Nefta Compliance Overview


Nefta has built an Ad Network that focuses on data privacy.
Our architecture is designed from the ground up to satisfy the letter and spirit of data privacy policy and legislation.

There are a number of key provisions and subjects in each core policy.
We will cover the overview of those below.

The User

The overwhelming sentiment of modern data privacy regulation is that The User should not only have visibility of how their data is collected and processed (GDPR), but they should now have the ability to opt-in or opt-out in the first instance (ATT & TCF 2.2). Additionally, major providers are moving away from tracking users and serving personalised advertising (Apple/ATT and Google's Privacy Sandbox with TCF 2.2 requirements).

Nefta believes that the continued development of clear mechanics that empower The User to have more clarity and control over what data is collected from/on them, and how that data is processed, is an incredibly positive step in the evolution of the digital world in which we all participate within.

New opt-in mechanisms and compliance frameworks such as ATT (Apple's App Tracking Transparency), TCF 2..2 (Transparency & Consent Framework) have disrupted the advertising industry, however, Nefta believe that this is a necessary step towards users having control and respect that they deserve to operate digitally.

Tracking, linking, and fingerprinting a user

Nefta does not track users, link data to users, or fingerprint users.

Firstly; Tracking refers to combining first-party data generated by a company with third-party data not owned by that company in order to paint a fuller picture as to who a user is or what they are interested in, in order to personalise advertising and enhance results. (The practice of providing your first-party data to a data broker also constitute tracking).

Nefta does not track users.
Furthermore, we do not link data to users, we don't fingerprint users, and we don't even collect any PII (personally identifiable information).

We only receive data collected by our publisher partners on a per-partner basis.
In other words; If "Publisher X" collects usage data in the form of our taxonomy of Game Events, and sends those events to Nefta for processing to discover patterns of usage behaviour and to serve third-party adverts based on this first-party usage data, then Nefta will only ever use Publisher X's data.

Data collection

The publisher adds Nefta's taxonomy of Game Events via our Ad SDK and/or Adapter.
These Game Events are a form of usage data to understand patterns of behaviour on how different groups of people interact with an app.

The data is collected (it is transferred off the device for non-immediate use).
We recommend that all Publishers submit our SDK and the following types of data collected & data uses to respective parties:

Types of data collected:

Usage data:

  • Product Interaction,
  • Advertising Data.

Data use:

  • Third-Party Advertising
  • Analytics

Data processing

Nefta processes the first-party data collected and supplied by our publisher partners.
We do this in two ways:

  1. Third-Party Advertising
    Our Publisher Partners use Nefta to display adverts to their users. Nefta is the third party in this arrangement, and we show our inventory of adverts on the publisher's app.
    We collect usage data including product interaction (which is recorded through our taxonomy of Game Events) to determine which adverts to show to different patterns of behaviour.
  2. Analytics:
    We return the processed first-party usage data to the publisher for their own analysis and understanding. We also enable this data to be viewed and queried through the Nefta platform which includes an analytics view/dashboard.
    Our publisher partners use this data to improve their app.

Usage data vs User data

User data encompasses data that relates to the user; including PII (personally identifiable information), data owned by the user, or data created by the user.

Usage data relates to any data about how a product or service is used. For example, clicks, opens, closes, actions, how long certain actions took, and other such data from an application.

Nefta does not collect or process any data relating to a user.
We do not collect or process any user data or PII.
We do not collect or process any data owned by, or created by, The User.

We do collect and process Usage data; specifically a taxonomy of Game Event Tags that are integrated into an app to understand how the app is interacted with. It is this data that enables Nefta to understand different patterns of usage, and which patterns of usage interact better/worse with various advertising creatives.

Identifiers (IDs)

Unique or Global Identifiers have been the backbone of the digital advertising industry for a long time.

User IDs are unique to a user. If a user logged out of a game and then logged back in on another device, the userID would follow the login.

Device IDs are specific to a device. If a user logged out of a game and another user logged in, all on the same device, the deviceID would remain the same.

SDK IDs behave differently from User or Device IDs, in that they're unique to the installation of an app.
If a user was logged in on two different devices, their activity would be recorded as two unique SDK IDs.
If a user uninstalled an app from their device, and then later reinstalled it; a new SDK ID would be assigned.

Nefta use an SDK ID to collect usage data on how an app is interacted with and to discover patterns of usage, as well as to return a bid response with a creative with the highest likelihood of being clicked, based on the pattern of usage that has been observed from that SDK.

The other advantage to an SDK ID is that it is impossible to use to track users, and because Nefta does not collect any PII, we are unable to link any data to a user. The SDK ID is the only way to ensure 100% anonymity of a user whilst being able to still provide a form of behavioural advertising.

PII (personally identifiable information)

Nefta does not collect or receive any PII.
We go as far as to not even store IP addresses.

We process first-party Product Interaction and Advertising usage data collected by the publisher for the purposes of displaying third-party adverts and providing analytics on app usage.

Nefta at no point knows anything about a user.