Effective Date: July 23, 2025
Last Updated: July 23, 2025

1. Who We Are
This website is operated by OnCore Digital Media (“we”, “our”, or “us”). We operate as a
pass-through technology provider in the digital advertising ecosystem, focusing on the
technical delivery and measurement of ads without directly collecting or storing personal
user data.

2. What Data We Process
We do not directly collect or store personal data from users. As a pass-through provider, we
may temporarily process technical data passed via programmatic ad systems for the
purpose of delivering, tracking, or measuring ad requests. This may include:
– IP address (in transit, not stored)
– User agent string
– Timestamp and ad request metadata
– Referring domain or page URL
– Ad placement ID or supply chain identifiers
All data is processed transiently and only for operational delivery of ads.

3. Legal Basis for Processing
We rely on legitimate interest (Article 6(1)(f) of the GDPR) for minimal and necessary
processing related to the technical operation of our advertising systems. We do not rely on
consent or manage a Consent Management Platform (CMP), as we do not engage in user-
level targeting or profiling.

4. Your Rights
Although we do not collect personal data, we support the principles of transparency and
accountability. If you wish to exercise your data rights, we recommend contacting the
website, app, or vendor responsible for displaying the ad you saw. We will assist any data
subject request that is forwarded to us by those parties.
5. Vendors and Third Parties
We do not share personal data with third parties. Any temporary data processed is passed
securely and transiently between supply and demand platforms. We only work with IAB-
registered or GDPR-compliant vendors.

6. Data Retention

We do not retain personal data. Any technical log data is anonymized or deleted shortly
after processing and used only for troubleshooting, fraud prevention, or operational
diagnostics.
7. Cookies and Tracking Technologies
We do not place or access cookies, localStorage, or any client-side tracking technologies.
Our systems operate entirely server-side as a passthrough layer in the programmatic
advertising chain.

8. Contact Us
If you have any questions or privacy-related concerns, please contact us at:
Data Protection Officer
OnCore Digital Media
[email protected]