1. Information we receive about end users (“End Users”) of third-party mobile applications (“apps”) that use our Software Development Kit (“SDK”), the AdView Ad Exchange (“AdView ADX”) (collectively, the “AdView Ad Services”), and
2. Information we receive through our website at https://www.adview.com or any other website on which this Policy is posted, as well as information we get through other corporate services and web portals, we make available to clients and business partners (“AdView Websites”). We describe the information received through the AdView Websites in Section 5 below, entitled “Privacy Practices for the AdView Websites.”
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 limit such marketing. We describe ways consumers can exercise that choice or opt out of marketing in Section 4 below, entitled “Consumer Control and Opt-Out Options.”
1. INTRODUCTION AND BACKGROUND
AdView provides mobile advertising technology services that facilitate transactions among advertisers, app developers, publishers of mobile apps, and ad exchanges (collectively, “Clients”), and service providers and other data partners (collectively “Partners”). We do this by making available the AdView Ad Services and other tools to Clients. Clients use the AdView Ad Services and other tools to deliver advertising to End Users, and we in turn provide our services to help Clients (and their own customers) to deliver ads that are of interest to End Users. We explain what SDKs are in Section 3 below, entitled “Pixel Tags, and SDKs,”.
2. PRIVACY PRACTICES FOR THE ADVIEW AD SERVICES
a. INFORMATION COLLECTED THROUGH THE ADVIEW AD SERVICES
Through the AdView Ad Services, we may (but do not necessarily, or always) collect a variety of information about End Users (whether through our SDK or through other partnerships and tools such as Client-facing APIs), including:
• IP addresses, from which geographic location may be inferred, as well as system configuration information such as information about End Users’ operating system;
• Precise geolocation information (generally an End User’s latitude and longitude data);
• Mobile advertising identifiers, such as iOS IDFAs and Android Advertising IDs (collectively, “Advertising IDs”). These Advertising IDs may be associated with other information we collect through the AdView Ad Services, from third parties, or through any other services we offer;
• Device type and other device information (e.g., whether you are using a smartphone or tablet, and related information);
• Network provider;
• Mobile browser (e.g., Firefox, Safari, and Chrome);
We may combine and merge the various types of information collected from the AdView Ad Services, and may also enhance it (or permit our Clients to enhance it) with information collected from third parties. We refer to all of the above information as the “Service Information.”
b. How We Use the Information Collected Through the AdView Ad Services
We use the Service Information to provide a variety of services to our Clients related to advertising and marketing, including services we may describe elsewhere on AdView Websites. This includes use of the Service Information for purposes such as to:
• Provide and improve the AdView Ad Services. This includes, for example, providing customer, technical, and operational support for these features, detecting and protecting against errors, fraud, or other criminal activity, and resolving disputes and enforcing our terms and conditions and other rights we may have. This may also include analyzing, customizing, and improving the features of the AdView Ad Services;
• Provide information and analytics to Clients about the use of app features provided through the AdView Ad Services, or help Clients create or enhance user profiles for marketing or analytics purposes;
• Create inferences about End Users categorized into “Audience Segments” or to help Clients do so. For example, if the information we collect indicates that an End User likes apps (or clicks on ads) about travel, we may categorize the End User of that device as someone who is interested in travel;
• Develop and use data models that try to predict End Users’ potential future behavior and interests on a per-device basis or across devices;
• Analyze ad performance, for example, by attributing End Users’ app installations or mobile web visits to ad campaigns;
• Combine the Service Information to perform (including by working with Clients and Partners) any of the above functions, or other advertising, marketing, or analytics services. Or, we may aggregate and create data models to do this, by creating algorithms in order to predict common interests among End Users. This may be done, for example, to target advertising or provide analytics to other parties.
c. How We Share Information We Collect Through the AdView Ad Services
Generally, we share the Service Information with Clients and Partners in order to provide the AdView Ad Services. For example, we share the Service Information with:
• Clients and their marketing and service providers, so they may provide targeted content and advertising to End Users on mobile apps;
• Other third parties that target advertising. This may include, for example, platforms that work directly with marketers (sometimes called demand-side platforms), analytics companies, data management platforms that help marketers maintain and use data, proximity solution providers, and other advertising technology providers. These companies may, for example, provide targeted content and advertising to End Users and others on third-party mobile apps or other advertising media (such as email, direct mail, and display media);
• Clients and their marketing and service providers, to help measure the effectiveness of marketing or analyze their End Users’ likely interests or demographics;
Even when you no longer access our SDK, we may continue to use and share your information as described in this Policy.
The processes we described above often involve cookies-similar technologies, which may be associated with other information about End Users, such as End Users’ interests, demographics, or transactions. This is generally known as “interest-based advertising.” We encourage individuals who are interested in controlling or learning about this type of advertising to go to Section 4 below, entitled “Consumer Control and Opt-Out Options,” or go to the Digital Advertising Alliance’s (DAA’s) website at www.aboutads.info.
We may also share Service Information with third parties:
• Pursuant to a request or authorization by an End User or Client;
• If the disclosure is provided to: (a) comply in good faith with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas, including for purposes of national security and law enforcement; (b) enforce our terms and conditions or other agreements; or (c) protect our, or any other person’s or entity’s, interests, rights, property, or safety, or in connection with an investigation of suspected or actual unlawful activity;
• Where the information is aggregated or de-identified; and
• As part of a business purchase, sale, merger, consolidation, investment, change in control, transfer of all or substantially all of our assets, reorganization or liquidation, bankruptcy, or in connection with steps taken in anticipation of such an event (e.g. due diligence).
a. Mobile Device Identifiers and SDKs
We, or our Clients or Partners, may use or work with mobile SDKs (including our own SDK(s), which are described in more detail in this Policy) to collect information, such as mobile identifiers (e.g., iOS IDFAs and Android Advertising IDs), and information related to how mobile devices and their users interact with our AdView Ad Services and those using our AdView Ad 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 example, to analyze or measure certain advertising through apps 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 Section 4 below, entitled “Consumer Control and Opt-Out Options.”
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, in order to more efficiently analyze or target advertising.
4. CONSUMER CONTROL AND OPT-OUT OPTIONS
In most cases, consumers have control over whether or not they would like to receive relevant ads and marketing email from our Clients.
a. Opting Out of Online Interest-Based Advertising
You can opt out of many of the platforms and service providers we work with that support online interest-based advertising by visiting the Digital Advertising Alliance’s consumer education and opt-out page at http://www.aboutads.info (or the European Interactive Digital Advertising Alliance’s opt-out page at http://www.youronlinechoices.eu if you are located in the European Union). 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; rather, the ads you see will be less customized to you.
b. 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 mobile advertising (also called “cross-app advertising”), including those performed by AdView, 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 cross-app advertising by updating to iOS 6.0 or higher and enabling “Limit Ad Tracking.”
o iOS 7 and Higher: Go to Settings → Privacy → Advertising, and toggle “Limit Ad Tracking” to ‘ON.’
o iOS 6: Go to Settings → General → About → Advertising, and toggle “Limit Ad Tracking” to ‘ON.’
• Android Devices: If you have an Android device, you can opt out of most cross-app advertising by going to Google Settings → Ads, and selecting the option to opt out of interest-based ads.
Please note that these platforms control how these settings work, so the above instructions may change. Likewise, if your device uses other platforms not described above, please check the settings for those devices.
c. Additional Choices
Advertisers may also provide ways for you to opt out from, or limit their collection of, certain information from and about you. Please refer to the privacy policies for retailers, apps, and mobile websites to learn more about their privacy practices.
You may opt out from receiving promotional emails from us, such as emails to inform you about events and new services, by following the “unsubscribe” instructions in any promotional email you receive, or by contacting us at email@example.com. Please note, however, that we may still send you non-promotional emails relating to your relationship with us.
5. PRIVACY PRACTICES FOR THE ADVIEW WEBSITES
a. Information We Collect Through the AdView Websites
The AdView Websites provide information regarding AdView and our products and services. Through the AdView Websites, we collect information you voluntarily disclose to us, and we may also obtain automatically-collected information.
i. Information You Disclose to Us
When registering for an account, expressing an interest in obtaining additional information about AdView or our products and services, or otherwise contacting us through the AdView Websites, we collect information you voluntarily disclose to us, such as your name, mailing address, email address, telephone number, credit card number, and other billing information. You may also provide us with certain information about your business or other individuals.
ii. Automatically-Collected Information
We may also use third party-services, such as Google Analytics, that gather information such as your IP address, browser type, the web page from which you came to the AdView Websites, and the times of your visit. In addition, as you browse the AdView Websites, advertising cookies may be placed on your computer so that we can “remember” your interests. Our display advertising partners may then help us retarget ads to you on other sites based on your interactions with the AdView Websites. To opt out of such interest-based mobile advertising, please see Section 4 above, entitled “Consumer Control and Opt-Out Options.” Opting out in this way will not prevent you from receiving ads; rather, the ads you see will be less customized to you.
b. How We Use Information We Collect Through the AdView Websites
In addition to the uses described elsewhere in this Policy, we use the information we collect through the AdView Websites (alone or in combination) to provide, market, improve, and operate the AdView Websites, AdView Ad Services, and any other products or services we have or may develop. This includes use of the information to:
• Fulfill your requests;
• Send information about our products and services, including marketing communications;
• Respond to your questions, concerns, or customer service inquiries;
• Create aggregated or de-identified information;
• Comply with applicable laws, prevent fraud, mitigate risk, and perform similar purposes;
• Understand usage trends and preferences;
• Analyze, improve, and provide products and services;
• Customize the content and advertising you see on the AdView Websites, across the Internet, and elsewhere; and/or
• Perform other purposes at your request.
c. How We Share Information We Collect Through the AdView Websites
We may share the information we collect through the AdView Websites in the following situations:
• With your consent, including through this Policy;
• With our affiliates;
• With third parties that help us to operate our business and provide our services, such as entities that provide us with technical, customer, billing, administrative, event planning, marketing, or operational services;
• As part of a business purchase, sale, merger, consolidation, investment, change in control, transfer of all or substantially all of our assets, reorganization or liquidation, bankruptcy, or in connection with steps taken in anticipation of such an event (e.g. due diligence);
• 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, including for purposes of national security and law enforcement;
• If we believe sharing the information may prevent physical, financial or other harm, injury, or loss; or
• If we believe sharing the information is necessary to protect our, or any other person’s or entity’s, interests, rights, property, or safety, or in connection with an investigation of suspected or actual unlawful activity.
With respect to aggregated or de-identified information, we may share such information without restriction.
6. DATA ACCESS AND RETENTION
Generally speaking, we retain the information collected from the AdView Websites and AdView Ad Services for as long as necessary to achieve our objectives as detailed in this Policy, and to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you are a resident of the European Union, you may obtain a copy of the information we have about you by contacting us at firstname.lastname@example.org. Please be advised that, due to the manner in which we collect information, we will only be able to provide you with such information if we can determine that the information is identifiable to you. Under extenuating circumstances, we reserve the right to charge a fee for providing you with such information, and that fee will be based on costs and fees we incur to fulfill your request.
7. 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 the information from loss, misuse, or alteration. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your information.
To assist with data security, you understand that YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF ANY ACCOUNT CREDENTIALS THAT CAN BE USED TO ACCESS ANY ACCOUNT WITH ADVIEW. ANY ACTIONS TAKEN USING YOUR ACCOUNT CREDENTIALS ARE YOUR SOLE RESPONSIBILITY.
8. THIRD-PARTY WEBSITES AND APPS
This Policy only applies to the AdView Websites and the AdView Ad Services. We are not responsible for the privacy practices or disclosures of websites, developers, or apps that access or use the AdView Websites or AdView Ad Services. Likewise, when you access the AdView Websites, 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 Policy.
9. USERS FROM OUTSIDE THE UNITED STATES
The AdView Websites and AdView Ad Services are provided, supported, and hosted in the Hong Kong, and their operation is governed by Hongkong law. If you are using the AdView Websites or AdView Ad Services from outside Hongkong, be aware that your Information may be transferred to, stored, and processed in Hongkong and other countries where our facilities are located. The data protection and other laws of Hongkong might not be as comprehensive as those in your country. By using the AdView Websites or AdView Ad Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share your information as described in this Policy.
We may occasionally update this Policy to reflect changes to our privacy practices. The amended Policy will be displayed on the AdView Websites. Please check our Policy regularly to ensure you have read the latest version and to stay informed of our privacy practices. Your continued access to and use of the AdView Websites and AdView Ad Services constitute your acknowledgement of this Policy and any updates.
13. CONTACTING US
If you have any questions regarding this Policy, please contact us at email@example.com or:
SHANGYOUJIA TECHNOLOGY (HK) LIMITED
FLAT/RM A 20/F SEABRIGHT PLAZA, 9-23 SHELL STREET NORTH POINT
Phone: +86 400-013-1400