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This Privacy Statement supplements the information contained in the Privacy Policies that apply to your use of the websites and applications made available by Digital Turbine, Inc. (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the EU (“consumers” or “you”). We adopt this notice to comply with international and domestic privacy laws.
This privacy statement only applies to our products and information practices. We are not responsible for the actions and privacy policies of third party websites, partners, or their services.
This Privacy Statement further provides you with instructions on how you can request to get your data under privacy laws, how you can instruct us to delete your data, and how to stop the “sale” of your information.
Here are instructions to obtain an accessible and printable version of this policy: Right click on this page and in the menu select “Print.”
Information We Collect
We offer two types of services: Content that we deliver through our software application loaded on your device (the “Applications”) and content we deliver through the web browsers on your device (“Web Services”)(we will refer to Applications and Web Services collectively as the “Services”).
Categories of Information Collected by Our Applications
We collect and use from the Applications the following categories of information. We also state whether this information is shared or “sold” to third parties.
1. Categories of Personal Information Collected or Used by the Applications: Identifying information about you.
Examples: Android Advertising ID and our own product ID, which we call the “MPID” (each, a “User ID”).
Primary Purpose of Collection:
- To authenticate your with access to the Services.
- To provide you with information, content products or services customized to your interests delivered from us and our advertisers.
- To improve the type of services and content that may be of interest to you.
- For our internal testing, research, analysis and product development.
Do we share or sell this data?: We store our data on third-party hosting services under agreement. We use third-party analytics services such as Google Analytics to analyze data on our behalf. This data cannot be reused by these services. We sell User ID to advertising networks to deliver advertising on our Applications.
2. Categories of Personal Information Collected or Used by the Applications: Internet or other electronic network activity information
Examples: We collect information on how a user interacts with our Applications, including IP address, user page views, device platform, the device language (e.g., English or Spanish), device model, views of first screen deliveries, date and time when a user interacts with our Applications, operating system of the user’s device, Application version, the type of browser, the type of content delivered to the user (e.g., entertainment news), and the number of clicks per session.
Primary Purpose of Collection:This information helps us assess what features and content are of interest to its users and to measure the Services’ efficiency in delivering its services.
Do we share or sell this data?: We store our data on third-party hosting services under agreement. We use third-party analytics services such as Google Analytics to analyze data on our behalf. This data cannot be reused by these services. We do not sell this data or share it for marketing purposes.
3. Categories of Personal Information Collected or Used by the Applications: Geolocation
Examples: The Services collect your location from your device when you access the Services. This data is not shared with third parties.
Primary Purpose of Collection:Location information helps us provide you with content relevant to your region, such as local weather forecast and regional news.
Do we share or sell this data?: We store our data on third-party hosting services under agreement. We use third-party analytics services such as Google Analytics to analyze data on our behalf. This data cannot be reused by these services. We sell geolocation to advertising networks to deliver localized advertising on our Applications.
Categories of Information Collected by our Web Services.
The information we collect from you related to the use of the Web Services may include the following:
1. Categories of Personal Information Collected or Used by the Web Servides: Identifying information about you.
Examples: Our own Application ID (we call it the “MPID”).
We also collect the make and model of your devices (but not its specific device ID) and information about your version of the Application.
Primary Purpose of Collection:
- To identify our users of the Web Services.
- To provide you with information, content products or services customized to your interests delivered from us and our advertisers.
- To improve the type of services and content that may be of interest to you.
- For our internal testing, research, analysis and product development.
Do We Share or Sell this Data?: We store our data on third-party cloud services and use third-party analytics services (e.g., Google Analytics) solely to analyze data on our behalf. We do not sell the MPID from Web Services.
2. Categories of Personal Information Collected or Used by the Web Services: Internet or other electronic network activity information
Examples: We collect information on how a user interacts with our Web Services, including IP address, user page views, device platform, the device language (e.g., English or Spanish), device model, views of first screen deliveries, date and time when a user interacts with our Applications, operating system of the user’s device, the type of browser, the type of content delivered to the user (e.g., entertainment news), and the number of clicks per session.
Primary Purpose of Collection:This information helps us assess what features and content are of interest to its users and to measure the Services’ efficiency in delivering its services./p>
Do We Share or Sell this Data?: We store our data on third-party cloud services and use third-party analytics services (e.g., Google Analytics) solely to analyze data on our behalf. We do not sell this data from our Web Services.
3. Categories of Personal Information Collected or Used by the Web Services: Geolocation
Example: We collect latitude and longitude information from your device when you are using the Web Services.
Primary Purpose: Location information helps us provide you with content relevant to your region, such as local weather forecast and regional news.
Do We Share or Sell this Data?: This information is stored on third-party services on our behalf and shared with analytics services such as Google Analytics for our internal business purposes. This information is not sold.
Categories of Information that We Do Not Collect
We do not collect or share the following categories of personal information:
- Other Identifiers such as name, postal address, email address, account name, social security number, driver’s license number, passport number, employment history, or financial information.
- Characteristics of protected classifications under California or federal law.
- Commercial information.
- Biometric information.
- Audio, electronic, visual, thermal, olfactory, or similar information.
- Professional or employment-related information.
- Education information.
- Inferences drawn from information to create a profile.
We will retain as permitted under privacy laws certain data analyzed and processed by us, such as when a user has accepted our terms for the Application and such other data reasonably anticipated within the context of our relationship with you or solely for internal business purposes.
How we Use Your Information
In addition to the primary purposes of collection noted above, we may generally use the categories of information noted above as follows:
- Provide you with access to the Services.
- Customize your experience with the Services.
- Contact you through the service to provide you with important information, notices, and promotions.
- Protect our rights and property and those of our other customers against unauthorized use.
- Aggregate information for business purposes that include market analysis or traffic flow.
Retaining Information
We keep your information only as long as necessary to provide you with our services and for legitimate and essential business purposes, such as maintaining the performance of the services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.
Sharing Personal Information
We may share your Information from our Services with data hosting services and analytical services to provide us with business, professional or technical support. Subject to your right to opt-out, we also share User IDs (but not location or activity information) from our Applications with advertising networks to provide you with offers that may be of more interest to you. Please note: We do not share User IDs, location or activity information with Advertisers from our Web Services. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties: Service Providers, which include data hosting services and analytics services that process information on our behalf under a written contract and Advertising Networks.
Your Rights and Choices
The privacy laws provides consumers with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.
We have a right to verify your request. Important: Since we do not collect email addresses, numbers or names, the only way we can verify your request is if you provide us with us with your User IDs (Android Ad ID and MPID). The easiest way for us to verify your request is (a) if you click the “Do Not Sell My Information” on the Application on your device, or (b) for other requests, click on the “Give Me My Data” or “Delete My Data” links below. These links automate the process. We also provide instructions below if you desire to submit your requests via toll free number or through an authorized agent.
Right to Know: Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Please note we delete user data that is older than 3 months.
Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information that we have collected.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting or selling personal information.
- The categories of third parties with whom the business shares personal information.
- The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
You can submit your request by:
Clicking on the “Give Me My Data” link at the bottom of this page.
Call 1-866-304-3097.
Right To Delete Data
You have the right to request that we delete any of your Information collected and retained by us subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality./li>
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
Exercising Deletion Rights
You have a right to ask us to delete your data. You can submit your request by:
Clicking on the “Delete My Data” link below.
Calling us at 1-866-304-3097
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may stop all information collection by uninstalling the Application. You may use the standard uninstall processes available as part of your mobile device or uninstall the App through your device’s Google Play store.
There are some instances in which you may not be able to uninstall some older versions of the Applications preloaded on your device. In that case, the Application can be force stopped by clicking on the “Settings” icon, then click on Apps & Notifications, then “See All apps”, and then click on the Application link. You will then have the option to “Force stop” the application, and clear information stored in memory by clicking on “Storage & Cache” then “Clear Storage” and “Clear Cache”.
Right to Opt-Out of the Sale of Personal Information
Users of Applications have the right to opt-out of the sale of Personal Information collected as part of the Applications. Users can submit their requests by:
Launch your version of the Application on your device, Click on the “Settings” icon, and then click “Do Not Sell My Info.”
Calling us at 1-866-304-3097
Right to Designate an Authorized Agent
Users of the Services can designate an authorized agent to make a request under the CCPA or other domestic and international privacy laws if they provide that agent with their User ID information. Please note that this action would allow such agent access to all information contained in the Application. If a user chooses to take this action, they do so entirely at their own risk and we disclaim all responsibility and liability for how such agent may access, use or disclose the information they obtain.
The agent will need to have your User ID to make a request. We are not able to identify a user based on name or email address since we do not collect this information. Agents must submit requests to privacyact.nokiamenabar@digitalturbine.com. Users can provide their User ID information using the process described below.
Finding the Android Advertising ID and Mobile Posse ID.
In order to verify your request under the CCPA, GDPR, and other domestic and international privacy laws we will need your User ID (again, that is the Android Advertising ID and the MPID). The easiest way to verify your request is by (a) using the “Do Not Sell My Information” in the Application’s Settings area on your device, or (b) for other requests, go to the “Get My Data,” or “Delete My Data” links below. These links automate the process. If you contact us toll free number or an agent, our representative may ask you or your agent to locate your User IDs. You can find the Google Android Advertising ID by clicking on the “Settings” icon on your device, click on “Google” and then click on “Ads.” There you will see a string of letters and numbers that make up your Google Android Advertising ID. In the event you are asked to provide an MPID, please follow this process: To find the MPID, launch the Application on your device. Click on the “Settings” icon (the gear icon). Click on “Send Feedback.” When you click on Feedback, you will see a pre-populated email page. You will see on this email page a string of numbers and characters that make up your MPID. Copy that ID and to share with us so that we can act on your request.
Cookies
Some of our third party partners may collect and share certain pieces of information from our visitors, such as cookies, advertising IDs, location and similar technologies so that our third party partners can deliver ads to you and conduct analysis about our services. These technologies are summarized as follows:
| Type of Technology | Description |
|---|
| Cookies | A cookie is a small file placed onto your device that enables our services’ features and functionality. There are two types of cookies: “persistent”, which stays on your browser or our application (such as, to help verify your login) and “session” cookies, which last only as long as you are currently using our app or browser. |
| Pixels | A pixel is a tiny image that may be found within web pages and emails. They’re used to learn more about your use of content on our service or whether you interact with an advertisement. |
| Other technologies | We also use other tracking technologies, such as the User ID we describe above. |
We and our third-party providers use Cookies for the following:
| Purpose | Description |
|---|
| Authentication | Cookies enable us to identify you and verify your account when you visit our services. |
| Security | Cookies to enable and support our security features, such as by helping us detect malicious activity and violations of our Terms of Service. |
| Preferences | These cookies can help us customize content for you, and remember the preferences you selected with use of our service. |
| Advertising | Cookies and similar technologies help us show relevant advertising to you more effectively and to measure the performance of such ads. We use these technologies to learn whether content has been shown to you or whether someone who was presented with an ad. Similarly, our third-party partners or service providers may use these technologies to determine whether we've shown an ad or a post and how it performed or provide us with information about how you interact with ads. Some of this type of information sharing may also be considered a "sale" under the CCPA, GDPR, and other domestic and international privacy laws. |
| Performance, analytics and research | We or our service providers use these technologies to understand, improve, and research products, features and services, including as you navigate through our sites or when you access our services. We, or our service providers, use these technologies to determine and measure the performance of ads or posts on the service and to learn whether you have interacted with our service and content and provide analytics based on those interactions. We also use these technologies to provide aggregated information to our customers and partners as part of our services. |
Advertisers
Our third-party advertisers may use cookies and collect information from our users so that they can deliver ads based on your interests and to conduct analysis about our services. If you wish to opt out of this advertising activity by advertisers who offer CCPA, GDPR, and other domestic and international privacy laws opt outs, please visit our Advertising and Cookie Policy and follow the instructions. The Advertising and Cookie Policy page also lists our third-party providers.
Service Providers
Our third-party service providers may use cookies and collect information on our behalf for analytics, auditing, security, debugging, delivering content and games to users, quality assurance, to assess our performance, research, and performance. Unlike advertising, these cookies are used for the functioning of our services.
Options on Cookies
The browsers on your device allow you to control cookies through their settings and to erase cookies stored on your browser. Please note that you may worsen your overall user experience if you limit the ability for our services to set cookies. You also can go to our Advertising and Cookie Policy to exercise your options with our third-party advertising
Please keep in mind:
- You must opt out on your device in which you access our services.
- If you clear cookies, your opt-out may also be cleared and you must opt out again where you want your choices to apply.
- We do not have control over the opt-out mechanisms of our third-party providers.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Your Exercising these choices does not prevent us from delivering contextual advertising, advertising to you based on data we have about you, conducting cross-device tracking for us to serve you first-party ads directly, or using information for non-targeted advertising purposes, such as measuring ad effectiveness, attribution and analytics.
Limitations on the Number of Requests
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. If we are unable to link your request with your User ID, we will provide you instructions on how you can locate your User ID on your device. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We will retain this information in accordance with the CCPA, GDPR, and other domestic and international privacy laws.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Children Under the Age of 16
Our Services are not intended for children under 16 years of age. No one under age 16 may provide any personal information on our Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on our Services. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.
Non-Discrimination
We provide our services at no cost to you. Unless permitted by law, we will not discriminate against you for exercising any of your CCPA, GDPR, and other domestic and international privacy laws rights.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
dt>Phone: 1-866-304-3097- Website: www.mobileposse.com
- Email: privacyact.nokiamenabar@digitalturbine.com
- Postal Address: Digital Turbine
- Attn: CCPA
- 4040 Fairfax Drive Ste 888
- Arlington, VA 22203
Updated: 31 December 2019