ADVERTISING POLICY

ADTRAIL – FZCO

Registration ID: DSO-FZCO-37799 Address: Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates

Brand: RockApp

Effective Date: 24.11.2025

This Advertising Policy applies to the mobile marketing services provided by ADTRAIL – FZCO (operating under the brand “RockApp,” “we,” “us,” and “our”) to our advertiser clients (“Advertising Services”).

About RockApp and Our Services

RockApp is a B2B mobile marketing agency specializing in user acquisition and retargeting across Web, In-app, and Native advertising channels. We work with advertiser clients to manage and optimize their digital advertising campaigns.

How We Operate

Our Services involve managing advertising campaigns on behalf of our clients. This process typically includes:

1. Campaign Strategy: Developing a strategy for user acquisition and retargeting.
2. Media Buying: Executing media buys across various ad exchanges, supply-side platforms (SSPs), and direct publishers.
3. Data Analysis: Analyzing campaign performance data (e.g., impressions, clicks, conversions) to optimize results.
4. Reporting: Providing detailed reports to our clients.

Data We Process

In our capacity as a mobile marketing agency, we primarily process data related to our clients' campaigns. This data is generally non-personally identifiable information (Non-PII) at the end-user level, but may include identifiers that are considered personal data under certain regulations (e.g., GDPR, CCPA).

The types of data we process on behalf of our clients include:

• Campaign Performance Data: Impressions, clicks, conversions, cost data.
• Device Identifiers: Advertising IDs (IDFA/GAID) and other device-level identifiers.
• Technical Data: Device make, model, operating system, IP address, network connection type, and browser user-agent.
• Location Data: City- and/or country-level geolocation data.

Our Role in Data Processing

Data Controller and Processor Roles (GDPR/International)

For the majority of the end-user data processed in connection with our Advertising Services, RockApp acts as a Data Processor on behalf of our Advertiser Clients, who are the Data Controllers. Our processing is strictly governed by the terms of our Master Service Agreement (MSA) and a separate Data Processing Agreement (DPA) with each client.

Our clients are responsible for ensuring they have the necessary legal basis (e.g., consent or legitimate interest) to collect and share end-user data with us for advertising purposes.

In limited circumstances, such as for internal fraud detection, reporting, and service improvement, RockApp may act as an independent Data Controller for certain aggregated or anonymized data elements, relying on its legitimate interests as the legal basis for processing.

Data Sharing and Disclosure

We may share data with the following categories of third parties:

• Advertiser Clients: We share campaign performance data and relevant identifiers with our clients and their mobile measurement partners (MMPs) to enable campaign tracking and attribution.
• Media Partners: We share necessary data (e.g., bid requests) with ad exchanges, SSPs, and publishers to execute media buys.
• Service Providers: We share data with vendors who provide services essential to our operations (e.g., cloud hosting, analytics).
• Legal Compliance: We may disclose data if required by law or to protect the rights and property of RockApp.

International Data Transfers

All data processed by us may be transferred, processed, and stored outside the United Arab Emirates. By engaging our Services, our clients consent to this transfer.

Data Transfer Mechanisms (GDPR)

When processing personal data of EEA residents, we ensure appropriate safeguards are in place for international transfers, such as relying on the European Commission's Standard Contractual Clauses (SCCs) or other recognized legal mechanisms.

End-User Choices

End-users of mobile applications have choices regarding personalized advertisements. They may limit ad tracking in mobile application environments by following the instructions for Android (https://support.google.com/android/answer/13720755?hl=en) and iOS (https://support.apple.com/en-us/105131).

Contact Information

If you have any questions about this Advertising Policy, please contact us at:

ADTRAIL – FZCO Registration ID: DSO-FZCO-37799 Address: Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates Email: legal@therockapp.com