1. Introduction

AdMatrix FZ-LLC (“ScreenLeads”, “we”, “our”) has designed the ScreenLeads App Scan application (the “Application”) as business (B2B) software for the staff of venues using the ScreenLeads platform: an all-in-one tool to validate the promotions presented by the venue's customers and to control the venue's screens.

The Application integrates with the ScreenLeads platform and allows people authorized under a business account to scan and validate promotion codes, check redemption status, and remotely manage the screens linked to that account (content, power, and status).

This Privacy Policy explains how we collect, use, and protect the information generated by the use of our Application. The Application is not aimed at end consumers (B2C), but at the staff, managers, and administrators of the companies that use the ScreenLeads platform.

2. Scope

This Privacy Policy applies exclusively to the ScreenLeads App Scan Application distributed through the official app stores (Google Play Store and, where applicable, Apple App Store) and installed on the mobile devices of staff authorized by the Client.

It does not govern the data processing carried out by the ScreenLeads web Dashboard, the ScreenLeads Player application for screens, the Client's external integrations (for example, CRM, automation tools, or messaging systems), or third-party services linked from the ScreenLeads platform. Those services may have independent policies that must be consulted separately.

3. Definitions

For the purposes of this Policy:

• “Client”: The company, organization, or professional that subscribes to ScreenLeads and authorizes the staff who use the Application.
• “Administrator”: A person authorized by the Client to configure accounts, permissions, screens, and content campaigns.
• “Staff User”: A person employed or authorized by the Client who signs in to the Application to validate promotions or control screens.
• “Device”: Mobile phone, tablet, or other compatible hardware where ScreenLeads App Scan is installed and run.
• “Validation data”: Information generated when validating a promotion, such as the scanned code, the associated promotion, the result, the date and time, the validating account, and the Device used.
• “Authentication data”: Information required to sign in with the Client's ScreenLeads account (username, password, session tokens).
• “ScreenLeads API”: Backend services accessible through the URL api.pre.screenleads.com and other related endpoints.

4. ScreenLeads' role and legal bases

In most cases ScreenLeads acts as a Data Processor with respect to the data managed by the Client, which is the Data Controller vis-à-vis its own staff and its end customers, to the extent that the data is processed in the context of the promotions, redemptions, and screens configured by the Client.

To the extent that ScreenLeads decides on the Application's basic telemetry and technical diagnostics (for example, logs and performance data), it may act as a Data Controller with respect to such technical data.

Where the General Data Protection Regulation (GDPR) or similar rules apply, the relevant legal bases include, among others, the performance of the contract entered into with the Client and the legitimate interest in maintaining the security, availability, and performance of the platform, as well as in preventing fraud in promotion redemptions.

5. Data we collect

Given the Application's business focus, we limit data collection strictly to the information needed for staff authentication, promotion validation, screen control, and the technical operation of the service.

5.1. Account and authentication data

We collect and process the following data when a Staff User signs in to the Application:

• Username or email address associated with the Client's ScreenLeads account.
• Name and role/permissions assigned by the Client to the Staff User.
• Password or equivalent credentials entered on the Device.
• Access and refresh tokens (for example, JWT) generated by our servers to keep the session active.

5.2. Promotion validation data

Each time a promotion is validated, the Application generates and sends to our servers:

• The promotion code scanned or entered manually.
• The promotion and campaign associated with the code.
• The validation result (valid, already redeemed, expired, invalid).
• The date, time, staff account, and Device from which the validation is performed.

During validation, the Application shows only the minimum redemption details of the end customer (promotion, status, and code). The Application does not give access to the end customer's full profile.

5.3. Screen control actions

The Application records the management actions the Staff User performs on the Client's screens:

• Assigning or changing content and campaigns on a screen.
• Power on, power off, restart, or status change commands.
• Checking the connection and playback status of the screens.

5.4. Device identifiers

The Application may collect:

• Public or private IP address assigned by the network.
• System identifiers generated by Android or iOS.
• Hardware model and manufacturer of the Device.
• Operating system version and Application version.

5.5. Diagnostics and telemetry data

To ensure service stability, the Application may send to our servers:

• Error logs (crash logs) and failure traces.
• Information about the connection state (online/offline).
• Application health signals, such as response times and success when contacting the API.

6. How we use the information

The information collected is used exclusively to ensure the continuous operation of the B2B service and to fulfil our contractual commitments to Clients.

6.1. Promotion validation and fraud prevention

We use validation data to:

• Check in real time that a promotion code is authentic and current.
• Prevent duplicate or fraudulent redemptions of the same promotion.
• Keep an auditable redemption record available to the Client.

6.2. Screen control

We use authentication data and control actions to:

• Execute on the Client's screens the commands issued from the Application.
• Ensure that each Staff User only acts on the screens authorized by their account and permissions.
• Reflect the updated status of the screens in the ScreenLeads Dashboard.

6.3. Technical maintenance and support

Diagnostics and telemetry data are used to:

• Detect and resolve failures remotely.
• Analyze recurring errors and improve future versions of the Application.
• Handle support requests from the Client and its Administrators.

6.4. Security and abuse prevention

Technical Device information and authentication information are used to:

• Validate the identity of the Staff User and the linked ScreenLeads account.
• Prevent unauthorized access to the Client's promotions and screens.
• Verify that the Application is used in accordance with our terms of service and license.

7. Device permissions

To operate as a staff work tool, the Application requires certain system permissions. These permissions are requested on first run or when the corresponding feature is used, and must be granted by the Staff User.

7.1. Camera

Permissions: CAMERA

Reason:

• Scanning the QR codes of the promotions presented by the venue's customers.
• The camera feed is processed on the Device itself, in real time, solely to decode the code.
• No camera images or video are recorded, stored, or sent to our servers.

If the camera permission is revoked from the Device settings, the scanning feature becomes unavailable, although codes can still be entered manually.

7.2. Internet access and network state

Permissions: INTERNET, ACCESS_NETWORK_STATE

Reason:

• Validating promotion codes in real time against the ScreenLeads API.
• Sending control commands to the screens and receiving their status.
• Checking the Device's connectivity for support and monitoring.

7.3. Notifications

Permissions: POST_NOTIFICATIONS (or system equivalents).

Reason:

• Showing operational notices relevant to staff, such as screen incidents or validation confirmations.

The Application does not request precise location, microphone, or contacts permissions, unless future versions require it. In that case, we will update this Policy and show prominent notices within the Application itself in accordance with the app stores' policies.

8. Cookies and similar technologies

The ScreenLeads App Scan Application does not use browser cookies in the classic sense, as it runs as a native application. However, it may use local identifiers and the Device's internal storage to keep the session, manage caches, and maintain minimal state information between restarts.

These mechanisms are used solely to ensure the proper functioning of the Application and not for advertising tracking purposes.

9. Sharing data with third parties

ScreenLeads acts as a Data Processor with respect to most of the data generated by the Application and does not sell or rent staff information, redemption records, or credentials for advertising purposes.

Data may be shared only in the following cases:

• The Client: As Data Controller, it has access to the activity of its staff accounts (validations performed and actions on its screens) through the ScreenLeads Dashboard.
• Cloud infrastructure providers: Hosting and processing needed to run the API, store logs, and keep redemption records.
• Monitoring and logging services: Performance and error-logging tools, limited to technical data.
• Legal requirements: Disclosure to competent authorities when required by law, a court order, or a valid request.

10. International data transfers

AdMatrix FZ-LLC is headquartered in the United Arab Emirates and may use providers located in different jurisdictions. In the event of international data transfers, we take reasonable measures to ensure an adequate level of protection, in accordance with applicable laws.

Where the GDPR or similar rules apply, standard contractual clauses and other safeguard mechanisms may be used.

11. Data retention

We retain the information associated with the ScreenLeads App Scan Application only for as long as necessary to maintain the service, document redemptions for the Client, resolve technical incidents, and comply with legal obligations.

• Validation records are retained for the duration of the contract with the Client and the periods agreed with them; afterwards they are deleted or anonymized.
• Error logs and telemetry data are retained for limited periods and then anonymized or deleted.
• Staff account data is kept while the Client keeps the account active.
• Authentication credentials are processed transiently and replaced by short-lived encrypted session tokens.

12. Security

We apply enterprise-grade security standards to protect our infrastructure and the information processed. All communication between the Application and our servers is encrypted using secure protocols, and access tokens are generated with limited validity.

Access to promotions and screens is controlled through roles and permissions defined by the Client. We limit internal access to data to the personnel and systems that need it, and we use access controls, auditing, and monitoring to prevent unauthorized access and detect security incidents.

13. Rights of Clients and staff

Depending on applicable law, Clients, Administrators, and Staff Users acting as natural persons may exercise rights over their personal data, such as access, rectification, erasure, restriction, objection, and portability.

As staff accounts are managed by the Client, most of these rights are exercised vis-à-vis the Client as Data Controller. ScreenLeads will cooperate with the Client to facilitate compliance with requests affecting data processed through the Application; you can also write to us directly at the address indicated in the contact section.

14. Minors

The ScreenLeads App Scan Application is not aimed at minors and does not allow end consumers to create personal accounts. It is designed for use by the authorized staff of companies using the ScreenLeads platform.

15. Links and third-party services

The Application communicates with ScreenLeads backend services to validate promotions and control screens and, indirectly, may integrate with other Client systems (for example, CRM or automation tools) configured from the Dashboard.

This Policy does not cover the processing carried out by those external services. We recommend reviewing the privacy policies of each integrated provider.

16. Changes to this Privacy Policy

We may update this Privacy Policy when we add new features, our processing practices change, or we need to adapt to new regulations or app store requirements.

We will update the “Last updated” date and, where reasonable, notify Clients and Administrators through appropriate channels. Continued use of the Application after an updated version is published constitutes acceptance of those changes.

17. Contact information

For legal, technical, or privacy inquiries related to the data processed by ScreenLeads App Scan, you can contact us at:

• Legal name: AdMatrix FZ-LLC
• Physical address: Compass Building, Al Hulaila Industrial Zone‑FZ, Ras Al Khaimah, 10000, United Arab Emirates.
• Privacy email: privacy@screenleads.com
• General email: david@screenleads.com

Please indicate in the subject line that your inquiry refers to the ScreenLeads App Scan Application to speed up the response.