Privacy Policy of Bubble Friends
Bubble Friends collects some Personal Data from its Users.
Policy summary
Personal Data collected for the following purposes and using the following services:
Access to third-party accounts
Facebook account access
Permissions: About Me, Access Friend Lists, Birthday and Photos
Advertising
AdMob and Facebook Audience Network
Personal Data: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data
AppLovin, AdColony, Chartboost, Unity Ads and Vungle
Personal Data: Cookies and Usage Data
Adjust
Analytics
Facebook Analytics for Apps and Unity Analytics
Personal Data: Usage Data and various types of Data as specified in the privacy policy of the service
Appsflyer
Personal Data: Cookies and Usage Data
Device permissions for Personal Data access
Device permissions for Personal Data access
Personal Data: Storage permission
Managing support and contact requests
Zendesk
Personal Data: various types of Data as specified in the privacy policy of the service
Registration and authentication
Facebook Authentication
Personal Data: various types of Data as specified in the privacy policy of the service
Remarketing and behavioral targeting
Facebook Custom Audience
Personal Data: Cookies and email address
Social features
Inviting and suggesting friends
Personal Data: various types of Data
Further information about Personal Data
ironSource Mobile Ltd.
ironSource Mobile Ltd. Privacy Policy
Effective Date: May 25, 2018
Table of Contents:
About Us.
Scope.
Information We Collect.
How We Use the Information We Collect.
Maximum Information Retention Period.
How We Share Your Information.
How to Control Your Information.
Children.
International Transfers.
Changes to This Privacy Policy.
Contact Us.
About Us
ironSource Mobile Ltd. (“ironSource Mobile”) operates 3 main services:
Ad Network – We have a network that connects app developers with advertisers, and helps app developers to serve ads on their apps. App developers means the company or individual that developed and operates the mobile app that is integrated with or otherwise sends information to ironSource Mobile. Advertiser is a company or an individual that advertises its products or services within the app.
Mediation Platform – A platform that helps app developers to manage all the ad providers with which they have a direct relationship (e.g. ironSource Mobile ad network, third party ad networks, additional online advertising companies, etc.) that serve ads on their apps.
Marketing Platform – We help advertisers to create and optimize advertising campaigns.
We collect information in either of 2 ways:
Directly – from your device through our SDK integrated by app developers in their apps. SDK, or a Software Development Kit, is a software component that allows us to serve ads in a mobile app, and to collect information directly from the end users of such app.
Indirectly – through other ad networks with which we engage in order to serve you with ads, or by receiving information from our advertisers.
We collect information as described in this privacy policy for ironSource Mobile’s own purposes, as a data controller under data protection law where relevant, except as otherwise indicated herein.
Scope
This privacy policy describes ironSource Mobile’s privacy practices with respect to information it processes through its ad network, mediation platform, and marketing platform. This privacy policy does not govern the use of our website, dashboard for publishers, and dashboard for advertisers.
ironSource Mobile serves ads to users all around the world. Accordingly, throughout the document, we try to harmonize our approach and the language of the privacy policy as much as possible. However, sometimes we refer to specific laws that require further disclosures. Accordingly, whenever you see throughout the policy the annotation “The GDPR angle”, it means that the purpose of such section is to satisfy the transparency requirements of the General Data Protection Regulation (AKA the GDPR), and therefore it applies only to users (devices) who we deem to be located in the European Economic Area, United Kingdom, or Switzerland.
Information We Collect
Information collected directly from you through our SDK, and information provided to us by a third party ad network (“Ad Network Information”) –
Identifiers: Your Advertising ID, an additional unique identifier of available solely from within the app of the app developer which cannot be used to identify you on other apps, IP address, information about your browser settings. The term Advertising ID refers to the Google Advertising ID on Android devices, and ID For Advertising (“IDFA”) or ID For Vendor (“IDFV”) on iOS devices. The Advertising ID is a resettable persistent identifier generated by Android or iOS that allows online advertising companies to recognize your device across non-affiliated apps, for purposes such as frequency capping, attribution, fraud detection, personalized advertising, and whitelisting. You can find additional information about how to limit our use of your Advertising ID under “How to Control Your Information”.
General technical information about your device: The ironSource Mobile SDK version, your time zone, the amount of free memory on your device, the name and version of the app to which the ad is served, battery status, limit ad tracking status, operating system name and version, timestamp, the name of the manufacturer of the device, the language of the operating system, the name of the mobile carrier, internet connection type (e.g. WiFi).
Interaction with our ads: An indication if you viewed or clicked on an ad.
Information received (through our SDK) from app developers that are integrated with our mediation platform (“Mediation Information”) – your age, gender, in-app purchases, advance in the game, and such other information provided by the app developer.
Information received from advertisers (through the advertiser itself or through a third party in behalf of such advertiser) (“Advertiser Information”) –
Identifiers: Your advertising ID, IP address, a unique identifier of your device available solely with respect to the advertiser, information about your browser settings.
Campaign information: an indication that you installed the advertiser’s app following a click on or a view of an ad served by us or otherwise; information about actions you performed within an advertiser’s app following such an install, such as in-app purchases, level in the game, and the number of times you opened the app; and other information that the advertiser decides to share with us.
How We Use the Information We Collect:
As stated above, we perform 3 main services. For each such service, we use the information we collect in different ways. Below is a general description of how we use your information across our services:
Serving Ads on App Developers’ Apps – We use the Ad Network Information collected from your device to serve ads on app developers’ apps. More specifically, we use such information for the following purposes:
Ad delivery: we use your Ad Network Information to technically enable the delivering of ads to your device.
Reporting, billing and attribution: We use your Ad Network Information to generate reports for our publishers and bill advertisers and publishers, including for ensuring that if you interacted with our ads, we will receive payment for our service.
Internal Operations: We use your Ad Network Information for internal operations, such as debugging, support, security, and improving our services.
Fraud detection and prevention: We use your Ad Network Information for detecting and preventing fraud, and for ensuring viewability of our ads.
Optimization and frequency capping: We use your Ad Network Information for optimizing advertising campaigns, including for limiting the number of times you view a specific campaign across our network, or the number of ads you view in a specific app.
Personalized advertising: Our corporate affiliates and advertisers may use your Ad Network Information for personalized advertising (i.e. ads that are based on your interest or profile).
Operating our Mediation Platform – We use your Advertising ID, IP address, and Mediation Information collected from your device to operate our mediation platform. More specifically, we use such information for the following purposes:
Reporting: We generate reports for the app developers using our mediation platform in order to allow them to better understand their audience in terms of interaction with ads.
Segmentation: We allow app developers to create segments based on parameters they configure in our mediation platform. Such segmentation allows them to use different ad networks and different ad units for different segments of users. However, this feature does not allow them to serve you with personalized advertising, as app developers cannot control the content of the ads served by different networks.
Sending ad requests on behalf of the app developer: In addition to the other information used to operate the mediation platform, we use the Ad Network Information in order to send ad requests on behalf of the app developer to ad networks with which the app developer has direct contractual relationship, but due to technical reasons, we are in the best position to populate the ad request with the Ad Network Information.
Operating our Marketing Platform – We use the Advertiser Information received from our advertisers to operate our marketing platform. More specifically, we use such information for the following purposes:
Optimizing advertising campaigns: We optimize campaigns for our advertisers based, for example, on events that happen in their app or indications of installs received from other apps.
Suppression: We use device IDs of users of an advertiser’s app in order not to serve advertising campaigns of such advertiser to such users, as they already have the advertiser’s app.
Whitelisting/blacklisting: We allow advertisers to upload lists of device IDs to include/exclude in their advertising campaigns.
Compliance with legal obligations – We may use your Ad Network Information, Mediation Information, and Advertiser Information to comply with applicable legal obligations.
The GDPR Angle:
We act as a processor – When we process Ad Network Information, Mediation Information and Advertiser Information on behalf of app developers, we act as their processors. For any request to exercise your individual rights related to such processing (including the rights of access, rectification, erasure, portability, and the right to restriction and/or object to processing), you should contact the relevant app developer.
We also act as controllers and process personal data on the basis of legitimate interest – When we process Ad Network Information for the purposes of optimization and frequency capping (to ensure you are not seeing the same ad too many times), fraud detection and prevention (to ensure that our ads are not viewed by bots, and/or any other fraudulent means), and internal operations, as detailed above (to ensure you receive smooth and secured experience), on the basis of our legitimate interest or the legitimate interests of our app developers, in order to ensure a specific campaign is .
Personalized Advertising in the European Economic Area, United Kingdom, and Switzerland – At the moment, we do not serve personalized ads to users who are located in the European Economic Area, United Kingdom, and Switzerland. However, as a result of technical considerations, on certain occasions, we may be included in consent pop-ups operated by app developers and ad networks that are engaged with us. If we start serving personalized advertising to users who are located in the European Economic Area, United Kingdom, and Switzerland, we, will ask you for your consent (typically through consent pop-us managed by app developers and ad networks with which we work).
Further processing of Advertiser Information – When we process Advertiser Information, we may further process Advertiser Information for optimization of our network based on our legitimate interest.
Legal necessity – We may process your Ad Network Information, your Mediation Information, and your Advertiser Information for compliance with applicable legal obligations.
Maximum Information Retention Period:
We will retain your Ad Network Information, Mediation Information, and Advertiser Information for the longer of: (i) a period of up to 2 years from the date such information is first stored in our systems; or (ii) a period of 3 months from the last appearance of your Advertising ID in our systems.
How We Share Your Information:
We share your Ad Network Information with:
Other ad networks – for the purpose of receiving advertising campaigns from such ad networks.
Our corporate affiliates – from which we receive services, such as IT, security, storage, delivery of advertising campaigns, personalized advertising, and other internal operations.
Advertisers – for the purposes of attribution and whitelisting/blacklisting, as stated above.
Service providers – We share your Ad Network Information, Mediation Information, and Advertiser Information with our service providers for the purpose of receiving services such as fraud detection and prevention, viewability measurement, reporting, and storage.
Viewability measurement – Please note that certain versions of our SDK may include MOAT, Inc.’s SDK for the purpose of verifying if our ads were actually viewed. Please review MOAT, Inc.’s privacy policy to learn about their privacy practices, as available at: https://moat.com/privacy.
How to Control Your Information:
Personalized Ads – We collect and transfer Ad Network Information to other entities (including our corporate affiliates and non-affiliates such as advertisers, other ad networks, and third parties acting on behalf of these types of entities) that use the information described in this Privacy Policy for serving you with personalized ads (i.e. ads that are based on your interests or profile).
Opt out from personalized ads – If you do not want us to transfer your information to corporate affiliates and third parties for personalized ads, please follow the below instructions:
iOS devices: go to Settings > Privacy > Advertising > enable Limit Ad Tracking. Please note that if you use more than one device, you need to opt-out separately in each device.
Android devices: Please follow the instructions set forth at: https://support.google.com/ads/answer/2662922?hl=en. Please note that if you use more than one device, you need to opt-out separately in each device.
Scope of the opt-out – Note that if you reset your advertising ID through your device’s platform settings, you should follow the steps above to reset your opt-out choice. In addition, opting out may not stop data from being collected from your device or transferred for other, non-personalized advertising purposes such as optimization, reporting, frequency capping, internal operations, and fraud prevention. If you become aware of any third party that received your Ad Network Information from us, and that does not respect your choices, please let us know by contacting us at: dpo@ironsrc.com.
The GDPR Angle:
Data subject rights – Please note that you have the right to request from us access to and rectification or erasure of your personal data we process as controllers, or to restrict or to object to processing of your personal data in accordance with the provisions of the GDPR. To submit a request for exercising your rights, please send an email with your request to the following address: mobile-gdpr-request@ironsrc.com. Please note that we will process your request subject to verification of your identity.
Complaint to supervisory authority – You also have the right to file a complaint with the relevant supervisory authority (e.g. of your country or domicile) where ironSource has not addressed your concerns.
Children:
ironSource does not knowingly collect or maintain personal information collected online from children under the age of 13, except to the extent that the U.S. Children’s Online Privacy Protection Act permits us to collect and maintain such information without parental consent. If you believe your child has provided us with personal information that is covered by the U.S. Children’s Online Privacy Protection Act without your required consent, please contact us at legal@ironsrc.com and we will make reasonable efforts to delete the information from our records. Our services may link to other websites or mobile apps. Please be advised that we are not responsible for the privacy practices of such other websites or mobile apps as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these websites and/or mobile apps and we shall not be responsible for any use of such websites and/or mobile apps.
The GDPR Angle:
We do not collect or otherwise process personal data from individuals in the European Economic Area, the United Kingdom, and Switzerland whom we know to be under 16 years of age, except to comply with law or to support our legitimate interests or the legitimate interests of our app developers as described above.
International Transfers:
We store information that we collect from your device on our Amazon Web Services servers in the United States. Accordingly, please note that if you do not live in the United States, we will transfer your information to and store it in, the United States.
The GDPR Angle:
If you are located in the European Economic Area, the United Kingdom, or Switzerland, we will transfer your information to the United States based on the Standard Contractual Clauses. If you wish to receive a copy of these clauses, please contact us through the below contact details.
Changes to This Privacy Policy:
We may revise this Privacy Policy from time to time. The most current version of the policy will govern our processing of your information and is posted at https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/. If we make a change to this policy that, in our sole discretion, is material, we will notify you via a banner on this website and by posting the revised Privacy Policy. By continuing to access or use an app containing our services after those changes become effective, you agree to be bound by the revised Privacy Policy.
Contact Us
ironSource Mobile Ltd.
121 Menachem Begin Rd., Tel Aviv, Israel
Attn: Data Protection Officer
ironSource Mobile Privacy Policy – Previous Privacy Policy Prior to May 25, 2018
ironSource is committed to respecting and protecting individuals’ privacy rights. This Privacy Policy (the “Privacy Policy”) describes how ironSource Ltd. and its subsidiaries (collectively “ironSource” or “we”, “us”, “our”) uses end users (“you” or “your”) information when you view ads served by platforms and services operated by ironSource Mobile Ltd. on third party websites or mobile apps (the “Services”).
Please read this Privacy Policy carefully. This Privacy Policy provides you with information on how we collect, use and/or share the information we obtain from you. This Privacy Policy applies to the Services and does not apply to any other ironSource products or services, or to any content or privacy practices on any websites or mobile apps not owned and operated by us that may be available as part of, linked to, from or in conjunction with the Services.
We may need to change this Privacy Policy from time to time in order to address new issues and to reflect changes to the Services or the applicable law. We reserve the right to revise or make any changes to this Privacy Policy in our sole discretion, and your continual use of the Services subsequent to any changes to this Privacy Policy shall conclusively mean that you accept such changes. You can tell when this Privacy Policy has been updated by checking the effective date posted on the top of this page.
BY ACCESSING AND/OR USING THE SERVICES, YOU CONSENT TO OUR USE OF ANY INFORMATION THAT YOU PROVIDE TO US OR THAT WE COLLECT FROM YOU IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT ACCESS AND/OR USE THE SERVICES.
CHILDREN’S PRIVACY POLICY (COPPA). ironSource also does not knowingly collect or maintain personal information collected online from children under the age of 13, to the extent prohibited by the Children’s Online Privacy Protection Act. Nor do we knowingly create profile segments of children under 13 years of age. If you believe your child has provided us with information that is covered by the Children’s Online Privacy Protection Act, or has registered with our Website, please contact us at legal@ironsrc.com and we will make reasonable attempts to have the data purged from our records.. The Services may link to other websites or mobile apps. Please be advised that we are not responsible for the privacy practices of such other websites or mobile apps as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these websites and/or mobile apps and we shall not be responsible for any use of such websites and/or mobile apps.
INFORMATION WE COLLECT AND USE. When you view an ad served by our Services on a website or mobile app or prior to that, when such website or mobile app send a request for an ad to us, we may collect information about your device or the ad that you have viewed. Such information may include device type (including manufacturer and model), operating system, IP address, Android advertising identifier and/or IDFA, as applicable, the time-zone and language set by the device, the mobile carrier, the type of the internet connection used by the device, the free space currently available on the device, and other statistical and technical information. Certain versions of our Services may collect location information based on the geo-location of your device, if location services have been enabled for the mobile app or website that uses our Services; We also collect some or all of the following information about the ad you have viewed: the ad type; the ad content; the location of the ad being served and certain post click information in relation to the ad. On occasion, our publishers or developers may also disclose to us information they have separately collected about you including, but not limited to, your gender, and the date on which you signed up to the publisher’s or developer’s services. This information is provided in accordance with their own specific privacy policies and subject to their own applicable legal requirements. We collect and use this information to operate, measure and improve the Services over time, provide you with the requested services, respond to your inquiries, and protect our rights or property.
CORPORATE AFFILIATES. We may use services and/or features developed by our corporate affiliates, when you use these services and/or features information about you may be collected by them. You hereby consent to our collection and use of such information.
INFORMATION YOU PROVIDE US. When you send us emails, contact our technical support or when we offer advertising solutions that include the collection of your email address as part of an advertisement, you are communicating with us voluntarily. You agree to receive electronic communication from us and that all communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. You also agree that we may keep record of your correspondence with us and that we may use any information you provide to us voluntarily to improve the Services or otherwise at our sole discretion. Your correspondence may include personal information should you chose to provide it to us.
ADDITIONAL FEATURES. We are always seeking to improve the Services. Therefore, we may introduce new features, some of which may result in the collection of additional information from you. If we start collecting additional types of personal information and materially change how we handle such information, we will modify this Privacy Policy and notify you in accordance with Section 6 (Changes to This Privacy Policy).
INFORMATION SHARING AND DISCLOSURE. We may share the information we collect with our advertisers, developers and publishers. We may also share your information in the event that we have a good faith belief that disclosure is permitted by law or is reasonably necessary to: (i) comply with the law, a legal requirement or process, including without limitation, subpoenas, court orders, or other compulsory disclosures, or to establish, maintain or exercise our legal rights; (ii) enforce this Privacy Policy; (iii) investigate, prevent, or take action regarding suspected or actual illegal activities or violation of third party rights; or (iv) protect our rights. In addition, in the event that we undergo a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be one of the assets sold or transferred.
SERVICE PROVIDERS. We may employ third parties to provide us with maintenance, analysis, audit, and development services with respect to the Services and in such instances we may provide your information to such third parties. We currently use Amazon Web Services, Inc. servers to process your information. You can read about the measures taken by Amazon Web Services, Inc. to protect the security of their servers and your information at: http://awsmedia.s3.amazonaws.com/pdf/AWS_Security_Whitepaper.pdf. We also use Forensiq’s and PerimeterX’s services with respect to some of our Services to detect and prevent fraud. You can read their privacy policies at: https://forensiq.com/privacy-policy/#service-privacy and https://www.perimeterx.com/privacy.
THIRD PARTIES. Among other things, we operate a service that enables the operators of a mobile app to manage and allow third parties to serve campaigns on such mobile app, and to collect information about the users of such mobile app for the purposes agreed between such third parties and the operators of such mobile app. Please be advised that we are not responsible for the privacy practices of such other third parties or mobile apps as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these third parties and/or mobile apps and we shall not be responsible for any use of such websites and/or mobile apps.
DATA TRANSFER. We may transfer your information and process it on servers outside your country of residence. If your country of residence is part of the European Union or the European Economic Area, please note that we will transfer your data outside of the European Union or the European Economic Area.
SECURITY. We have implemented reasonable security safeguards designed to protect your personal information. Nevertheless, as the Internet is not a 100% secure environment, we cannot guarantee the security of any information that you transmit to us. There is no guarantee that information on our servers may not be accessed, disclosed, altered, or destroyed by breach of our safeguards.
DELETING YOUR PERSONAL INFORMATION. You have a right to request that we delete any of your personal information in our possession by sending us an email to: legal@ironsrc.com.
CONTACT INFORMATION. If you have any questions or comments about this Privacy Policy, please contact us at legal@ironsrc.com.
IRONSOURCE MOBILE PRIVACY POLICY
Last updated: March 4, 2018
Admost
Privacy Policy
We are updating our Privacy Policy which clarifies the details of personal data usage in
accordance with privacy protection. We will share personal data, which is collected via
website or taken by Admost services, only in the ways described in this privacy policy. We
do not sell any personal data to Third Parties.
Admost collects personal data in order to provide the services or business purposes, please
note that you are not required by law to provide Admost with any personal data.
This Privacy Policy explains working principle of Admost and which information get through
the system. The terms “Admost”, “we”, “our” and “us” include Admost Mediation Limited and any
affiliates and subsidiaries.
This Privacy Policy may be updated from time to time. In the event of any material changes
there will be a post of new Privacy Policy on the website. We encourage you for consulting this
Privacy Policy regularly for any changes.
Privacy Policy
1.Admost Services
Admost is a tool that optimizes ad revenues and gives analytical information for mobile apps.
Mediation service working principle work through integrating Admost Software Development
Kit to mobile app; to send requests and get ads over Admost Mediation Router which are
provided by ad networks.
Analytics service gives analytical data of mobile apps to publishers. Analytics service gives
details of user behavior to a publisher for improving mobile app performance and retention
rate.
2. Personal Data Collected by Admost via Web Site
Registration Information: Admost website collects information as name, email, phone
number, company name and app/game link for completing the signing up process. Admost
may use your information for its business purposes; to contact you, for support services and, for
marketing purposes.
You can subscribe for newsletter services preferably, thereafter you have an option to unsubscribe.
Also, our employees are sworn to confidentiality.
3. Analytical Information of Web Site
Admost website utilize a service of Google Analytics which collects information as
device/browser, IP address and on-site/app activities to measure and report statistics about
user interactions on the websites and/or apps anonymously.
You can find more details in http://www.google.com/analytics/learn/privacy.html for Google
Analytics Services and you can opt out by going to http://tools.google.com/dlpage/gaoptout.
4. Admost may share personal data
When required by law or regulation
To protect our rights or preserve the safety of our users
If required to investigate fraud; may include exchanging information with other companies and organisations.
Situation of Merger & Acquisition, Sale of All or Portion of Assets: In the event of thistype of situation your personal data will be shared under the appropriate confidentiality and only for purposes which you approved in the first place.
You should be aware of that the information submitted to public areas, such as blogs, may
be used by others.
5. Accessing your personal data
You may contact us and request to access the personal data that Admost keeps by mailing
privacy@admost.com. There will be some requisites to make sure that you are the owner of
the account.
If you want to delete data that you have provided or withdraw your consent, please contact
us by privacy@admost.com and Admost will respond within a reasonable time after
receiving your email.
After your deletion request put into the process, it will be deleted on Admost active servers
immediately but deletion on backup systems will occur in 7 days. Also, you should be aware
of that deletion cannot retrieve or delete personal data which has been already shared with
partners and other Third Parties.
Please be aware that your personal data can be used by Admost to comply with legal
obligations and Admost’ s agreements.
6. Mediation & Analytics as Services
Mediation provides service to publishers. To activate publisher account, Admost needs
information for registration and completing setup process which may collected by the website.
Account information include name, company name, telephone number and email. If you are
not volunteer to share this information with Admost, you may choose to send mail to
amr@admost.com. For payment process, Admost need billing information which keeps in a
secure system within company.
For providing our services as mediation, publishers should integrate a software development
kit (SDK) to their mobile applications. Admost collects information about end users of mobile
applications through SDK, including Advertising IDs (IDFA), usage statistics such as
session, duration, impression and click-throughs.
Mediation service provides ads for publisher via ad networks. System inform publisher about
which ad networks will be integrated to their mobile application. Publishers agree that for
using Admost SDK, they should get appropriate consent from their users for using and
sharing of personal data through Admost SDK. It is important to take consent from users
which should be compatible with laws and regulations for the country that your mobile
application users are located.
Ad networks as ad providers send targeted ads that associated with end-users point of
interest with the help of Mobile Advertising ID which can be considered as personal data.
End users have an option to limit the access Advertising ID (IDFA) for ad targeting on your
devices.
For iOS devices: Settings > Privacy > Advertising > Limit Ad Tracking.
For Android devices: Google Settings > Ads > Opt Out of Interest-Based Ads. Other option is to reset the Advertising ID (IDFA) on your mobile device.
For iOS Devices: Settings > Privacy > Advertising > Reset Advertising Identifier.
For Android: Google settings > Ads > Reset advertising ID.
Such an fresh start makes harder to associate with your past activity, but tracking will be
continue as a new user.
Mediation service has reporting feature for publishers to have information about ad/revenue
performance. Reports include information as geographic and demographic which are de-
identified information. This type of information is not Personal Data and helps analyze
revenue distribution based on country to help publishers for improving their businesses.
Publishers may submit voluntary their Advertising ID for adding testers for test process.
Analytics service provides analysis of user experience for publishers. Admost collects
information about end users of mobile applications through SDK, including Advertising IDs
(IDFA), usage statistics such as session, duration, impression and click-throughs and create
aggregated and anonymous information. The analytics report provided by Admost includes;
user acquisition, session information, cohort analysis, retention analysis and in-app
purchases.
Publishers have an option for not giving consent for collecting Advertising IDs (IDFA) of their
mobile apps’ users. Collecting Advertising IDs may varies depending on location of users
according to laws and regulations. If there is constraints for collecting Advertising IDs as
personal data, the default option will be not collecting Advertising IDs.
7. GDPR Rights for EU people
General Data Protection Regulation imposes restriction for using personal data without
getting the consent of EEA and Switzerland users.
GDPR Terminology
Data subject: A data subject is a natural person. Examples of a data subject can be an individual, a customer, a prospect, an employee, a contact person, etc.
Personal data: Any information relating to an identified / identifiable individual, whether it relates to his or her private, professional, or public life. Can be anything from a name, photo, email address, bank details, posts on social networking sites, medical information, IP address, or a combination of the data that directly or indirectly identifies the person.
Data controller: Any organization, person, or body that determines the purposes and means of processing personal data, controls the data and is responsible for it, alone or jointly. Examples of the data controller is an individual include general practitioners, pharmacists, and politicians, where these individuals keep personal information about their patients, clients, constituents etc. Examples of organizations can be data controllers, for profit or not for profit, private or government-owned, large or small, where those organizations keep personal information about their employees, clients, etc.
Data processor: A data processor processes the data on behalf of the data controller. Examples include payroll companies, accountants, and market research companies.
Processing: Processing is an operation performed on personal data (sets), such as creation, collection, storage, view, transport, use, modification, transfer, deletion, etc., whether or not by automated means.
For website, Admost processes data as controller and adapting website fully compatible with GDPR.
For Mediation and Analytics services, publishers who provide service in GDPR applicable
areas should admit the responsibility for taking consent to collect personal data of users.
As EEA and Switzerland residents, you have options indicated below:
You can access data that Admost and ad networks partners keep about you. There will be some requisites to make sure that you are the owner of the account. You may change data in case of any inaccurate, outdated or missing data and provide us with the necessary information to set aright it.
You can withdraw your consent if you do not want your personal data to continue to be processed. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
You can request delete or restrict access to your personal data. If your personal data is in current use for providing services or legitimate purposes, your request may be postponed or get rejected. After your deletion request put into the process, it will be deleted on Admost active servers immediately but deletion on backup systems will occur in 7 days.
You may request to be informed for actions that Third Parties do with your personal data.
You have the right to have the personal data transmitted directly from one controller to
another, where technically feasible (Art 20 para 2). You have the right to object at any time
to processing of personal data concerning you for such marketing, which includes profiling to
the extent that it is related to such direct marketing (Art 21 para 2). You have the right not to
be subject to a decision based solely on automated processing, including profiling, which
produces legal effects concerning or significantly affects you (Art. 22 para 1). You have a
right to lodge a complaint with a data protection supervisory authority. (Art. 77 para 1)
Admost is the data processor for your Advertising ID data.
IDFA-like data used by Admost; Companies like Apple, Google, etc. are the pseudonymous data created for targeted advertising purposes. Here is how you will use your rights of disposition on this data. This data will be processed for targeted advertising, without matching your other personal data.
Pseudonymisation is recognized as a safeguard that reduces the risks to data subjects and helps controllers and processors meet their data protection obligations. If you have any concerns, please do not hesitate to contact Admost at privacy@admost.com.
8. Data Retention
Admost retains the information about you for as long as you use Admost services or as
necessary for business purposes or required by legal obligations. Unless you request to
delete your information or required by law, Admost will keep information about you for active
accounts.
For accounts that do not have any action for 180 days, information will be deleted from
Admost system.
9. Children
Admost do not knowingly collect, maintain or use personal data from children under the age
of 13 (and in certain jurisdictions under the age of 16) or from websites or online services
directed to children under the age of 13 (and in certain jurisdictions under the age of 16). In
the unlikely event, as a parent or legal guardian of a child you may alert us
privacy@admost.com to have your child’s personal data deleted.
10. Information Security
The security of your personal and non-personal data is important to us. Admost takes
necessary precaution and security standards to protect you personal data. We encrypt your
personal data to prevent unauthorized access, damage, expose or use of information.
Please be aware that Admost cannot guarantee the security of any information you provide
to us. Although we take all precautions to provide security of your personal data, we do not
promise that your personal data will always be in secure. In the event of any security flaw,
you will be noticed by website or an email.
11. Data Transfer
We may share your information as described in this Privacy Policy (with ad networks as our
Third-Party service providers, when required by law, to protect our rights or preserve the
safety of our users) or with your consent.
The complete ad network list as Third-Party service provider list can be found here:
Admob
Facebook
One by AOL
Adcolony
Flurry
Pollfish
Adtiming
Fyber
Startapp
Adview
Double Click Ad Exchange
IronSource
Amazon
Inmobi
Tapjoy
Applovin
Inneractive
UnityAds
Appnext
LoopMe
Smaato and its partners
Avocarrot/Glispa
Mobfox
Vungle
Chartboost
Mopub
YouAppi
12. California Privacy Rights
For California residents, California law permits users to request the list of relating Third Parties
to which Admost has disclosed personal information for direct marketing purposes during the
preceding year.
Admost does not share Personal Information with Third Parties for their own marketing
purposes.
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13. Our right to change the guidelines without prior notice
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We reserve the right to change these guidelines at any time, taking into account all applicable privacy protection laws.
14. Contact Us
If you have any questions about this Privacy Policy, please contact us at
Tapjoy
Tapjoy Privacy Policy
Table of Contents [show]
Tapjoy Privacy Policy
Tapjoy, Inc. (“Tapjoy,” “we,” “us,” “our”) cares about our users’ privacy and is committed to disclosing our data practices. This Privacy Policy explains how Tapjoy collects, uses, and shares information from and about you when you: (i) use mobile applications from app publishers (“Publisher(s)”) that integrate Tapjoy ads or other Tapjoy publisher services (“Tapjoy Ad Platform”); and/or (ii) visit the Tapjoy corporate website or use any Tapjoy Web Services, as defined below. (Tapjoy Ad Platform and the Tapjoy Web Services are referred to hereinafter as the “Tapjoy Services”). Please note that Tapjoy publishes certain mobile applications (“Tapjoy Apps”); with respect to Tapjoy Apps only, references to “Partner App” and “Publisher” include the Tapjoy Apps and Tapjoy, respectively.
Tapjoy is a member of the Interactive Advertising Bureau (“IAB”) and abides by the IAB Code of Conduct including its “Self Regulatory Principles for Online Behavioral Advertising.” More information about the IAB may be found here. If you have any questions, please contact us at privacy@tapjoy.com.
This Privacy Policy contains the following sections:
Tapjoy Ad Platform Privacy Practices
Tapjoy Web Services Privacy Practices
Tapjoy General Privacy Practices
Tapjoy Ad Platform Privacy Practices
1. The Information We Collect via the Tapjoy Ad Platform
When you interact with a mobile application that has partnered with Tapjoy for the purpose of displaying advertisements within the app (a “Partner App”), we and/or our service providers may collect a variety of information about your device and the Tapjoy ads that you view. The Publisher of the Partner App is responsible for obtaining your consent, if required and as applicable, to enable us to collect information from your device. The information we collect may include the following:
Information about your device.We may collect some or all of the following information about your device: device identifiers, which may include Google Advertising ID (GAID), Android ID, ID for Advertisers (IDFA), ID for Vendors (IDFV), MAC address, International Mobile Equipment Identity (IMEI), or other unique device identifiers; device type (e.g., mobile, tablet); type and version of operating system (e.g., Android, iOS); network provider; IP address; mobile browser (e.g. Safari, Chrome, etc.); the carrier user ID (a number uniquely allocated to you by your network provider); Tapjoy SDK version used by the Partner App; timestamp; API key (identifier for application); Partner App version; manufacturer and device model; language setting; time zone; network status type (such as WiFi); list of installed apps (the applications and/or processes which are installed or run on your device while the Partner App is active or inactive).
Precise Location Information and How to Opt Out of Location Tracking. The Partner App may allow us to collect and process information about your mobile device’s GPS location (including the latitude, longitude or altitude of your mobile device) and the time the location information was recorded to customize the Tapjoy-originated ads you view. It is the responsibility of the Publisher to obtain your consent prior to the Partner App enabling collecting of such location data – please refer to the Publisher’s privacy policy for more information. You can stop the collection of this data at any time by disabling the GPS or other location-tracking functions on your device either generally or for that Partner App, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
Information about ads you view. We collect some or all of the following information about the ads you view: (i) what the ad is about; (ii) the ad type (e.g., text, image, or video); (iii) where the ad is displayed within the Partner App; and (iv) certain information regarding what you do when interacting with or after viewing the ad (e.g., whether you proceed to purchase the product advertised). If the advertiser who created the ad (“Advertiser”) uses one of our advertising solutions that involves the voluntary collection of information from you as part of an ad (for example, an ad that contains an Advertiser questionnaire), and if we collect your voluntary responses, then your responses will be provided directly to the Advertiser will be governed by the Advertiser’s privacy policy.
Information from our partners. Our Publishers and other third-party partners may sometimes disclose to us information they have separately collected about you so that we can improve the relevance of the ads we serve on their behalf. They do this in accordance with their own privacy policies and subject to their own applicable legal requirements.
2. How We Use the Information We Collect via the Tapjoy Ad Platform
We use the information we collect through the Tapjoy Ad Platform, where and as permitted by applicable law, to:
Display interest-based advertising customized to individuals’ inferred interests, preferences and locations, and to analyze the effectiveness of the ads.
We use this information to provide filtering options for Publishers to manage ads appearing in their Partner Apps, and to provide targeting options for Advertisers.
For example, we use this information to avoid presenting you with ads that you have already seen, and to help our Advertiser clients to serve ads that are more likely to be of interest to you.
Track your interaction with ads and to ensure you receive any virtual awards you have earned via ad engagements.
Respond to your customer support inquiries and to facilitate accurate resolution of any customer support problems that may arise.
Perform analysis and research aimed at improving our services.
Display contextual advertising (advertising based upon the context of the App).
Manage frequency capping of displayed ads (so you don’t see the same ad multiple times), conversion tracking (so you can receive any reward earned by interacting with an ad), reporting, and security and fraud detection.
We keep this collected information as long as it remains necessary to provide the Tapjoy Services.
3. How We Share the Information We Collect via the Tapjoy Ad Platform
We share the information that we collect through our advertising platform in the following ways:
Publishers and Advertisers. We may share the information with our Publishers and Advertisers to aid in their understanding of how end users are using Partner Apps and engaging with ads
Service Providers. We may share your information with the service providers who perform services on our behalf, such as providers of analytics, payment processing, product fulfillment, technical infrastructure, data services, engineering and other technical support, and email and customer support. Under our agreements with our service providers, they can use this information only as needed to perform their services; they cannot use it for their own purposes. A list of service providers who may have access to information collected via our advertising platform can be found here: https://dev.tapjoy.com/faq/tapjoy-privacy-policy/privacy-third-party-vendors-list/.
Tapjoy Affiliates.We may share your information among Tapjoy affiliates (for purposes hereof, the term “affiliate” means an entity controlled by, controlling or under common control with Tapjoy) so that we can better provide advertising that is relevant to you. A current list of Tapjoy affiliates can be found here: https://dev.tapjoy.com/faq/tapjoy-privacy-policy/privacy-affiliates/.
Legal Purposes. We may share your information when we believe in good faith that such sharing is reasonably necessary in order to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process to the extent permissible by applicable laws. We may also share your information in situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or the Terms of Service; or to respond to the claims of violation of the rights of third parties and/or to protect the rights, property and safety of Tapjoy, our employees, users, or the public and obtaining your consent is difficult. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.
Business Transaction. We may share your information in connection with any merger, reorganization, a sale of some or all Tapjoy assets, or a financing or acquisition of all or a portion of our business by another company.
Consent. We may share your information in any circumstances where we have your consent.
Aggregated Data. We may aggregate, anonymize and/or de-identify information collected through the Ad Platform so that the information can no longer be associated with your specific device. As a result, our use and disclosure of aggregated and/or anonymized information is not restricted by this Privacy Policy, and it may be used and disclosed to others without limitation.
4. Opting Out of Tapjoy Interest-Based Advertising
As described above, we use the information we collect when you use our Partner Apps or visit our website for purposes including in order to serve you with interest-based ads based on your inferred interests, preferences and location.
If you prefer not to receive ads that are tailored to your interests, you can opt out of Tapjoy using your information to provide you interest-based ads at any time by going to the Tapjoy Opt-Out page: https://home.tapjoy.com/info/third-party-opt-out/. You can also usually opt out of the receipt of all in-app interest-based ads by using your device’s privacy settings. Each operating system (e.g., iOS, Android) provides its own instructions on how to prevent the delivery of such in-app ads. Please review the support materials and/or the privacy settings for your device’s operating system in order to opt-out of interest-based in-app ads. Please note that if you opt out of Tapjoy using your information for interest-based advertising you may still receive “generic” ads from us that are not based on your inferred interests.
5. Customer Support.
If while using one of our Partner Apps you recognize a problem with an integrated Tapjoy ad and notify us of the problem or otherwise contact us via email or with a question, we will ask for your email address or other contact information so that you can receive a response.
Tapjoy Web Services Privacy Practices
The Information We Collect via Tapjoy Web Services When you use Tapjoy Web Services, we collect different types of information from and about you based on which service you are using. Please do not use the Tapjoy Web Service(s) if you do not agree to the collection and use of your information as detailed below.
“Tapjoy Web Services” means, collectively: the MyTapjoy functionality (www.my.tapjoy.com), accessible both online and via the MyTapjoy application, that allows users to view advertisements in exchange for in-game currency rewards (collectively, “MyTapjoy”); the Tapjoy dashboard accounts used by Tapjoy Advertisers and Publishers to manage their use of Tapjoy’s products and services (“Dashboard”), and the Tapjoy corporate website that provides viewers with general information about Tapjoy and our products and services (the “Website”) ( www.tapjoy.com).
Information You Voluntarily Provide In Creation of MyTapjoy Accounts.
If you use MyTapjoy,
we collect information that you may provide voluntarily during your creation and use of your MyTapjoy account, such as your username, password and/or email
address.
Information You Voluntarily Provide In Creation of a Dashboard Account. If you use Tapjoy to create an Advertiser or Publisher Dashboard account, we collect information that you provide voluntarily during your creation and use of your Dashboard Account, which may include your name, the name of your company, your username and password, your email address, postal address, phone number, and payment information, as well as any required financial information such as your tax ID, VAT, or sales tax registration number or any other relevant tax number and credit card information.
Use of Dashboard and MyTapjoy Collected Information. We collect information from you that you voluntarily provide via your Dashboard account or your MyTapjoy account or that you allow us to access when you do certain things, such as when you:
Register to use the Dashboard or MyTapjoy
Edit your MyTapjoy or Dashboard profile
Contact us for customer support
Respond to a survey or register for a promotion
Participate in sweepstakes or contests
Request certain features (e.g., newsletters, updates, or other products)
Submit feedback to us.
Tapjoy Website and Social Media Channels. We may also collect user-generated content you post to the Tapjoy Website or Tapjoy social media channels, such as in a discussion board, blog, or other forum. You understand that we cannot control what other users do with any content (including without limitation images, ratings, captions, and comments) you voluntarily post. You should not post any sensitive personal data, such as details of your ethnicity, health or political preferences or photos of yourself to any Tapjoy board, blog, social media channel, or forum, nor should you allow other users to have access to your content if you do not wish them to make your content publicly available to be collected and used by others, or to be redistributed through the Internet and other media channels.
Information from You About Others. If we offer a referral option and you choose to use it to invite a friend to use Tapjoy, we will ask you for your friend’s email address. You must make sure you friend has consented before you provide us with your friend’s email address. We will automatically send your friend a one-time email inviting your friend to visit Tapjoy. We store this information only to send this one-time email to your friend and track the success of our referral program.
Additional Publisher or Advertiser Dashboard Users. We also provide registered Publishers or Advertisers with the option of adding users to their Publisher or Advertiser Dashboard accounts. When they do so we will collect the email address of the employee or other individual they wish to add. We will then send that individual a one-time email informing them they have been added. For individuals who are not employees of the Publisher or Advertiser, the Publisher or Advertiser must have their consent prior to providing us with their email address.
Information from Third Parties. We may collect, process and store your user ID associated with any social media account (such as your Facebook account) that you use to sign in to or otherwise connect with the Tapjoy Website or your MyTapjoy account via social media channels. If you connect your social media account with the Tapjoy Web Services (for example, by using your social media account information as login information), you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the information that you choose to make available to us through the social media interface. This could include, without limitation, any information that you have made public in connection with your social media account, information that the social media service shares with us, or information that is disclosed as being shared during the sign-in process. Please see your social media provider’s privacy policy and help center for more information about how they share information when you choose to connect your account.
Aggregated Data. We may aggregate, anonymize and/or de-identify information collected through the Tapjoy Web Services so that the information no longer relates to you individually. As a result, our use and disclosure of aggregated and/or de-identified information is not restricted by this Privacy Policy, and it may be used and disclosed to others without limitation.
Tapjoy’s Cookies and Related Tracking Technologies. When you use the Tapjoy Web Services, we may place and read cookies or access information on your device to obtain information about the performance of our site, enable you to move around the site, to record your preferences and to serve you with advertising that is relevant to your interests. This information may, where permitted by applicable law, then be combined with other information we hold about you. Information and technologies we may use include:
Device/Usage Information. When you interact with the Tapjoy Web Services, we may collect information such as (a) IP addresses, unique device identifiers (e.g. Google Advertising ID (GAID), Android ID, ID for Advertisers (IDFA), ID for Vendors (IDFV), MAC address, International Mobile Equipment Identity (IMEI), or other device IDs), and other information about your device(s), browser types, browser language, operating system, the state or country from which you accessed the services; and (b) information related to the ways in which you interact with the Tapjoy Web Services, such as: referring and exit pages and URLs, platform type, the number of clicks, internal Tapjoy subdomain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the services, error logs, and other similar information. As described in “Third Party Online Analytics and Tailored Advertising” below, we may use third party analytics providers and technologies, including cookies and similar tools, to assist us in understanding how the Tapjoy Web Services are used.
Location Information. We may make ad offers available to you that ask you for, access, or track geo-location-based information from your mobile device while downloading or using the MyTapjoy mobile app or functionality. If you choose to engage with these ad offers, we will receive certain information about your location, which may include country, state, city, or more specific location information, in order to provide you with the requested ad-related services including geographically relevant features, offers, applications, and application recommendations.
Cookies and other technologies. When you use the Tapjoy Web Services, we use persistent and session cookies and other similar technologies to perform various tasks including to: (a) store your MyTapjoy account or Dashboard account username and password; (b) analyze the usage of our Web Services; (c) customize the Tapjoy Web Services to your preferences; and (d) display advertising. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/. Most browsers automatically accept cookies, but you can modify your browser settings to decline cookies by visiting your browser’s help page. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some features of the Tapjoy Web Services. By using the Tapjoy Web Services with your browser set to accept cookies you are consenting to our use of cookies in the manner described above.
In addition to cookies, we and/or our third-party advertising partners may use a technology called clear gifs (a.k.a. Web Beacons/Web Bugs) that help us better manage and analyze content. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages. Where permissible under applicable law, we may also include Web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics purposes.
2. Third Party Online Analytics and Tailored Advertising
Online Analytics.To help us better understand your use of the Tapjoy Web Services, we may use third-party web analytics providers, such as Google Analytics. These service providers use the sort of technology described in the “Tapjoy’s Cookies and Related Tracking Technologies” Section above. The information collected by this technology will be disclosed to or collected directly by these service providers, who use the information to evaluate users’ use of the websites. To prevent Google Analytics from collecting or using your information, you may install the Google Analytics Opt-Out Browser Add-on.
Tailored Advertising.Third parties whose products or services ar e accessible or advertised via the Tapjoy Web Services may also use cookies or similar technologies to collect information to help them (i) inform, optimize, and serve ads based on past visits to the Tapjoy Web Services and other services and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Tapjoy Web Services. We also allow other third parties (e.g., ad networks and ad servers) to serve interest-based ads to you, and to access their own cookies or similar technologies on your computer or other device you use to access the Tapjoy Web Services. We neither have access to, nor does this Privacy Policy govern, the use of tracking technologies that may be placed by non-affiliates, third party ad technologies, or any other non-affiliated third parties. Those parties may permit you to opt out of ad targeting as described below. You may receive interest-based advertising on your computer through a web browser. If you are interested in more information about interest-based browser advertising and how you can generally control cookies from being put on your computer to deliver such advertising (i.e., not just for the Tapjoy Web Services), you may visit the Network Advertising Initiative’s Consumer Opt-Out Link, or the Digital Advertising Alliance’s Consumer Opt-Out Link. Please note that to the extent advertising technology is integrated into the Tapjoy Web Services, you may still receive ads even if you opt-out of interest-based advertising. In that case, the ads will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
When using MyTapjoy or other you may also receive interest-based in-app ads. Each operating system (e.g., iOS, Android) provides its own instructions on how to prevent the delivery of such in-application ads. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of interest-based in-app ads. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or operating system or contact the applicable platform operator.
3. How We Use the Information We Collect via the Tapjoy Web Services
We use the information we collect from and about you through the Tapjoy Web Services to:
Provide the Tapjoy Web Services
Manage your MyTapjoy, Publisher, or Advertiser account
Communicate with you, including responding to your inquiries, informing you about products and services based on with your marketing preferences, and notifying you of new features
Fulfill your requests for products and services and conduct business with you (e.g. reporting and payment)
Generate reports about our user base and service usage patterns, analyze the accuracy, effectiveness, and popularity of the service
Improve our content and features and personalize the content and advertising you see
Tapjoy retains the collected information for so long as we continue to provide the Tapjoy Services.
4. How We Share the Information We Collect via the Tapjoy Web Services
We will share the information we collect through the Tapjoy Web Services only in the ways that are described in this Privacy Policy. We may share your information in the following ways:
Service Providers. We may share your information with a variety of service providers who perform services on our behalf. Unless we tell you otherwise, service providers are only permitted to use your information on our behalf and cannot use it for their own purposes. These service providers include analytics providers, advertisers, payment processors, product fulfillment providers, providers of technical infrastructure, engineers or other technical support, email providers, and customer support vendors. A list of our service providers can be found here: https://dev.tapjoy.com/faq/tapjoy-privacy-policy/privacy-third-party-vendors-list/.
Tapjoy Affiliates. We may share your information among Tapjoy Affiliates so that we can better provide advertising that is relevant to you as well as generally to provide the services as applicable.
Legal Purposes. We may share your information when we believe in good faith that such sharing is reasonably necessary in order to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process to the extent permissible by applicable laws. We may also share your information in situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or the Terms of Service; or to respond to the claims of violation of the rights of third parties and/or to protect the rights, property and safety of Tapjoy, our employees, users, or the public and obtaining your consent is difficult. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.
Business Transaction. We may share your information in connection with any merger, reorganization, a sale of some or all Tapjoy assets, or a financing or acquisition of all or a portion of our business by another company.
Consent. We may share your information in any other circumstances where we have your consent.
5. Your Choices.
You have a number of choices as you use the Tapjoy Web Services:
Commercial Marketing. We will comply with applicable marketing laws in your country. Where under applicable law we may only send you email marketing with your prior consent, Tapjoy will only send you marketing if you have opted in. By clicking our Privacy Policy when registering, you consent to our sending you email marketing. If you wish to opt out of receiving email or other commercial communications from us, please indicate your preference in your profile, by emailing us at privacy@tapjoy.com, or by following the unsubscribe options contained in commercial messages you receive from us. Please note that it may take some time for us to process your request, consistent with applicable law.
Publisher and Advertiser Accounts. If your name has been added to a Publisher or Advertiser account and you wish to no longer have your email address used you may contact us at privacy@tapjoy.com.
Account Deactivation. You may request deactivation of your Dashboard account or your MyTapjoy account by sending an e-mail to privacy@tapjoy.com. Please note that some information may remain in our private records after deactivation of your account. We may use any aggregated data derived from or incorporating your personal information after your account is deactivated, but not in a manner that would identify you personally.
III. Tapjoy General Privacy Practices
1. How We Secure Your Information
We have put in place physical, electronic, and managerial procedures designed to safeguard, and to help prevent unauthorized access to, your information and to maintain data security. These safeguards take into account the sensitivity of the information that we collect, process and store and the current state of technology. Although we take appropriate measures to safeguard against unauthorized disclosures of information, the Internet and the services are not 100% secure so we cannot assure you that information we collect or store will be protected from all unauthorized access.
2. International Users
If you are located outside the United States and choose to use our services, engage with ads served by Tapjoy, and/or provide information to us, your information is provided to Tapjoy in the United States, and may be and processed and stored in the United States and otherwise outside of your country of residence, by Tapjoy and by third parties with whom we share in accordance with this Privacy Policy. By using the services, you consent to the export of your information outside of your country of residence.
3. Children
Tapjoy does not knowingly collect or solicit personal information from children under the age of 13, and we do not knowingly allow such persons to use our services. If you are under 13, please do not attempt to register for MyTapjoy or any other Tapjoy service or send any information about yourself to us. In the event that we learn that we have collected personal information from a child under age 13 without verified parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at privacy@tapjoy.com.
4. Changes to Our Privacy Policy
We reserve the right to amend this Privacy Policy from time to time to reflect changes in the law, our data collection and use practices, the features of our services, or advances in technology. Please check this page periodically for changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is used. Please review the changes carefully. Your continued use of our services following the posting of changes to this Privacy Policy will mean you consent to and accept those changes.
5. Links to Third Party Sites and Services
Our services may contain links to third-party websites, including social media services. Your use of these features may result in the collection, processing or sharing of information about you, depending on the feature. Please be aware that we are not responsible for the content or privacy practices of other websites or services that may be linked on our services. We do not endorse or make any representations about third-party websites or services. The information you choose to provide to or that is collected by these third parties is not covered by our Privacy Policy. We strongly encourage you to read such third parties’ privacy policies.
6. Do Not Track Requests
Many browsers and devices allow the user to limit tracking by enabling a preference called “Do Not Track.” Tapjoy recognizes such preferences, and responds to them when they are enabled in a device or browser by providing generic advertising offers only, rather than using collected data to provide targeted advertising offers.
7. Notice to California Users
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. As explained above, Tapjoy does not sell or share your personal information with third parties for their own marketing purposes.
8. Accessing and Deleting Your Information.
You may, under applicable law, have the right to access, correct, update or delete the personal information Tapjoy holds about you. In order to exercise your rights, to the extent permitted and required of Tapjoy under applicable law, please contact us at privacy@tapjoy.com.
If you have a MyTapjoy account or a Publisher or Advertiser Dashboard account , you may, through your account settings, access and, in some cases, change or delete your username and password, email address, and user profile information that you have previously entered. The information you can view and update through your account settings may change as the Tapjoy Web Services change. You may also request to access or remove personal information we have about you by emailing us at privacy@tapjoy.com.
In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
9. Contact Us
If you have any questions or concerns regarding our privacy policies, please send us a message to privacy@tapjoy.com, mail us at Tapjoy, Inc., 111 Sutter Street, 12th Floor, San Francisco, CA 94104, U.S., Attn: Privacy, or call us at +1 415-766-6900.
Tapjoy Privacy Policy updated June 30, 2015.
One Signal
OneSignal Privacy Policy
Last Updated: May 2, 2018
OneSignal., a U.S. company located at 2194 Esperanca Avenue, Santa Clara, CA 95054 (“OneSignal” “we,” “us,” and “our”), provides this privacy policy because we believe that consumers should have clear and comprehensive ways to understand how information about them is collected and used – both to provide our services and for third party advertising purposes. We’ve tried to write this policy in a way that is easy for consumers to understand at a “high level,” while still providing detail to allow sophisticated users (and privacy advocates) to understand what data models we’re engaged in, and more generally, how interest-based advertising works.
We’ve also provided a section about the choices that you have with respect to “interest based advertising,”, and we encourage you to read that section and exercise your “opt out” rights if you’re inclined to do that. (But because interest based advertising leads to more relevant (and thus, less annoying) advertising, we hope you won’t do that.)
Introduction and Background
OneSignal’s provides SDKs to mobile app developers and websites, and data and analytics services to other data partners and advertisers. These web and mobile SDKs permit app developers and websites to send, manage, optimize and customize push notifications to their users. All of these services (further described in this privacy policy) are referred to collectively as our “Services,” and all of these developers, website operators, partners and advertisers are referred to collectively as our “Clients.”
This privacy policy (the “Privacy Policy”) explains how we may collect, use, store, and disclose information about the end users (“End Users”) of third-party mobile applications and websites that use our Services. We also collect information on our corporate website(s), including any website on which this Privacy Policy is posted. We separately describe how we collect, use and share that website information (“OneSignal Website Information”) in Section 4, below.
We encourage consumers to learn about how information (including information we collect) can be used to market to them, and how to exercise their choices to permit or, if they prefer, to limit such marketing. We describe some ways consumers can exercise that choice or opt out of marketing in Section 6, below, titled Consumer Control & Opt Out Options.
Our SDKs: Information We Collect and Services We Provide
We refer to the information we collect from our SDKs as the ‘SDK Information.” The SDK Information includes (or may include) the following:
Information Collected About End Users by Our Web SDKs
Web pages visited that have implemented the SDK , and information about those visits (e.g., session duration, time-stamp, referring URLs)
What push notifications an End User has been sent
Information about End User’s transactions and interactions with apps and websites
IP address, from which geographic location may be inferred, as well as system configuration information
Email address which we may (in our discretion) hash or otherwise deidentify
Information about an End User’s browser, such as, browser language type and version of operating system (e.g., Android, iOS); network provider; language setting; time zone
A unique cookie identifier, which may uniquely identify an End User (such as in de-identified or anonymous form). These cookies may be associated with other Information, including with Data Segments, which we describe in Section 3.
Information Collected About End Users by Our Mobile SDKs
When permitted by the operating system, OneSignal may check to see if the device has specific applications installed, based on a limited list, for purposes that include attribution, relevancy of ads, and relevancy of notifications related to those applications.
Purchases made within an app.
Information about End User’s transactions and interactions with apps and websites
Mobile advertising identifiers, such as iOS IDFAs and Android Advertising IDs (“Mobile IDs”). These Mobile IDs may be associated with other Information, including with Data Segments.
Precise Location information, generally an End User’s lat/long data (i.e., GPS-level data) or WiFi information, which we may associate with Mobile IDs, and which may be collected whether or not an app is in use.
Email address, which we may (in our discretion) hash or otherwise deidentify.
IP address as well as system configuration information
Information associated with or related to devices, such as device type (e.g., mobile, tablet); type and version of operating system (e.g., Android, iOS); network provider; mobile browser (e.g. Safari, Chrome, etc.); language setting; time zone; and network status type (such as WiFi).
As noted above, we refer to all of the above collectively as the “SDK Information.”
How We Use the SDK Information
We use the SDK Information to provide a variety of Services to our Clients. This includes:
To Provide Our App and Website Services. We use the SDK Information to offer and support app and website features provided through the SDKs, including those related to push notifications. This includes, for instance, providing customer, technical and operational support for these features, detecting and protecting against errors, fraud, or other criminal activity; resolving disputes and enforcing our EULA and other rights we may have. It also includes analyzing, customizing, and improving the features we offer Clients.
To provide information and analytics to our Clients about the use of these app and website features provided through the SDKs, or to help app developers and website operators create or enhance user profiles.
To create inferences about End Users categorized into “Data Segments” or to help Clients do so. For instance, if SDK Information indicates that a particular device is frequently seen at restaurants, we might categorize a user for targeting of local restaurant offers. Or, if a user is frequently seen at sports stadiums, we might categorize the user as a “Sports Fan.”
To develop and use “predictive models” – data models that try to predict End Users’ potential future behavior and interests on a per-device basis or across devices
To analyze ad performance, for instance, by attributing End Users’ app installations, web visits, or store visits to ad campaigns.
Sometimes, the SDK Information may be used (by us or ad and data platforms we work with) to resolve identities across multiple devices, such as to match IP addresses or hashed emails to link an End User across (for instance) browsers, mobile devices, tablets, set top boxes, or other devices.
Sometimes the SDK Information may be combined (by us or ad and data platforms we work with), to perform any of the above functions, or other advertising, marketing or analytics services. Or, we may aggregate and create data “models” to do this – creating algorithms in order to predict certain trends and things that different End Users might have in common, for instance.
We may provide End Users’ email addresses (which we generally “hash” or render non-human readable) to online data platforms that “match” this information to online cookies or Mobile IDs in their system, and tie the information (or associated IDs) to further interest-based or demographic data about End Users. This may be done, for instance, to target advertising or provide analytics to brands and other companies.
We, or ad and data platforms we work with, may deploy online cookies to track users across websites, or to associate users (and these cookies) with Mobile IDs. We or they may do this to resolve user identifies across platforms, and to better or more accurately target relevant ads to users (such as to a brand’s customers). You can learn more about cookies and similar technologies, such as web beacons and SDKs, in the Section titled “Cookies, Pixel Tags and SDKs.” We may also “append” or combine certain SDK Information (such as hashed email addresses) to other information provided by third party data providers, to learn more about End Users or to provide advertising and analytics services.
How and Why We Share the SDK Information. To Provide Services to Websites and Apps Using the SDKs
We share the SDK Information with service providers, contractors and other companies to fulfill your orders, operate our business, communicate with you and make available our Services and this Website. These service providers may help us perform any of the activities set forth in Section 2. For instance, we may share certain of the information we collect or receive with companies that help us with billing and payment, marketing, advertising and email marketing,
data enhancement (e.g., to provide more relevant offers), website hosting, technology and customer support, web and marketing analytics, anti-fraud or security operations, and other operational, marketing or business support.
We likewise may share the SDK Information or Data Segments we create with website operators and app developers (for instance, related to push notifications they send) for their advertising, analytics, or other purposes.
To Provide Services to Marketers, Advertisers and Platforms They Work With
We also share SDK Information to provide or help us to provide advertising and marketing services as we have described in Section 3, including as follows:
With advertisers and their marketing providers, so they may provide targeted content and advertising to you on websites and mobile applications With other third parties that target advertising. For those familiar with the online ad ecosystem, these may include demand-side and supply-side advertising platforms, data management platforms, advertising agency trading desks, proximity solution providers, and other advertising technology providers, so they may provide targeted content and advertising to End Users and others on third-party websites, mobile applications, and other advertising mediums (email, direct mail, display media), and so that they may measure the effectiveness of this marketing.
Similarly, we may work with service providers who, to enhance consumer privacy, use a non-human readable “hashed” version of Information such as an email address when sending advertising offers by email or display advertising (which may be linked to a cookie as described above).
Sometimes we provide information (such as IP address, but excluding precise lat/long coordinates) to third party platforms to help advertisers identify common users across different devices or browsers – for instance, to identify a
The processes we’ve described above often involves cookies or similar technologies, which may be associated with other information about you, e.g., your interests, demographics or transactions. This is known generally as “Interest-Based Advertising.” We encourage users who are interested in controlling or learning about this type of “interest-based advertising” to go to Section 6, titled “Consumer Control & Opt-Out Options, or go to this this page operated by the online ad industry trade association.
We may also share the SDK Information with third parties:
If an End User or Client requests or authorizes
If the information is provided to: (1) comply in good faith with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas; (2) enforce our Terms of Use or other agreements; or (3) protect our rights, property, or safety or the rights, property, or safety of our users or any other person or entity
If the disclosure is done as part of, including as part of due diligence for, a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, any information we have may be one of the transferred assets) or in the event of bankruptcy
Even when you no longer access the SDKs, we may continue to use and share your Information as described in this Privacy Policy.
How we Use and Share Information Collected on the OneSignal Website(s)
Website Information We Collect
We collect the following information from visitors to our websites (the “OneSignal Website Information”, including the website on which this Privacy Policy appears (“OneSignal Website(s)”):
Volunteered: You may share information with us on the OneSignal Websites when you request information from us, fill out a form on our website, or interact with us in other ways. This information may include personal information, such as your name, email address, and other contact information.
Passively Collected (e.g., Cookies and Unique IDs): We use automated mechanisms, such as cookies, pixels, and other locally stored objects (such as “IndexedDB)”) that we associate with unique identifiers in order to keep track of visitor interactions with the OneSignal Websites. (You can learn more about these technologies below in the Section titled “Cookies, Pixel Tags and SDKs”)). We may use third party-services such as Google Analytics, in which case those third parties gather information such as your IP address, browser type, the webpage from which you came to our website, and the times of your access to the OneSignal Website. In addition, as you browse our website, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our display advertising partners may then help us retarget ads to you on other sites based on your interactions with the OneSignal Website. To “opt out” of having your information used to tailor ads to you in this way by third party ad platforms that we may work with or provide data to, please review the Section below titled “Consumer Control and Opt Out Options” to learn how to opt-out of these services and instead receive generic, non-tailored ads.
How We Use the OneSignal Website Information
In addition to the uses described above, we use the OneSignal Website Information (alone or in combination) to provide, market, and operate the OneSignal Websites and Services. Among other things, by collecting the OneSignal Website Information, we are able to
Maintain and offer access to the OneSignal Websites and Services and optimize how they’re offered to our Clients.
Send information about our products and services, including marketing communications.
Respond to your questions, concerns, or customer service inquiries.
Customize the content and advertising you see on the OneSignal Websites, across the Internet, and elsewhere.
How We Share the OneSignal Website Information
We may share the OneSignal Website Information as follows:
As part of a business sale, merger, consolidation, investment, change in control, transfer of substantial assets, reorganization or liquidation, or in connection with steps taken in anticipation of such an event (e.g., due diligence).
With our corporate affiliates.
With third parties that help us to provide the OneSignal Websites or Services, such as entities that help us make the OneSignal Websites or Services available and functional (such as hosting services); entities that help us make available or transmit any information we hold (such as helping us send emails, process payments, and manage customer information); and entities that help us (including our contractors, agents, and affiliates) provide technical, customer, billing, administrative, event planning, marketing or operational services to us or our Clients.
When required by law or in response to lawful process, such as a subpoena, or to cooperate in good faith with a request from a government or law enforcement agency or official.
If we believe sharing the information may prevent physical, financial or other harm, injury or loss; or we believe is necessary to protect our, or any other person’s or entity’s, interests; or in connection with an investigation of suspected or actual unlawful activity.
We also may disclose your information under circumstances not mentioned here with your prior consent.
Cookies, Pixel Tags and SDKs
Cookies and Pixel Tags. Cookies are small data files containing a string of characters, such as an anonymous unique browser identifier. Cookies are stored on your computer or other device and act as unique tags that identify your device or browser. Our servers may send your device a cookie when you visit the OneSignal Websites, and our Clients and Partners may do likewise on our Websites, our Clients’ websites, and elsewhere. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages on which a pixel tag is deployed, the pixel tag may generate a generic notice of the visit and permit OneSignal, our Clients or Partners to set or read cookies. Pixel tags are used in combination with cookies to anonymously track the activity on a website by a particular browser on a particular device. If you disable cookies, pixel tags simply detect an anonymous website visit. OneSignal, alone or with our Clients and Partners, may use cookies to, among other things, “remember” you (e.g., when you visit the OneSignal Websites or the websites of our Clients or Partners), track trends, and collect information about how you use our Clients’ or Partners’ websites or interact with advertising. We and partners we work with use cookies to provide relevant content to you and replace non-relevant ads with ads that better match your interests. We may sometimes use other locally stored objects in ways similar to how we use cookies. Often, these objects are deleted when you clear your browser cookie cache, but because this may not always occur (depending on the browser you use), we recommend that if you wish to opt out of notification features or third party interestbased advertising you instead follow the steps we have set forth in Section 6 titled “Consumer Control & Opt-Out Options.”
Mobile Device Identifiers and SDKs. We may use or work with partners who use mobile SDKs (including our own SDKs, which are described in more detail in this Policy) to collect information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), and information related to how mobile devices and their users interact with our Services and those using our Services. The SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services to be implemented. We may use this technology, for instance, to analyze or measure certain advertising through mobile applications and browsers based on information associated with your mobile device. If you would like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions in the below Section titled “Consumer Control and Opt-Out Options.”
As described in Section 4 our Clients or Partners may use the above technologies (sometimes, in combination with each other or other data such as IP addresses or hashed or de-identified data files) to coordinate identifiers across platforms, browsers or devices, to more efficiently analyze or target advertising.
Consumer Control & Opt-Out Options.
In most cases, consumers have control over whether or not they would like to receive relevant advertisements and marketing email from our Clients.
Opting Out of OneSignal Push Notifications
You may in most cases opt out of receiving push notifications by going to your device “Settings” and clicking on “Notifications,” and then changing those settings for some or all of the apps on your device. (Different device configurations, or updates to devices, may affect or change how these settings work.)
Your choice to opt out of “Notifications” from the OneSignal platform will not affect ads placed by any other organization.
Opting Out of Online Interest-Based Advertising You can opt out of many of the platforms and service providers that facilitate online interest-based advertising by visiting the Digital Advertising Alliance’s consumer education and opt-out page, at http://www.aboutads.info/. This type of opt out is cookie based, which means that if you replace or upgrade your browser, or delete your cookies, you will need to opt out again. Opting out in this way will not prevent you from receiving ads – it will just make the ads you see less customized to you.
Opting Out of “Cross-App” Advertising on Mobile Devices
You can opt out of having your mobile advertising identifiers used for certain types of interest-based (also called “cross-app”) mobile behavioral advertising, by accessing the “settings” on your Apple or Android mobile device, as follows:
Apple Devices: If you have an Apple device, you can opt out of most app-based tracking for interest-based advertising by setting Limit Ad Tracking to ‘ON.’ You can do this by clicking on Settings -> Privacy -> Advertising and toggling Limit Ad Tracking to ‘ON.’
Android Devices: If you have an Android device, you can opt out of most app-based tracking for interest-based advertising by opening the Google Settings app on your device, selecting Ads, and then selecting the option to opt-out of interest-based ads.
Please note that these platforms control how these settings work, so the above may change. Likewise, if your device uses other platforms not described above, you should check the settings for those devices.
Additional Choices
Advertisers may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the privacy policies for retailers, applications and websites to learn more about their privacy practices.
You may opt not to receive promotional emails from us by contacting us as indicated below or by following the “unsubscribe” instructions in any promotional email you receive from us. Please note, however, that we may still send you non-promotional emails about your relationship with us.
Data Access and Retention
Generally speaking, we retain the SDK Information and Website Information for as long as necessary to achieve our objectives as detailed in this Privacy Policy, and to comply with our legal obligations, resolve disputes and enforce our agreements.
Data Security
We have administrative, technical, and physical safeguards in place in our physical facilities and in our computer systems, databases, and communications networks that are designed to protect information contained within our systems from loss, misuse, or alteration. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information and Non-Personal Information.
Third Party Websites and Apps
We are not responsible for the privacy practices or disclosures of websites and applications that use our Services. Likewise, when you access the OneSignal Website, you may be directed to other websites that are also beyond our control. We encourage you to read the applicable privacy policies and terms and conditions of such third parties and websites, and the industry tools that we have referenced in this Privacy Policy. This Privacy Policy, however, only applies to the OneSignal Site and the Services.
Users From Outside the United States
The Website and our Services are provided, supported and hosted in the United States, and our operation of them is governed by United States law. If you are using the Site from outside the United States, be aware that your Information may be transferred to, stored and processed in the United States and other countries where our facilities are located. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using the Site you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Policy.
Contacting Us
If you have any questions regarding this Privacy Policy, please contact us at privacy@OneSignal.com.
Changes to This Privacy Policy
If we make material changes to our privacy policy that may impact you, we will prominently post notice of the change on our website for a period of at least 30 days prior to the change becoming effective. We recommend that you check the Privacy Policy frequently so that you are informed of any changes.
Playfab
Facebook
Our games optionally allow users to link their Facebook profile to the game. In these cases, we only access your basic account information, such as name, to display in the game. When you log in to Facebook, we also link your Facebook account to your Playfab Game account so that game data can be easily recovered.
If you wish to unlink your Facebook account from your Playfab Game account please contact us at support@narcade.com
Game Data Storage
Your game inventory data might be stored on PlayFab's cloud servers, which we use to recover you when you play our games on multiple devices. If you would like to permanently delete this stored game data, please contact us at support@narcade.com
Microsoft Azure PlayFab
To implement the game service, we use the backend system "PlayFab" via the Microsoft Azure platform. This framework is provided to us by Microsoft Ireland (see point 6).
The Games are hosted on the Microsoft Azure platform, which means that your data processed in this context is stored on Microsoft Ireland servers. Microsoft Ireland has implemented several data security features and allows customers to further enhance the protection of user data. We therefore strive to achieve the best possible protection of your data while still providing you with a great experience.
We use PlayFab and Microsoft Azure for the purpose of being able to fulfil the contract you entered into with us when you registered to play the games offered (Art. 6(1)(b) GDPR). Without the framework of PlayFab and Microsoft Azure, we would not be able to offer you our service. Any additional analysis of game data and player behaviour when launching and playing our games is performed for the purpose of evaluating the use of our services in order to obtain feedback on the acceptance and effectiveness of our offerings - this enables us to continuously improve our services as well as our marketing approach; such analysis is based on our legitimate interest in collecting the relevant data we need to maintain and improve the quality of our services (Art. 6 (1) list of GDPR; for the right to object, see item 7).
Outsourcing of processing activities by Microsoft Ireland to third parties, such as affiliates, may occur, which may result in processing of your data in the United States, specifically by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Any transfer of your data in this context to the jurisdiction of these third parties will, unless there is an adequacy decision by the European Commission within the meaning of Art. 45 DSGVO, take place on the basis of standard data protection clauses within the meaning of Art. 46 (2) lit. c DSGVO issued by the European Commission.
Please also review the Microsoft privacy statement for information in greater detail on how data protection is handled: https://privacy.microsoft.com/en-us/privacystatement.
The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use Bubble Friends only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use Bubble Friends.
Contact information
Owner and Data Controller
COMPANY: NARCADE TEKNOLOJI LTD.STI., ADDRESS: HACIMIMI MAHALLESI DIBEK SOKAK NO:15 D:7 BEYOGLU/ISTANBUL TURKEY
Owner contact email: zip@nar.club
Full policy
Owner and Data Controller
COMPANY: NARCADE TEKNOLOJI LTD.STI., ADDRESS: HACIMIMI MAHALLESI DIBEK SOKAK NO:15 D:7 BEYOGLU/ISTANBUL TURKEY
Owner contact email: zip@nar.club
Types of Data collected
Among the types of Personal Data that Bubble Friends collects, by itself or through third parties, there are: Cookies, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), Storage permission, email address and various types of Data.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Bubble Friends.
Unless specified otherwise, all Data requested by Bubble Friends is mandatory and failure to provide this Data may make it impossible for Bubble Friends to provide its services. In cases where Bubble Friends specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Bubble Friends or by the owners of third-party services used by Bubble Friends serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through Bubble Friends and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Bubble Friends (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Access to third-party accounts, Advertising, Analytics, Device permissions for Personal Data access, Managing support and contact requests, Registration and authentication, Remarketing and behavioral targeting and Social features.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Facebook permissions asked by Bubble Friends
Bubble Friends may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows Bubble Friends to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
Basic information
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
About Me
Provides access to the 'About Me' section of the profile.
Access Friend Lists
Provides access to any friend lists the User created.
Birthday
Provides access to the birthday.
Photos
Provides access to the photos the User has uploaded, and photos the User has been tagged in.
Device permissions for Personal Data access
Depending on the User's specific device, Bubble Friends may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of Bubble Friends.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Bubble Friends.
Storage permission
Used for accessing shared external storage, including the reading and adding of any items.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Access to third-party accounts
This type of service allows Bubble Friends to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Facebook account access (Bubble Friends)
This service allows Bubble Friends to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: About Me, Access Friend Lists, Birthday and Photos.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Advertising
This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on Bubble Friends, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Bubble Friends. For more information, please check the privacy policies of the relevant services.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.
AdMob (AdMob Google Inc.)
AdMob is an advertising service provided by AdMob Google Inc.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
AppLovin (AppLovin Corporation)
AppLovin is an advertising service provided by AppLovin Corporation.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
AdColony (Jirbo, Inc.)
AdColony is an advertising service provided by Jirbo, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Chartboost (Chartboost, Inc.)
Chartboost is an advertising service provided by Chartboost Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
Unity Ads (Unity Technologies ApS)
Unity Ads is an advertising service provided by Unity Technologies ApS.
Personal Data collected: Cookies and Usage Data.
Place of processing: Denmark – Privacy Policy.
Vungle (Vungle, Inc.)
Vungle is an advertising service provided by Vungle, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
Facebook Audience Network (Facebook, Inc.)
Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.
Bubble Friends may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.
Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.
Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Adjust
Adjust GmbH, adjust Inc. and adjust KK (collectively, “adjust” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. With this privacy policy, We would like to inform you how we process your personal data whilst using this website. The responsible body according to art. 4 European General Data Protection Regulation (“GDPR”) is Adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin, managing directors are Christian Henschel and Paul Müller. In case of any questions relating to data protection, please get in touch with us at privacy@adjust.com or contact our Data Protection Officer Prof. Dr. Christoph Bauer directly at Große Bleichen 21, 20354 Hamburg, Germany or via e-mail at c.bauer@eprivacy.eu. This policy describes the types of information we may collect from you or that you may provide when you visit the website www.adjust.com (our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information. This policy applies to information we collect: on this Website. in e-mail, text and other electronic messages between you and this Website. when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy. when using our Adjust Dashboard. It does not apply to information collected by: us offline or through any other means, including on any other website operated by adjust or any third party; or any third party, including through any application or content (including advertising) that may link to or be accessible from the Website. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 1. Collection and Use of Data on the Website Content Personal data is all information relating to personal and objective circumstances through which a person may be personally identified. This may for example entail information such as your name, address or other contact details such as phone number or e-mail address. Intended Use Legal basis for the processing of this personal data is Art. 6 para. 1 (f) GDPR, as this data is necessary for the following purposes: to present and improve our website. to estimate the size of our target group and their user pattern. to save information about your preferences so that we may adapt our website to your individual interests. to speed up your search. to recognize you when you return to our website. Furthermore, with this information we will be able to ensure the stability and security of our website. How We Use Your Information We use information that we collect about you or that you provide to us, including any personal information: To present our Website and its contents to you. To provide you with information, products or services that you request from us. To fulfill any other purpose for which you provide it. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. To notify you about changes to our Website or any products or services we offer or provide through it and to help us understand how the Website is being used. In any other way we may describe when you provide the information. For any other purpose with your consent. We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, you may elect to unsubscribe and we will cease using your information in that manner. Children Under the Age of 13 Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at Adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin, Germany, via email at privacy@adjust.com or per phone at +49 172 153 501 1. Information We Collect About You When You Visit Our Website We collect several types of information from and about users who visit our Website via internet connection or through your device which you use to access our website, including certain user details. Such information includes: traffic data, location, logs and communication data, resources on our website which you access and use, IP address, operating system and browser type, and information which is collected through cookies, web-beacons and other tracking technologies. Furthermore, we are tracking data with which you may be personally identified such as your name, postal address, e-mail address, phone number and any other identifier with which you may be contacted online or offline (‘personal data’) insofar as you provide us with this data in our online form. The technologies we use for this automatic data collection may include: Cookies (or browser cookies). We, and businesses we work with, require for some features of our website. Cookies are small files that your browser places on your device in a designated directory. These cookies can be used to determine, for example, whether you have visited a website before. Most browsers accept cookies automatically. However, you can set your browser so that no cookies are stored or an explicit consent is required before saving a cookie. In addition, you can delete previously set cookies at any time. Please note that disabling cookies may result in restrictions when using our website. Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit adjust, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Log files. Every time you access our Internet pages, your usage data is transmitted through the respective internet browser and stored in log files, the so-called server log files. The records stored in this case contain the following data: domain and location from which the user is accessing the website Additionally, we can receive information from third parties, for example business partners. Information You Provide to Us The information we collect on or through our Website may include: Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to our newsletter, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Website or the adjust technology. Records and copies of your correspondence (including e-mail addresses), if you contact us. Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website. Details of Website searches and button clicks are also recorded. You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. Third-party Use of Cookies and Other Tracking Technologies Some third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information. Duration of Retention of Data We store your data: if you have consented to the processing at the latest until you revoke your consent, if we need the data to carry out a contract at most as long as the contractual relationship with you or statutory retention periods are running, if we use the data on the basis of a legitimate interest at most as long as your interest in deletion or anonymization does not prevail. Disclosure of Your Information We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy: To our subsidiaries and affiliates for the sole purpose of providing our services. To contractors, service providers and other third parties we use to support our business. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of adjust’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by adjust about our Website users is among the assets transferred. To fulfill the purpose for which you provide it. For any other purpose disclosed by us when you provide the information. With your consent. We may also disclose your personal information: To comply with any court order, law or legal process, including to respond to any government or regulatory request. To enforce or apply our terms of use and other agreements, including for billing and collection purposes. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of adjust, our customers or others. There is a transfer of data to third countries outside the European Union. This is done on the basis of statutory contractual provisions that are intended to ensure an adequate protection level of your data. Choices About How We Use and Disclose Your Information We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly. Opt-out. You may “opt out” of receiving marketing or promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website. How we protect Your Data We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All transactions, regardless of their nature, are encrypted using SSL technology. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. Transfer between subsidiaries: We may transfer user and customer information to our affiliates and to third party providers for the sole purpose of providing our services. Newsletter If you subscribe to our newsletter, we will process your e-mail address and data to verify your subscription. You can cancel your subscription at any time by sending a message to us or by clicking the ‘unsubscribe’ button. Your rights according to the GDPR As the data subject, you have the right of access (Art 15 GDPR), the right to rectification (Art 16 GDPR), the right to erasure of your personal data (Art 17 GDPR), the right to restriction of processing of your personal data (Art 18 GDPR) as well as the right to data portability (Art 20 GDPR). Furthermore, you have the option to file a complaint against the processing of your personal data with the competent supervisory authority (in this case Berliner Beauftragte für Datenschutz und Informationsfreiheit at https://www.datenschutz-berlin.de/). If you have given your consent to the processing of your data, you can revoke the given consent at any time. Such revocation affects the admissibility of the processing of your personal data after you make such revocation. You can object to the processing of your personal data insofar as we base the processing of your personal data on the balance of interests. This is the case in particular if the processing is not necessary for the fulfilment of a contractual obligation to you, which we in each case present in the description of the functions which follow. In case of such objection, we kindly ask for an explanation of the reasons for the objection against the processing of your personal data. In the case of your justified objection, we will examine the situation and will either discontinue or adapt the data processing or point out to you our compelling legitimate reasons based on which we continue the processing your personal data. You may, of course, object to the processing of your personal data for advertising and data analysis purposes at any time. In this case, please send an e-mail to privacy@adjust.com. Your California Privacy Rights California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to privacy@adjust.com or write us at: Adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin, Germany. Commitment to the EU-US Privacy Shield Adjust Inc. complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Adjust has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. In compliance with the Privacy Shield Principles, Adjust commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Adjust at: Adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin, Germany or by sending an email to privacy@adjust.com at any time. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. Adjust has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU. The Federal Trade Commission (FTC) has jurisdiction over our compliance with the Privacy Shield. Under certain conditions, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. 2. Tracking Technologies on our Website Google Analytics In order to optimize this website, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how you use this website. The information generated by the cookie about your use of this website (including your IP address) will be transmitted to and stored by Google on servers in the United States. If the IP anonymization is activated on this website, your IP address will previously be truncated by Google within the EU member states or EEA member states. Only in exceptional cases will the IP address be transferred to Google on a server in the United States and thereafter be truncated. On behalf of the website operator, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The IP address that was transmitted by your browser will not be combined by Google with any other data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You may also prevent the collection of the data that was generated by the cookie and that is related to the use of the website (including your IP address) as well as its processing by Google by downloading and installing a browser plugin that is available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de. Additional information thereto is available at http://www.google.com/intl/de/analytics/privacyoverview.html (general information to Google Analytics and privacy). This Website uses Google Analytics with its extension code “gat._anonymizeIp()“ so that IP addresses will therefore only be processed in a shortened form to prevent persons from being identified. Google AdWords We as a Google AdWords customer also use Google Conversion Tracking, a web analytics service provided by Google, Inc. (“Google”). Google AdWords places a cookie in your browser (“Conversion Cookie”) if you have accessed our website via a Google ad. These cookies are valid for 30 days. If you access some of our sites and the cookie is still valid, we and Google can recognize that somebody has clicked on the ad and thereafter was transferred to our website. Every AdWords customers uses a different cookie, and therefore it is not possible to track cookies via the websites of AdWords customers. The information obtained via the Conversion Cookie is used in order to assemble conversion reports for AdWords customers. The AdWords customers receive the number of users that have clicked on their ad and have been transferred to a site that includes the Conversion Tracking Tag but they do not receive any information that would allow them to identify the user. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. Facebook Pixel We use the “visitor action pixels” from Facebook Inc. on our website. This allows user behavior to be tracked after they have been redirected to our website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads in your account-settings. Facebook is certified under the US-EU Privacy Shield Agreement and thus guarantees compliance with European data protection legislation. LinkedIn Insight Tag The LinkedIn Insight Tag is a piece of lightweight JavaScript code that we have added to our websites to enable in-depth campaign reporting and to help us unlock valuable insights about our website visitors. We use the LinkedIn Insight Tag to track conversions, retarget website visitors, and unlock additional insights about members interacting with our LinkedIn adverts. The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamp, and events such as page views. All data is encrypted. The LinkedIn browser cookie is stored in a visitor's browser until they delete the cookie or the cookie expires. You can opt out of cookies from LinkedIn on your LinkedIn settings page and recommend you read their Cookie Policy for more information. Marketo Marketo Inc. is a marketing automation platform focused on account-based marketing, including e-mail, mobile devices, social media, digital ads, web management and analytics. O this platform, cookies are used in order to recognize you as a customer when you visit the website again; to track different data when using the website and to provide better content. The cookies placed by Marketo Inc. are read only by Marketo Inc. For more information about Marketo Cookies and Marketo's privacy policy, please click here. Pardot Pardot is a B2B marketing automation by Salesforce which we use to keep customers informed about upcoming events, product updates/ new features, etc. This marketing tool is embedded in our website for general marketing purposes, including e-mail, social media, digital ads, web management and analytics. For this marketing tool, we use cookies to identify you when you visit and re-visit our website. With this tool we track different data points when you are using our website in order to improve the website content we provide to you as well as to improve our marketing campaigns and make their content more relevant for you. For more information on Salesforce/ Pardot's privacy policy, click here. Bizible Bizible offers an integrated marketing analysis platform for marketers in order to optimize their advertising campaigns. Bizible collects your name, e-mail address and (if applicable) your address (only if you have explicitly provided us with this), as well as IP address, browser type and marketing source. You can do a Bizible Cookie-Opt-Out here. For more information, please klick here. Clearbit Clearbit is operated by APIHub Inc. Clearbit has developed a business intelligence API to aid businesses in acquiring more information about their clients in order to increase turnover and reduce fraud. Clearbit collects your IP address so that we may improve our website. For more information and to have yourself removed from the Clearbit database, please click here. Hotjar Hotjat Ltd. provides a service which analyses the online behavior of website users by combining analytics and feedback tools. Hotjar will collect and processe your IP address when you navigate through and interact with the contents of our website. The sole purpose for passively collecting this information is to improve your experience when using our website. You may opt-out from having Hotjar collect Your information when visiting our website at any time by visiting their Opt-out page and clicking 'Disable Hotjar'. VWO VWO is operated by Wingfify Software Private Limited. VWO is a test and optimization tool with which businesses can conduct A/B Tests and develop behavioral geological targeting campaigns. This helps us to optimize and personalize our website. For this, VWO collects your IP address when you visit our website. Your IP address, however, is anonymized instantly. For more information, please click here. If you no longer want VWO to track your IP address when you visit our website, please use this opt-out link. Drift Drift.com Inc. is a conversation-driven marketing platform. With its rapidly evolving tools, Drift unlocks the hidden insights to accelerate business success. Drift records the email address you enter in our forms. For more information on how drift data is collected and processed please click here. To unsubscribe from drift tracking, please email privacy@drift.com. Raygun Raygun is operated by Raygun Limited and is an online service providing us with error tracking and performance analytics for our Adjust Dashboard. The only data that is shared with Raygun is the IP address of a Dashboard user. This information is used to compute geographic performance metrics limited to only the country of origin, that we use to improve the quality of our service. Raygun does not share data with any other third party. If you would like to opt-out from our performance analysis and not to be tracked by Raygun please send a request to dashboard+raygun@adjust.com specifying the email address associated with your Adjust Dashboard user. 3. Processing of data through the Adjust Technology Adjust GmbH, Adjust Inc. and Adjust KK (collectively, “Adjust” or “We”) provide mobile analytics and attribution services to mobile app providers (our “Customers”). In connection with these services, we may process certain data from the users of these mobile apps (collectively the “End User” or “You”), as further described hereafter. We process the data upon instructions from our Customers and do not have any kind of direct relationship with the You as the End User. Customers who have child-directed apps must choose the appropriate product settings and must not share any personal data with Partners or any third parties. Customers must agree to the section in our Terms and Conditions accordingly. Our SDK and APIs (collectively the “adjust technology”) may process some of the following data from You as the End User: Anonymized (hashed) IP address Mobile identifiers such as the ID for Advertising for iOS (IDFA), Google Advertising ID or similar mobile identifiers Installation and first opening of an app on Your mobile device Your interactions within an app (e.g. in-app purchases, registration) Information regarding which advertisements You have seen or clicked on We use the aforementioned data for providing mobile analytics and attribution services to our Customers, and thereby allow our customers to track their marketing performance, to match You to their campaigns and to understand how You engage with our Customer’s app. Furthermore, we enable our Customers to track Your interactions in their apps in real time in order to see how You engage over their full lifetime. The aforementioned data is therefore processed in order to analyze the performance of marketing campaigns and to provide performance reports to our Customers. We do not combine the data with any other data that would enable us to personally identify You. Any information processed via the adjust technology is owned and controlled by our Customer who has implemented the adjust technology into their mobile app. We do not share or disclose the user data with anyone else except with our server providers and in response to lawful requests by public authorities, including national security or law enforcement requirements. We store the data as long as our Customers are using the adjust technology because we need it to provide our services to our Customers, if not requested otherwise by our Customers. In some cases, there is a transfer of data to third countries outside the European Union. This is done on the basis of statutory provisions that are intended to ensure an adequate level of protection for Your personal data. Changes to Our Privacy Policy It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our website and this privacy policy to check for any changes.
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Facebook Analytics for Apps (Facebook, Inc.)
Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Unity Analytics (Unity Technologies ApS)
Unity Analytics is an analytics service provided by Unity Technologies ApS.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: Denmark – Privacy Policy.
Appsflyer (AppsFlyer Ltd)
Appsflyer is an analytics service provided by AppsFlyer Ltd.
Personal Data collected: Cookies and Usage Data.
Place of processing: Israel – Privacy Policy – Opt Out.
Device permissions for Personal Data access
Bubble Friends requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (Bubble Friends)
Bubble Friends requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data collected: Storage permission.
Managing support and contact requests
This type of service allows Bubble Friends to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Zendesk (Zendesk, Inc.)
Zendesk is a support and contact request management service provided by Zendesk Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Registration and authentication
By registering or authenticating, Users allow Bubble Friends to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Bubble Friends will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Remarketing and behavioral targeting
This type of service allows Bubble Friends and its partners to inform, optimize and serve advertising based on past use of Bubble Friends by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Bubble Friends with the Facebook advertising network.
Personal Data collected: Cookies and email address.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Social features
Inviting and suggesting friends (Bubble Friends)
Bubble Friends may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.
Personal Data collected: various types of Data.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Cookie Policy
Bubble Friends uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Bubble Friends or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Bubble Friends may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Bubble Friends and any third-party services may collect files that record interaction with Bubble Friends (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
Bubble Friends does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Bubble Friends and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through Bubble Friends (or third-party services employed in Bubble Friends), which can include: the IP addresses or domain names of the computers utilized by the Users who use Bubble Friends, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using Bubble Friends who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Bubble Friends. The Data Controller, unless otherwise specified, is the Owner of Bubble Friends.
Bubble Friends (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Bubble Friends as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies
Small sets of data stored in the User's device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to Bubble Friends, if not stated otherwise within this document.
Latest update: December 14, 2018