measures (employee training and confidentiality), physical measures (access management) and technical measures (access controls, encryption of data in transit). We also understand the external environment, including the personal information protection systems of Singapore and other countries where personal data is handled.

7. Complaints

For complaints regarding our handling of personal information, please contact [email protected]. We will respond in good faith and without undue delay.

Additional EEA, United Kingdom and Switzerland Privacy Disclosures

These disclosures supplement the Privacy Policy and apply to individuals located in the European Economic Area ("EEA"), the United Kingdom and Switzerland, and should be read together with the GDPR, the UK GDPR and the Swiss Federal Act on Data Protection, as applicable.

1. Controllership

  • Website Visitors: DAIROS is the controller of personal data collected via our own Sites.
  • Customers and Authorized Users: we generally act as controller of business contact and account data.
  • Users: with respect to personal data collected through our technology integrated on Customers' and partners' digital properties for ad serving and measurement, DAIROS and the relevant Customer may act as separate or joint controllers, depending on the integration. Customers are responsible for providing notice and, where required, obtaining consent at the point of collection.

2. Legal Bases

We process personal data on the following legal bases: consent (e.g., non-essential cookies and personalized advertising, direct marketing where required); performance of a contract (providing the Services to Customers); legitimate interests (operating, securing and improving the Services, fraud prevention, business administration), balanced against your interests and rights; and legal obligation (compliance with applicable laws).

3. International Transfers

Personal data may be transferred to and processed in countries outside the EEA, the UK and Switzerland, including Singapore and the United States. Where required, such transfers are made: on the basis of an adequacy decision; or subject to appropriate safeguards, such as the European Commission's Standard Contractual Clauses (2021), the UK International Data Transfer Agreement or Addendum, and Swiss-compatible supplements, together with transfer impact assessments and supplementary measures where appropriate. You may request further information about these safeguards by contacting [email protected].

4. Your Rights

Subject to applicable law, you have the rights of access, rectification, erasure, restriction of processing, data portability, objection (including to direct marketing, for any reason), the right to withdraw consent at any time (without affecting prior processing), and the right not to be subject to solely automated decisions producing legal or similarly significant effects. To exercise these rights, contact [email protected]. We may request proof of identity. You also have the right to lodge a complaint with your local supervisory authority (for the UK, the Information Commissioner's Office; for the EU, see edpb.europa.eu).

5. Retention and Security

We store personal data no longer than necessary for the purposes described, and we implement appropriate technical and organisational measures, as described in Sections 4–5 of the Privacy Policy and Section 4 of the Singapore Disclosures.

Additional U.S. State Privacy Disclosures

These disclosures supplement the Privacy Policy for residents of U.S. states with comprehensive privacy laws (including California, Colorado, Connecticut, Utah and Virginia).

1. Categories Collected

In the preceding 12 months we may have collected: identifiers (cookie IDs, mobile advertising IDs, IP addresses; for Customers, names and business email addresses); commercial information (campaign and transaction information); internet or other network activity (device information, logs, analytics, ad interaction data); geolocation data (approximate location from IP address); professional information (job titles, companies); and inferences (interest and preference predictions). Sources and purposes are described in Sections 2–3 of the Privacy Policy.

2. Disclosure, "Sale" and "Sharing"

We disclose the above categories to service providers, affiliates, Customers and advertising partners for the business purposes described in Section 4 of the Privacy Policy. Certain disclosures of identifiers, internet activity and geolocation data to advertising partners for personalized advertising may constitute a "sale" or "sharing" under applicable state laws. We do not knowingly sell or share the personal information of consumers under 16 years of age. We do not use or disclose sensitive personal information for purposes requiring a right to limit under applicable law.

3. Your Rights

Subject to applicable law and verification of your identity, you may have the right to: know/access the personal information we have collected; delete personal information; correct inaccurate personal information; opt out of "sales", "sharing" and targeted advertising; and appeal a refusal, with the further right to contact your state Attorney General if an appeal is denied. We will not discriminate against you for exercising your rights. To exercise rights or submit an appeal, contact [email protected] with the subject line "Privacy Rights Request". Authorized agents may submit requests with proof of authorization as required by law. California residents with an established business relationship may also make "Shine the Light" requests (Civ. Code §1798.83) via the same address. For cookie-based opt-outs of personalized advertising, email [email protected] with the subject line "Do Not Sell or Share".

4. Global Privacy Control

Where required by applicable state law, we honor opt-out preference signals, such as the Global Privacy Control ("GPC"), transmitted by your browser or extension, as a valid request to opt out of the "sale" or "sharing" of personal information linked to that browser. You may also submit an opt-out request to [email protected] with the subject line "Do Not Sell or Share".

Additional Canada Privacy Disclosures

These disclosures supplement the Privacy Policy and apply to individuals located in Canada, in accordance with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy laws, including the Quebec Act respecting the protection of personal information in the private sector, as amended by the Act to modernize legislative provisions as regards the protection of personal information ("Quebec Law 25").

1. Accountability and Privacy Officer

We are responsible for personal information under our control and have designated a person in charge of the protection of personal information (Privacy Officer). You may contact our Privacy Officer at: [email protected] (Attention: Privacy Officer / Data Protection Officer).

2. Consent

We collect, use and disclose personal information with consent, except where otherwise permitted or required by law. Consent may be express or implied, depending on the sensitivity of the information and the reasonable expectations of the individual. Where our advertising technology collects information through cookies or similar technologies for personalized advertising, you may withdraw consent at any time as described in the Cookie Notice. Withdrawal of consent is subject to legal or contractual restrictions and reasonable notice, and may affect our ability to provide certain services.

3. Cross-Border Processing

Personal information may be transferred to, stored and processed in Singapore, the United States and other jurisdictions outside Canada by us and our service providers. While such information is outside Canada, it is subject to the laws of those jurisdictions, which may permit access by courts, law enforcement and national security authorities. We use contractual and other means to provide a comparable level of protection while information is processed by third parties on our behalf.

4. Your Rights

Subject to applicable law, you may request access to and correction of your personal information, withdraw consent, and request information about our handling of your personal information, including, for individuals in Quebec, the rights to deindexation and cessation of dissemination and to be informed of decisions based exclusively on automated processing, where applicable. To exercise these rights, contact our Privacy Officer at [email protected]. We will respond within the timeframes required by applicable law and may need to verify your identity.

5. Confidentiality Incidents

We maintain procedures to identify, assess and respond to confidentiality incidents involving personal information. Where an incident presents a real risk of significant harm (or, in Quebec, a risk of serious injury), we will notify the Office of the Privacy Commissioner of Canada and/or the Commission d'accès à l'information du Québec and affected individuals, as required by applicable law, and will keep a register of such incidents.

6. Complaints

If you have concerns about our handling of your personal information, please contact our Privacy Officer first. You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) or, for Quebec residents, the Commission d'accès à l'information du Québec.

Effective Date: October 21, 2026

1. Scope

This Cookie Notice supplements the Privacy Policy and explains how we use cookies, mobile advertising IDs and similar technologies (together, "cookies") in the course of providing the Services.

2. What Are Cookies and Mobile Advertising IDs

Cookies are small files downloaded to your device that allow the collection of certain information about your interactions with websites and online services. In mobile app environments, we may use common mobile advertising identifiers, such as the Google Advertising ID on Android and the Identifier for Advertisers (IDFA) on iOS.

3. Types of Cookies We Use

  • Strictly necessary cookies — essential for the operation and security of the Services (exempt from consent requirements where applicable).
  • Functionality cookies — remember your choices and preferences.
  • Analytics cookies — help us measure usage and improve the Services.
  • Advertising/targeting cookies — used to serve relevant advertisements, limit ad frequency and measure campaign effectiveness.

Where required in the EEA, the UK and Switzerland, non-essential cookies are set only with your prior consent, which you may withdraw at any time.

4. Your Choices About Cookies

Where cookies require consent, you can withdraw or change your choices at any time by contacting us at [email protected] or by using your browser settings. Most browsers allow you to receive notification before a cookie is set, to disable existing cookies, or to reject cookies automatically. Disabling cookies may affect the functionality of the Services. Choices must be made on each browser and device you use.

5. Your Choices About Mobile Advertising IDs

  • Android: Settings → Google → Ads → turn on "Opt out of Ads Personalization" (or delete the advertising ID, where available).
  • iOS/iPadOS: Settings → Privacy & Security → Tracking (disable "Allow Apps to Request to Track"), and Settings → Privacy & Security → Apple Advertising → turn off Personalized Ads.

6. Your Choices About Online Advertising

To learn more about interest-based advertising and to opt out of participating companies' interest-based ads, visit the Digital Advertising Alliance at www.aboutads.info/choices, the Network Advertising Initiative at www.networkadvertising.org/choices, and, for mobile apps, www.aboutads.info/appchoices. Opting out does not mean you will stop seeing advertisements; it means the ads you see from participating companies should not be based on your interests.

7. Cookies We Set

Cookies set directly by DAIROS on dairos.net
Cookie NameTypeWhen SetDurationPurpose
dairos_uidAdvertisingOnly after you consent to advertising cookies, when a User views or clicks an advertisement served by DAIROS365 daysHolds an anonymous user ID used to serve ads, cap frequency and measure ad interactions

8. Third-Party Cookies and Advertising Partners

When our advertising technology runs on our Customers' and partners' websites and apps, or when we buy media on their behalf, cookies and mobile advertising identifiers may also be set or read by advertising exchanges and platforms involved in delivering and measuring an ad. Depending on the campaign, these may include Google (including DV360 and Google Ads), Meta, TikTok, X, Amazon Ads and other programmatic exchanges and measurement providers. Those partners act under their own privacy policies, and their cookies are not controlled by DAIROS.

In the EEA, the UK and Switzerland we do not serve personalised advertising without a valid consent signal. Consent is obtained through the consent mechanism of the relevant publisher app or site, or directly by us, and we require partners to have a lawful basis (including, where applicable, an IAB Europe Transparency & Consent Framework signal) before personal data is used for personalised advertising. You can withdraw your choices at any time by contacting [email protected].

Our own Sites load fonts and images from dairos.net rather than third-party content delivery networks, so visiting our Sites does not by itself transmit your IP address to a third-party font or image provider.

9. Updates and Contact

We may update this Cookie Notice from time to time; material changes will be prominently notified. For questions, contact [email protected].