1. COLLECTION AND USE OF INFORMATION
Our primary goals in collecting and using information are to provide and improve the Online Services and the Sites, to administer and assist customers with their Online Services account, and to provide a better experience with the Online Services. Information about customers and end users will be stored and processed by us in the United States. For more information about the transfer of your data to the United States, please refer to Section 5. The EU and Swiss legal basis for the processing of end users’ personal data is consent for our use of end user personal data and the performance of the agreement between Customer and Pedemy Inc for our use of end user personal data on behalf of customers, or, for employees working for a customer, the legitimate interests Pedemy has in processing such data in order to provide the Online Services to our customers. In some instances, we may also rely on consent that has been given for specific forms of processing.
2. INFORMATION ABOUT CUSTOMERS
Registration: During the registration process on our Sites, customers may be asked for certain information, which may include their name, their email address, the company for which they work, their country, and a password. This registration information is used to validate customers when they visit the Sites. It may also be used to send customers additional promotional information about our services. Employees of customers can opt out of receiving promotional emails at any time by using the link provided for this purpose in each email. If customers are entered in a Pedemy promotion in connection with their registration, we will also use their name and email address to contact them if they have won a prize in that promotion, and will ask them for the address at which they would like to receive their prize. We store all data associated with customer accounts, including contact information, applications and campaigns. Contact/Content: On the Sites we may offer online forms to enable customers to contact us. We may also offer customers the opportunity to request specific content, like newsletters and whitepapers we publish. When we request contact details (such as name and email address), we may ask for consent to use these to send information about our Online Services in the future.
Cookies and Beacons: A “cookie” is a small text file that contains a string of alphanumeric characters. There are two types of cookies that may be used at our Sites: persistent cookies and session cookies. A persistent cookie gets entered by a Web browser of a visitor to our Sites (“Site visitor”) into the “Cookies” folder on their computer and remains in this “Cookies” folder after their browser is closed. Persistent cookies may be used on subsequent visits to the Sites. A session cookie is held temporarily in a computer’s memory and disappears after a Site visitor closes their browser or shuts off their computer. The Sites or the emails we send may also use Web beacons (also called “clear GIFs” or “pixel tags”) in conjunction with cookies. Web beacons are small strings of code that are placed in a Web page. If a Site visitor arrives at the Sites by clicking on a banner ad for one of our products or services, a session cookie may be used. This cookie will contain an identification number for the ad that a Site visitor clicked on, or will contain an identification number for the Sites that a Site visitor was visiting when they clicked on the banner ad. This session cookie helps Pedemy determine which of our ads attract the most visitors. If, after a Site visitor arrives at our Sites and requests further information from us about our products and services, the information provided in that request will be linked to the information in the session cookie. This also helps Pedemy measure the effectiveness of our advertising. Because this is a session cookie, it will disappear once a Site visitor closes their browser. Our Sites may use persistent cookies, Web beacons and information collected in our log files (such as Internet Protocol Address, referring URLs, etc.) about activities at the Sites to better understand how the Sites are used, resolve technical problems, and enhance the experience of Site visitors. We may use a third-party email technology to send emails that customers have agreed to receive. Web beacons are used in those email messages to measure the effectiveness of our advertising. In addition, Pedemy may serve ads on the Sites using our own ad serving technology. In doing so, one of our ad servers will place or read a unique ad-serving cookie on a Site visitor’s computer and will use information about their browser and activities at the Sites. The ad serving cookie is a persistent cookie. We may also allow third parties to place cookies on our Sites to track use of the site to enable us to analyze the traffic of our marketing pages. Examples of such providers of analytics services may include Google Analytics
3. COLLECTION AND USE OF INFORMATION ABOUT END USERS
Online Services: When an ad is served through our Online Services, we and others may collect the following from end users’ devices: bundle ID, language ID, operating system version, device model, software developer kit (SDK) version, unique device identifier, IP address, and Media Access Control (MAC) address. In addition, when an end user accesses a video ad, we and others may collect additional stats about videos and video playback such as: start/boot-up information, amount played/session length information, memory on device used for our video cache, videos cached on a device and complete view event. We identify an end user’s device using Pedemy’s internal device ID, which is linked to an end user’s Apple IDFA, Google Advertising ID (GAID), or Android ID, as applicable. If a customer uses Pedemy’s Post-Install Tools, which include Post-Install Analytics, Publisher Segmentation and Retargeting, we and others may access and collect data such as the following: when an end user launches the app, how long the end user plays the app, and in-app events. We and others may use this information to provide customers with an end user’s usage data, advertising campaign optimizations, and user re-targeting based on a user’s usage patterns. We also receive any of the information described in this section about end users from third party data providers, advertisers, or advertising services companies including mobile device identifiers, geolocation, IP addresses, website cookie information and usage data. We and others combine information about end users with additional demographic, geolocation and interest-based segment data, along with cookie information, including from third-party providers. We and others may also derive inferences about demographics, geolocation and interests based on end user information. The additional information we, infer, access, and collect may determine the nature of the ad that the end user sees. If customers do not want to expose end users to behaviorally targeted advertising campaigns, customers can choose to opt out of behavioral targeting by following the relevant instructions as set out on the Sites.
4. INFORMATION SHARING OR DISCLOSURE
We may share any of the information described above as follows. We contract with third parties to provide some part of the Online Service or to assist us in analyzing our services or information. Pedemy may provide this information to such third parties, or such third parties may collect information from you or the end users on our behalf or on behalf of our customers. We may also share this information with third parties with whom we have a strategic relationship, including on behalf of our customers, such as advertisers, demand side platforms, measurement/attribution companies, and advertising services companies. The information shared with these third parties may be used, among other things, for industry analysis, tracking ad conversions, cross-device matching, behavioral advertising or demographic profiling, and to provide services on behalf of our customers. These third parties may collect information about your online activities over time and across different websites and applications. We may also provide this information to our business partners or other trusted entities, including on behalf of our customers, for the purpose of providing you with information on goods and services we believe will be of interest to you. We may be required to disclose information about you in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and will disclose such information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Pedemy, our customers, end users, or any third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable. In addition, we may disclose this information to third parties in connection with a corporate re-organization, bankruptcy, liquidation, merger or amalgamation, or the sale of all or substantially all of our assets. We may share information for other purposes if you or our customers direct us to do so or you consent to such sharing. Finally, in addition to the information described above, we may share aggregate or anonymous information about you or end users with advertisers, publishers, business partners, sponsors, and other third parties, including on behalf of our customers. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-U.S. Privacy Shield, Pedemy is potentially liable for such transfers.
5. PRIVACY PRACTICES OF CUSTOMERS AND THIRD PARTIES
- that their data will be collected by Pedemy to show ads on customers’ applications, including ads which are based on behavioral targeting (for example: ads for games which are similar to those which they have installed and played before);
- the transfer of their data to Pedemy in the US under the EU/US Privacy and Swiss-U.S. Shield Framework;
- their rights as data subjects, as described in Section 9;
- their right to withdraw consent at any time;
- their right to lodge a complaint with a supervisory authority.
6. TRANSFER ON THE BASIS OF THE EU/SWISS – US PRIVACY SHIELD FRAMEWORK
Pedemy has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles for the collection and processing of personal data from our customers and end users in the European Union [and Switzerland]. To learn more about the Privacy Shield program please visit www.privacyshield.gov
. Pedemy has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact Kathleen Pierz, JAMS Practice Development Manager, Global on 212.607.2771. You can also submit a form on https://www.jamsadr.com/eu-us-privacy-shield/
. The services of JAMS are provided at no cost to you. In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles. Because Pedemy complies with the Privacy Shield Principles, it is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission with respect to our adherence to Privacy Shield.
7. CONFIDENTIALITY AND SECURITY
While we cannot guarantee that loss, misuse or alteration to your data will not occur, we make good faith efforts to prevent such occurrences. We do not warrant or represent that your account or any of your information will be protected against, loss, misuse, or alteration by third parties.
It is our policy to provide communications, whether such communications are required by law or are for marketing or other business related purposes, to our customers via e-mail notice, written or hard copy notice, or through posting of such notice on our Sites, as determined by us in our sole discretion. Notwithstanding the foregoing, we reserve the right to determine the form and means of providing notifications to our customers.
9. DO NOT TRACK, CALIFORNIA DO NOT SELL MY INFO, AND END USER CHOICES
Because the Sites we operate do not collect or use the type of information that is generally subject to your browser’s “Do Not Track” (DNT) privacy preference, our websites do not look for this signal from your browser. Your DNT settings, however, may affect the third-party services we use. You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. You may opt out of interest-based advertisements by adjusting the settings on your mobile device. For iOS mobile devices, go to “Settings” from the device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile devices, go to “Google Settings” on the device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.” You can review http://www.networkadvertising.org/mobile-choices
for more information regarding how you may opt out via the mobile platform. If you would like to disable the collection of your mobile device geolocation information, you can make this selection on your mobile device. To learn more about interest-based advertising, and to access the opt-outs of certain online advertising companies, visit the Network Advertising Initiative at http://www.networkadvertising.org/choices/#completed
or Digital Advertising Alliance (DAA) at http://www.aboutads.info/choices/
. You should complete the opt-out process for all devices and browsers you use. If you opt-out of targeted advertising, you will still receive general advertisements.
10. RIGHTS OF EU AND SWISS DATA SUBJECTS
Pedemy recognizes that any individual in the EU or Switzerland has the following rights in relation to their information:
- The right to obtain, at reasonable intervals and free of charge, confirmation as to what personal data about them are processed by Pedemy
- The right to object to processing of personal data about them for direct marketing purposes
- The right to have personal data about them rectified, blocked or deleted if the data are incorrect, incomplete, irrelevant, outdated or processed unlawfully
- The right to object to processing based on their particular situation
- The right to receive the personal data about them which they have provided to Pedemy in a structured and commonly used format and to transmit those data to another controller
Some of your information can be changed or deleted by following the process provided in the Online Services Account, unless we must keep the information for legitimate business or legal reasons. If you delete certain of your information, your account may become deactivated. If you wish to make a request based on the above, please inform us by visiting answers.Pedemy.com
and going to the ‘Contact Us’ page. We may request evidence of your identity for verification purposes. We will respond to your request within the applicable statutory term. If an end user exercises any of their rights with you with respect to the processing of their information by us, please use the tools in the Online Services Account to accommodate their request, or, if this is not possible, please visit answers.Pedemy.com
and go to the ‘Contact Us’ page.
11. RIGHTS OF CALIFORNIA RESIDENTS
The processing of certain personal information about customers that are California residents is subject to the California Consumer Privacy Act (“CCPA”) and the following rights apply with respect to that data.
Right to opt out. Customers have the right to opt out from future “sales” of personal information. To do so, review section 9 of this policy (DO NOT TRACK, CALIFORNIA DO NOT SELL MY INFO, AND END USER CHOICES).
Customer’s End User Data
We are a service provider as defined by CCPA with respect to personal information we process on behalf of our customers about their respective end users. To understand rights end users have with respect to personal information we process as service providers on behalf of our customers, please visit their respective privacy notices.
Pedemy retains information about you for as long as necessary to fulfil the purposes for which we collected the data, except if required otherwise by law. We may store information for longer periods for archiving or statistical purposes in which case we will take appropriate measures to ensure that the information is used solely for this purpose.