Effective Date: 1/12/2025

Last Updated: 1/12/2025

Device Storage Disclosure Policy for Programmatic Mechanics and Pontiac Intelligence

1. Purpose of This Policy
This policy outlines how Pontiac Intelligence accesses or stores information on a user’s device in compliance with the General Data Protection Regulation (GDPR) and applicable ePrivacy regulations.

2. Device Access and Storage Practices
We do not use traditional tracking cookies or store persistent identifiers such as cookie IDs on user devices.
However, in some cases, our systems may access minimal, non-identifiable data on user devices strictly for the following permitted purposes:

• Ensuring system security and integrity
• Frequency capping of advertisements
• Conversion attribution based on session activity
• Detecting ad fraud or invalid traffic

3. Lawful Basis
We rely on the legitimate interest legal basis (Art. 6(1)(f) GDPR) for minimal storage/access when it is necessary:

• To deliver core advertising services
• To monitor and secure our systems
• To improve measurement accuracy

We ensure that such access is limited in scope, does not involve profiling, and does not identify individual users.

4. No Cookies or Persistent Identifiers
We do not store cookie IDs, advertising IDs, or other unique identifiers on user devices.
 We do not use local storage, web beacons, or fingerprinting techniques for user identification across sessions.

5. Your Rights
Under GDPR, you have the right to:

• Request access to any data collected or stored about you
• Object to processing based on legitimate interest
• Request data erasure or restriction of processing

To exercise these rights, contact us at: privacy@pontiac.media

6. Data Transfers and Storage
We take appropriate technical and organizational measures to ensure that any data accessed or stored complies with EU data protection standards. Where applicable, data is pseudonymized or encrypted, and processed within secure environments.