Privacy Policy for EEA
LAST UPDATED: May 2018
EFFECTIVE: May 25, 2018
1. INTRODUCTION
InMobi is committed to respecting and protecting individuals' privacy rights. This Privacy Policy explains how InMobi Pte Ltd, its subsidiaries and affiliated companies (collectively, "InMobi" or "we", "us", "our") collect, use, secure, and/or disclose EEA end users’ (“you” or “your”) device-related information when (i) you view ads served by InMobi on third party websites or mobile apps (see the section below called "InMobi Ad Network"), and (ii) you visit the InMobi website at www.inmobi.com (see section below called "InMobi Website").
Any content aggregation services or feature (such as displaying of stories, articles, pictures, blogs etc.) (whether through an app or other software integration) provided by InMobi on a device will not be covered under this Privacy Policy, except to the extent the app or software promotes any interest-based advertising by InMobi. We urge you to refer the privacy policy of such services separately, as and when made available.
“EEA” means all member states of the European Union and for the purpose of this Privacy Policy, U.K. and Switzerland.
2. INMOBI ADVERTISING
2.1 WHAT IS THE INMOBI AD NETWORK?
InMobi is a global ad network with a suite of ad tech products. We partner with third-party mobile website publishers and mobile app developers to serve ads on their sites and in their apps, and InMobi may also serve ads on the site and mobile applications that InMobi owns. These ads may be customised to their users' interests and geographic locations, which we may derive or infer from information that we collect about how those users interact with such sites and apps (this type of advertising is often called "interest-based advertising" or "targeted advertising"). This enables our partnering publishers and developers to provide content-rich services that are more relevant to their users, often using the advertising revenues they generate to offer their services for free or at a subsidised cost. Further, we may also obtain user data from our data partners, advertisers and/or advertisers’ partners for optimising digital advertising and/or analytical purposes including to provide relevant advertising and reporting. Please note that collection, use or storage of such data is governed by the privacy policy of such third party partners and/or advertisers providing the same.
InMobi may engage in cross-device data collection, which refers to the process of collecting data from devices that have been determined through statistical analysis to be linked or related. We, or third parties whom we engage to provide this service, may use cross-device data to provide interest-based advertising services and to deliver tailored ads to users across multiple devices.
2.2 WHAT INFORMATION DO WE COLLECT?
When you view an InMobi ad on a site or app, we may collect information about your device that you have viewed. This information enables us to improve our services including recognising your device when you use other sites and apps that have partnered with us.
(a) Information about your device
InMobi may collect some or all of the following information about your device: device type (e.g. smartphone, tablet, etc.),operating system (e.g. iOS, Android, Windows, Blackberry), network provider, mobile browser used (e.g. Safari, Internet Explorer etc.),platform, SDK version, timestamp, API key (identifier for application), application version, iOS Identifier for Advertising, iOS Identifier for Vendors, model, manufacture of device, OS version of device, session start/stop time, locale (specific location where a given language is spoken), time zone, network status such as WiFi, the geo-location of your device (using GPS or other geo-location data) and the Identifier for Advertising (IDFA) or the Google Advertising ID (AAID) etc. In some countries, we also collect information such as international mobile equipment identity (IMEI), Internet (IP) addresses or geo-location data, which may be considered to be personal information and in which case, we ensure compliance with applicable laws in our collection or use of the same, to the extent applicable in such jurisdictions.
InMobi may collect the geo-location of your device only when an app or site, which leverages InMobi’s offerings through integration of InMobi’s technology/software (whether SDK, API or other integration) is active on the device. One way InMobi derives a device’s location is by collecting the device’s latitude and longitude coordinates through GPS. InMobi may infer the geo location of a device based on data collected through a WiFi identifier that the device is connected to, subject to country specific laws and/or industry guidelines related to such collection or inference practices. e.g: In the U.S. and UK, InMobi may infer geo-location through WiFi identifiers pursuant to obtaining user consent through applicable apps or sites.
(b) Information about ads presented on your device
InMobi also collects some or all of the following information about an ad presented on your device: (i) the content type of the ad (what the ad is about, e.g. games, finance, entertainment, news); (ii) the ad type (e.g. whether the ad is a text, image, or video based ad); (iii) where the ad is being served (e.g. the address of the site on which the ad appears); and (iv) certain information about post-click activity in relation to the ad including user interaction with such ad.
On occasion, our partnering mobile publishers or app developers may also disclose to us certain information including email addresses of users in a hashed format (not in raw format) 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 specific privacy policies and subject to their own applicable legal requirements. We do not use the information they provide to us for any purpose other than serving you with interest-based ads or for reporting or analytical purpose(s).
2.3 HOW DO WE USE INFORMATION THAT WE COLLECT?
InMobi uses the information that we collect from your device to display advertising on your device, which may include interest-based advertising customised to individuals’ inferred interests, preferences and locations and to perform analysis aimed at improving our services.
The information we collect from your device also helps us to provide filtering options for publishers and developers to manage ads appearing on their sites and in their apps, and to provide targeting options for advertisers. We rely on your consent to process your personal data in this way. If you do not consent, the ads you see will be less tailored to your interests. In particular, processing your data in this way help our publishers and developer clients, for example, to avoid presenting you ads that you have already seen, and helps our advertiser clients serve advertisements that are more likely to be of interest to you.
2.4 WHO DO WE SHARE INFORMATION WITH?
(a) Publishers, Developers, Advertisers, Data Partners and Measurement Companies
InMobi may share the information we collect or receive regarding you as described in this Policy with our publishers, developers, data partners, measurement companies and advertisers. These partners may use this information to show you relevant ads, measure your ad/site interaction, identify your interest areas, better understand the site and app traffic usage or user behaviour in order to refine and improve their services. Such partners’ use of the information we share with them will be governed by their privacy policies.
(b) With InMobi Affiliates
We may also share your information with InMobi affiliates so that we can better provide advertising that is relevant to you.
(c) Sharing Info with third parties such as advisors and law enforcement authorities.
From time to time, we may also need to disclose your information to other third parties, such as law enforcement authorities or our legal advisers, where it is necessary to: comply with the law or regulations; enforce or apply our user terms and conditions; protect our rights, or; preserve the safety of our users. This may include exchanging information with other companies and organizations for fraud protection.
InMobi may also share your information in connection with any merger, a sale of InMobi assets, or a financing or acquisition of all or a portion of our business to another company.
3.YOUR INTERACTION WITH INMOBI WEBSITE
3.1 WHAT INFORMATION DO WE COLLECT?
If an individual or entity chooses to create an account on the InMobi website we collect username, password, email address, phone number, country, and preferred account type that is provided at the time of registration.
A registering party can also provide us with other optional information, such as name, picture, postal address, phone number, social network profiles, questionnaire responses, general business information, and other personal, biographical, or demographic info. The optional information may not necessary for use of the InMobi site or to maintain an account with us, but by sharing this information we can better serve and improve overall website and marketing experience. Please note that we may use some or all such data in conducting business transactions with the registering party or for marketing purposes.
If the name and email address of another individual or entity is provided, we may use that information to send such individual or entity a one-time invitation to visit or register with our site. Please do not share such information, if such individual or entity has not authorized provision or use of the same. In the course of registration or other modes of providing the data sets referred above, we advise all visitors to only share their business information with us.
3.2 THE USAGE INFORMATION WE COLLECT
In addition to the personal information described above, we also collect certain information about the usage of the site. Specifically, our servers collect the following information automatically about a visitor’s usage of the site:
1.the type of web browser used (e.g. Internet Explorer, Mozilla Firefox, Google Chrome or another)
2.vistor’s travel within the site (e.g. the pages visited within the InMobi site)
3. browsing preferences, such as screen size, resolution and other viewing preferences
4.the links and adverts that clicked on
5.information about how the visitor arrived at our site (e.g. whether directed to our site by a search engine or another third party website)
6.Information about how a visitor leaves our site (e.g. which website is visited immediately after visiting our site).
We may use cookies to help us collect and store this information, as described in more detail in our cookie policy (see: https://www.inmobi.com/cookie-policy/).
3.3 HOW DO WE USE THE INFO WE COLLECT?
For account management purposes
We use the account information and other personal information provided by a visitor to manage account, communicate with such individual or entity, conduct business (e.g. reporting and payment), personalise the InMobi website and comply with requests.
To contact visitors with marketing information
We will handle personal information (such as name, email address, postal address, telephone number and sector preferences) for marketing purposes and inform about products and services in accordance with marketing preferences.
When we send marketing emails because it has been opted-in by a visitor to receive them, we rely on consent to contact such visitor for marketing purposes.
If not opted-in and we send marketing emails, we do this because of our legitimate interest to promote the success of InMobi.
Every email we send for marketing purposes will also contain instructions on how to unsubscribe from receiving them.
A visitor is not under any obligation to provide us with personal data.
Visitor(s) can notify InMobi of their election of personal information to be not processed in this way at any time by contacting us at privacy@inmobi.com or, where relevant, by following the unsubscribe link shown in every marketing communication received from us.
To conduct web analytics
We use usage information to analyse our web traffic, to figure out how often customers use parts of the site, to improve the site and generally to make it appealing to as many users as possible.
3.4 WHO DO WE SHARE INFORMATION WITH?
We will share personal information only in the ways that are described in this privacy statement. We do not sell any such personal information to third parties.
From time to time, we may need to disclose such information to third parties such as to law enforcement authorities or our legal advisers, where it is necessary to comply with the law or regulation; enforce or apply our user terms and conditions; to protect our rights, or to preserve the safety of our users. This may include exchanging information with other companies and organizations for fraud protection.
We may also share personal information with companies that provide services to help us with our business activities (e.g. processing payments or submitting emails on our behalf), in connection with any merger, a sale of InMobi assets, or a financing or acquisition of all or a portion of our business to another company. We need to process personal information in this way to provide the ongoing services and benefits. Whenever we share personal information for this reason we will ensure that the recipient is bound by all appropriate confidentiality obligations and that it commits to using such personal information only for the purposes for which it is originally provided.
Please be aware that the information submitted to public areas, such as our blogs, may be read, collected, and used by others who access them.
If social media features are interacted with on our site, such as the Facebook Like button, or social network credentials are used to comment on our blog, these features may collect information about such use of this site as well as post information about activities on this site to applicable profile page. Interactions with these features are governed by the privacy policy of the company providing it.
4. OPTING OUT OF INTEREST-BASED ADVERTISING
If you prefer not to receive interest-based advertising from InMobi, you can opt out of interest-based advertising at any time by going to the InMobi Opt Out page and submitting your device ID.
Please note that if you opt-out of interest-based advertising you will still receive "generic" ads from InMobi.
To effectively opt-out of our cross-device data collection activities, you must opt-out on every device browser and device using the appropriate opt-out methods.
5. HOW DO WE KEEP INFORMATION SECURE?
InMobi uses reasonable technical and organisational measures to protect the information it collects about you and your device. We may anonymise the information we collect using one-way hashing technology before sharing it with any third parties. We also seek appropriate contractual protection from our partners regarding their treatment of user data.
6. HOW LONG DO WE KEEP INFORMATION FOR?
InMobi may retain the information relating to your device collected from partnering mobile publishers or app developers for a period of up to thirteen (13) months, unless otherwise required by law or applicable contract. After the 13-month period, InMobi may retain and use such data in aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes and enforce agreements.
Where we are using personal information to contact for marketing communications, if opted-in we will contact you periodically, if required by applicable laws, to ensure you are happy to continue receiving such communications.
If informed of election to no longer receive marketing communications from us, InMobi will stop sending the same.
7. INTERNATIONAL TRANSFERS
InMobi may share your information with clients, affiliates and other third parties described above who are based in countries outside of your country of residence (for example, if you are an EU resident, we may share your information with our non-EU clients or affiliates), subject to any contractual or legal requirements. This means that their processing of your personal information will involve a transfer of data outside of the EEA.
Whenever InMobi transfers your personal information outside of the EEA, we ensure it is protected by making sure at least one of the following safeguards is in place:
- by transferring your personal information to a country that has been deemed to provide an adequate level of protection by the European Commission;
- by using specific contracts approved by the European Commission which give your personal information the same protection it has within the EEA including to US;
- where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
If you wish to learn more about the specific circumstances when each of these protection measures are used, you can contact us at privacy@inmobi.com for the details as to how we protect specific transfer of your data.
All information you provide to InMobi is stored on our secure servers or those of our third party data storage providers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. You must not share your password with anyone.
8. INFORMATION COLLECTED ON BEHALF OF THIRD PARTIES
InMobi may offer advertising solutions to clients that include the collection of voluntary information from you as part of an advertisement, e.g. serving an ad that contains an advertiser questionnaire or suveys. Such information may consist of personally identifiable information, non-personally identifiable information, or both. All of the information that you voluntarily provide in response to this form of advertisement is typically forwarded directly to the relevant client and will be governed by that client's privacy policies in place. This information may be temporarily stored by InMobi for the aforesaid purpose and reporting to client, subject to applicable legal requirements. For more information see www.inmobi.com/leadgen.
9. COOKIES
We use cookies and beacons to help us collect some of the information we have described above. This may be done when you interact with our advertiser or publisher partners who enable InMobi to collect data related to your interaction with their apps or sites for the purpose of serving relevant Ads to you and/or improve our services.
We may also use cookies to provide website functionality and advertising to you, and to save you having to provide the information you have already given us on subsequent visits to our site.
For more detailed information about the technologies we use and your ability to control those cookies, please visit our cookie policy. We recommend that you review the privacy policies the third party apps, services or sites that you directly interact with to learn how those third parties use cookies.
10. WHAT ABOUT CHILDREN?
InMobi complies with the age gating provisions of the General Data Protection Regulation in EEA and Children's Online Privacy Protection Act (COPPA) in the U.S and does not knowingly collect any personal data of children, as applicable.
11. WHAT ABOUT OTHER WEBSITES?
Our website and the ads we service may contain links to other websites. You should be aware that we are not responsible for the privacy practices of such other websites as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these links and we shall not be responsible for any use of such websites.
12.YOUR RIGHTS
Right of access: Where we hold personal information about you, you can ask us for access to this personal information, to correct or update any inaccurate personal information we hold, to stop sending you direct marketing or to stop using your personal information altogether.
Right to rectification: You have the right to require InMobi to rectify any inaccurate personal information we hold about you. You also have the right to have incomplete personal information we hold about you completed, by providing a supplementary statement to us.
Right to restriction: You can restrict InMobi’s processing of your personal information where:
- you think we hold inaccurate personal information about you;
- our handling of your personal information breaks the law, but you do not want us to delete it;
- InMobi no longer needs to process your personal information, but you want us to keep it for legal reasons; or
- where we are handling your personal information because we have a legitimate interest, as described above, and are in the process of objecting to this use of your personal information.
Where you exercise your right to restrict InMobi from using your personal information, we will then only process your personal information when you agree, except for storage/archival purposes and to handle billing and legal claims.
Right to data portability: You have the right to receive your personal information in a structured, standard machine readable format and to send this to another organisation controlling your personal information. This right only applies to your personal information we are handling because you consented to us using it or because there is a contract in place between us.
Right to erasure: You have the right to require InMobi to erase your personal information which we are handling in the following circumstances (anonymization would satisfy erasure):
- where we no longer need to use your personal information for the reasons we told you we collected it for;
- where we needed your consent to use your personal information, you have withdrawn your consent and there is no other lawful way we can continue to use your personal information;
- when you object to our use of your personal information and we have no compelling reason to carry on handling it;
- if our handling of your personal information is in violation of applicable law; and
- when we must erase your personal information to comply with a law we are subject to.
Right to complain: You have the right to lodge a complaint with the Information Commissioner's Office, the supervisory authority for data protection issues.
If you would like to exercise any of these rights, you may be able to make the update within your account settings or by contacting us using the details provided below.
13 HOW DO WE KEEP INFORMATION SECURE?
We use appropriate technical and organisational security measures to protect the information we collect. We use multiple electronic, procedural, and physical security measures to protect against unauthorised or unlawful use or alteration of information, and against any accidental loss, destruction, or damage to information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.
14. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy at any time. The amended Privacy Policy will be displayed on our site. If we make any material changes we will notify you by means of a notice on this site prior to the change becoming effective. Please check our Privacy Policy regularly to ensure you have read the latest version.
15.CONTACTING US
If you have any questions about this Privacy Policy, please contact us at privacy@inmobi.com.
