Continental Expeditions, Inc. d/b/a CloudX (“we,” “us,” “our,” or “CloudX”) strives to support a trustworthy and transparent digital advertising ecosystem for all publishers, demand partners, advertisers, and users. 

This Publisher Policy (“Policy”) is designed to ensure that publisher partners conform to applicable policies of advertisers, vendors, and publishers that integrate with our Platform, as well as relevant industry requirements. All Publishers that integrate their application or other web property (“Property”) with our Platform or otherwise use our Advertising Services must adhere to this Policy. This Policy applies in addition to any other policies or agreements governing your use of the Platform or Advertising Services. Terms that are not defined in this Policy have the definition set out in the agreement governing your use of the Platform and the Advertising Services.

We may update this Policy from time to time, and any revised version will apply to you when we post the updated version on our website or otherwise provide you with reasonable notice of such changes.

General Obligations

You must comply with this Policy and all applicable laws and other requirements  in connection with the operation of your Property. You will keep appropriate documentation of your compliance. Applicable laws and other requirements include any laws, rules and regulations, including data protection, consumer protection, commerce, advertising, and product laws, age-related restrictions, regulatory requirements or self-regulatory guidance, intellectual property and license restrictions, for all of the locations where your Properties are used or accessible. You must obtain any consents and make all necessary disclosures required with our Platform or use the Advertising Services. We may request that you provide documentation of your compliance. If you don’t comply with this Policy, we may suspend or terminate your access to the Platform and Advertising Services as provided in the Terms.

Ineligible Properties

You may not integrate with the Platform or use the Advertising Services if your Property meets any of the following criteria:

• Your Property contains significant unmoderated user-generated content.  This includes Properties that do not have a method to moderate user-generated content, a method to report or appropriately manage any misconduct, and/or the ability to remove or block users.
• Your Property is primarily intended to generate outbound web traffic or engages in or promotes fraudulent traffic.
• Your Property is predominantly advertisements, and does not include primarily original or publisher generated content.
• Your Property is subject to export controls, sanctions, or cannot demonstrate compliance with applicable data transfer requirements.
• Your Property is a beta, test, or otherwise non-production or non-public Property.
• Your Property promotes or consists primarily of low-quality, artificially generated content (excluding services that are intended for user creation or interaction with generative AI features or services), or lacks meaningful user engagement.

Prohibited and Restricted Content

You cannot use the Platform or Advertising Services to monetize or promote prohibited content. You may be required to seek preapproval or meet other conditions in order to monetize or promote restricted content.

Prohibited Content

Publishers may not use the Services to monetize any of the following prohibited content categories:

• content that is illegal, promotes illegal activity, or infringes on the legal rights of others, including without limitation, privacy or intellectual property rights.
• content that promotes or relates to the sale of fraudulent or unlawful goods or services.
• products or services that cause damage, harm, or injury, including without limitation: recreational drugs (chemical or herbal); psychoactive substances; equipment to facilitate drug use; drug paraphernalia, substance abuse, weapons, ammunition, explosive materials and fireworks; instructions for making explosives or other harmful products; or tobacco products.
• advertisements targeting children.
• pornographic or sexually explicit content, sexually-explicit nudity, sex trafficking, sexual exploitation, adult merchandise, adult entertainment other obscene content.
• content that includes foul, vulgar or obscene language.
• content that promotes products or services that are designed to enable dishonest behavior, including without limitation: hacking software or instructions; services designed to artificially inflate ad or website traffic; document forging; or academic cheating services.
• shocking content or content promoting hatred, intolerance, discrimination, harassment, or violence, excessive profanity, threats, or content that can be characterized as bullying or intimidation toward individuals or groups, promotes hate groups or symbols, or any other hate speech that promotes hateful behavior or ideologies or advocates violence or discrimination against any group, organization, or individual. This includes groups, organizations, or individuals identified by their race or ethnic origin, religion, disability/medical condition, age, national origin, immigration status, refugee status, veteran status, sexual orientation, gender, gender identity, political association, or any other characteristic associated with systemic discrimination or marginalization.
• content promoting harm, e.g. images depicting violence or gore, or content that promotes murder, self-harm, or animal cruelty, graphic depictions of bodily functions or fluids, or grotesque images, footage, or audio, or other potentially offensive, obscene, or sensitive events.
• content that violates or infringes upon any third-party intellectual property rights, including the sale or promotion of counterfeit products, file sharing, torrenting, or other infringing content, or content that violates or infringes any other third-party rights, including confidentiality obligations.
• defamatory or libelous content, or other information that is patently false, misleading, deceptive, or intended to harm or damage the reputation of others, or that impersonates a third party individual or organization.
• content that makes misleading, deceptive, false, or unrealistic claims, unreliable or harmful claims, enables misleading or dishonest behavior, or includes deceptive or misleading ad designs or elements.  This includes things like make-money-fast schemes, chain letters, or pyramid schemes, products or services that help users mislead others or gain unauthorized access to systems, devices, or property, and unacceptable and dishonest business practices. 
• content that attempts to scam users, entices engagement under false or unclear pretenses, attempts to obtain personal information unlawfully or fraudulently, tricks users into sharing personal information, or otherwise uses unacceptable or dishonest practices. 
• malicious or abusive programs, code, or content, including hosting, promoting, or facilitating the use or distribution of malware, spyware, adware, corrupted files, or other materials that could damage, render inoperable, interfere with, or gain unauthorized access to any computer, device, network, or any of the associated data or personal information, as well as any similar forms of digital or internet abuse.

Restricted Content

CloudX may, in its sole discretion and without any obligation, allow the monetization of certain content subject to additional legal or industry restrictions. Subject to our permission, and your compliance with applicable law and any supplemental requirements we may establish from time to time, Publishers may be allowed to monetize or promote the following content:

• alcohol 
• gambling or the promotion of gambling related activities, including services that enable users to place wages or play games to win prizes.
• Marijuana, CBD and other cannabis/hemp derivatives
• Nicotine/tobacco and related products
• Political or cause-based advertising
• Financial products or services, including cryptocurrency or alternative financial assets, prediction markets, and the like
• Health-related websites, including pharmaceuticals, wellness products, or similar health content
• Any other non-prohibited content subject to local advertising or content monetization restrictions

Regardless whether your monetization of restricted content is allowed on our Platform or through the Advertising Services, you accept liability for your content and the actions you take on the Platform and the Advertising Services you request. You are required to ensure that your advertising and content monetization complies with local legal requirements, including geographic targeting restrictions and age verification requirements. If you are subject to age verification requirements, you must ensure that you respond to required age signals, and ensure that you do not request or supply ad space that is not consistent with applicable age designations.

If we receive a complaint about an advertiser’s advertising campaign, we reserve the right to (i) disclose the advertiser’s and/or the your identity to that complainant, and (ii) immediately suspend or terminate the Publisher’s access to the Platform and Advertising Services.

You will disclose clearly any data collection, sharing, and usage by you through the Services or in connection with any advertising campaign provided through the Service.

Prohibited Conduct

You will not, directly or indirectly:

• Allow or engage in any automated,  inauthentic, or other non-human interaction with ads, or other conduct that artificially inflates impressions or clicks, or use artificial means to inflate the volume or cost of impressions, conversions and/or clicks (e.g. click fraud). Clicks and impressions are valid only if they are authentic, human interactions.
• Distribute, or link to pages that distribute, malware or other malicious code or software.
• Use systems or provide an advertising campaign that overlays ad space on a given site without express permission of the site owner.
• Engage in conduct that is deceptive, misleading, or against reasonable expectations.  For example, do not display excessive content not requested by the user, mislabeled links that redirect to unrelated or unexpected content, fake notifications, popups, or messages that lead to an ad or landing page when clicked, social engineering, browser history or settings manipulation, fake error messages or system flags, malware or unwanted software or downloads, or otherwise display any other elements that attempt to trick a user into interactions, engagement, or sharing their personal information.
• Engage in spam or unsolicited communications.
• Impair the usability of a user’s device or application, e.g. by preventing a user from clicking on a page or navigating away from a page.
• Make changes to a user’s browser, application or device, or access features, functions, or data of a user’s device, browser, or application.
• Access the Platform or use the Advertising Services to engage in benchmarking or to evaluate the potential efficacy of or logic underlying the Platform or Advertising Services.
• Collect any data or seek any permissions to access data from and end user unless necessary for you to enable the provision of the Platform and Advertising Services that we provide to you, and provided that you have obtained appropriate permissions to do so.

Requirements for your property

• You must own or have all the right and licenses necessary to integrate with the Platform and engage in Advertising Services on your Property. 
• All ad space must be visible and placed in appropriate locations (i.e., not hidden or invisible, clipped, out of page, or overlapping) and placed reasonably and oriented correctly within the content.  Ads that are not visible or reasonably viewable may be considered, in CloudX’s sole discretion, invalid activity.  
• If your Property is a mobile application, you must comply with all requirements of app stores, including all requirements relating to the handling and reset advertising identifiers, advertising signals, age signals, human interface guidelines, etc.
• You must integrate the Platform and accept bid requests through the Advertising Services only for ad space offered and that is actually available on your Property. You cannot use the Advertising Services to forward requests from a third-party Property.
• Your bid request must include all appropriate information necessary to ensure compliance (e.g. user consent signals or preferences) and accurately describe the inventory offered and its source. 
• Your Property must not be directed at children under the age of 13.

Privacy Requirements

Your integration with the Platform and use of the Advertising Services must comply with all applicable laws and regulations. Without limiting your obligations under applicable law, you must:

• Publish and comply with a privacy policy that is clear and comprehensive, and that describes your collection, use, and disclosure of personal data, including for targeted advertising or data “sharing” purposes, including related measurement activities. The privacy policy must be prominently posted and easily accessible on your Property. 
• Your privacy policy must specifically list CloudX as a third-party that collects data, describe how data is shared with and used by third parties like CloudX, and include the following statement and link in your privacy policy.  “For more information about CloudX’s collection and use of your information visit: https://cloudx.io/privacy” 
• You must provide direct notice to and obtain the appropriate consent from end users relating to your processing of personal data, as required by applicable law. Any consent must be informed, specific, and freely given. 
• You must respect all end user or device-based privacy choices made known to you (whether via GPC/GPP/TCF consent/opt-out signals or other similar methods), including those limiting ad personalization, tracking or measurement, limiting or restricting data use, or age gating/age-specification. You must cease processing when you no longer have a lawful basis to process personal data, including upon a withdrawal of consent, or where an end user objects to processing where the end user’s interests prevail.
• You must follow all of our documentation and otherwise integrate with our Platform in a manner that ensures that you pass through any consent signals or flags in a manner recognized by our Platform. If you use a consent management platform, you are responsible for correctly configuring it. 
• You must comply with all obligations of applicable self-regulatory codes of conduct applicable to you, including (without limitation) your obligations under the IAB’s Multistate Privacy Agreement and Transparency and Consent Framework Policies and procedures (as applicable).
• You must implement and maintain commercially reasonable technical and organizational measures to protect personal data from unauthorized disclosure, use, or other processing, and to protect your Property from unauthorized access or other malicious activity. 

No Sensitive Data 

You may not provide or make available to us, the Platform, or use the Advertising Services to process, create, or derive any personal data relating to or that could reasonably reveal an individual’s racial or ethnic origin, immigration, refugee or veteran status, political opinions, religious or philosophical affiliation or beliefs, trade-union membership, health, sex life or sexual orientation, criminal convictions or alleged commission of an offense, genetic data, biometric data, or other ‘omic data, government-issued identifiers, financial account information, account log-in credentials, the contents of user communications, precise geolocation information, or any other information that could be considered sensitive personal information under applicable laws.  

No child directed services or children’s data

You may not provide or make available to CloudX, directly or indirectly, data collected from a known child or from a service directed at a child, as determined under applicable law. You may not integrate with the Platform, or initiate or use the Advertising Services in any way, if an end user is known to be or is likely to qualify as a “child” under applicable laws. You shall be solely responsible for (1) determining whether an end user of your Property qualifies as a “child” under the definitions and requirements of applicable laws and (2) taking the steps necessary to ensure that you do not integrate with the Platform, or initiate or use the Advertising Services in any way with respect to a “child” under applicable laws. 

If required under applicable law, you must obtain all appropriate consents from users of your Property who are minors who but not children, as determined under applicable legal requirements. 

In addition, you may not use the Services for any Property or portion thereof directed to children, or for any property that could implicate the Children’s Online Privacy Protection Act (“COPPA”) or other similar laws in any other jurisdiction. CloudX does not knowingly collect personal information from children or serve ads to children.

Any violation of this section by any Property operated by Publisher may subject your account to immediate termination, and we may prohibit you from integrating with the Platform or using the Advertising Services in perpetuity, without further recourse.

Enforcement

Any actual or suspected violation of this Policy (or any agreement governing your use of the Services) may result, in CloudX’s sole discretion, in CloudX blocking or limiting ads from appearing against your Property, the suspension or termination of your account or access to the Services, the imposition of limits on your account or access to the Services, and/or the suspension, withholding, or termination of any payments potentially owed to you.  

How to Contact Us

Please contact legal@cloudx.io with any questions regarding this Policy.