Effective as of 5/23/2018
AppOnboard, Inc. provides advertising technology services that allow publishers of mobile applications (“Apps”) to show ads on their Apps. This allows publishers to generate revenue while reducing or eliminating charges owed by the end user. Through our interactive advertising technologies, Advertisers, typically other App developers, can reach audiences that may be interested in their products or services.
Section 1: End User Practices
The Information We Collect
When you interact with an App that uses the AppOnboard Services, we collect information about your device and the ads you view or interact with. Generally, the AppOnboard Services do not collect information that identifies you directly (for example, we do not collect information such as your name, any user name associated with the App you use, your email address, or a mailing address). We will not combine this information with any information that identifies you without your express consent. We collect:
• Information about your device such as the type and model, manufacturer, operating system (e.g. iOS or Android) and operating system version (e.g. iOS 11.2), device language setting, carrier name, IP address, mobile browser (e.g. Chrome, Safari), applications using the AppOnboard Services and the version of such applications, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, and the geo-location of your device (using GPS or other geo-location data), when location services have been enabled for the mobile App you are visiting.
• Information about your visit such as log information, including the App visited, session start/stop time, time zone, and network connection type (e.g., WiFi, cellular).
• Information about the ads we deliver and how you interact with them such as the type of ad, the placement of the ad, whether you clicked on it, where and how (e.g. tap vs. swipe) you clicked on it, what elements or features of the ad you clicked on or otherwise interacted with, and whether you visited the advertiser’s Web site or downloaded an App of the advertiser.
• Information from Third Parties that Business Partners and other third parties have collected and share with AppOnboard, such as information they collect through their Apps or other services, which may include general demographic or interest information, if it is lawful for them to share such data with us under applicable privacy laws.
How We Use the Information We Collect
We use the information we collect from End Users for the following purposes. In some cases for certain purposes, consent may be required from an End Users under applicable law, in which cases we will obtain consent directly from the End User or through the publisher of the applicable third-party App before using the information for that purpose.
• To provide, maintain, secure, and improve the Services and to develop new services.
• To allow publishers to offer ads from our advertisers in their Apps, and to allow advertisers to provide the ads.
• To calculate appropriate charges for advertisers.
• To allow AppOnboard to target more relevant ads to End Users.
• To identify and prevent improper or fraudulent behavior.
How We Share the Information We Collect
We may share the information we collect as follows (and as described below in Section 3):
• We may share aggregate information with advertisers regarding when and how ads were displayed and how many End Users clicked on their ads, downloaded their Apps, or visited their Web sites. We share this information with them for reporting purposes and so that they can improve the advertising they conduct through our Services.
• We may share aggregate information to publishers about when and how ads were shown on their Apps for reporting purposes.
• We may share information with third-party partners and service providers to receive credit for advertiser billable events such as installs of applications, independently verify performance data such as impressions and button clicks, help prevent fraud, provide security and improve the accuracy of the Services. These third-parties include certain service providers designated by advertisers or ad agencies who verify the authenticity of the interactions that occur with the advertisements we provide.
Privacy Practices of Business Partners
AppOnboard requires Business Partners to comply with all applicable laws and regulations regarding data privacy and security. Independently, our Business Partners are also required to comply with such laws and regulations. All users are responsible for reviewing the privacy policies of sites and Apps they visit for information about those sites’ and Apps’ data collection and use practices.
We do not engage in activities that require parental notice or consent under the Children’s Online Privacy Protection Act (COPPA). Similarly, our ads are not intended to be displayed in Apps primarily directed to children under the Age of 13. If you believe that we have inadvertently collected information from a child under 13 that is subject to parental notice and consent under COPPA, please contact us using the contact information below to request deletion of such information.
When the European Union’s General Data Protection Regulation requires consent for the collection of personal data, we will not collect such personal data from End Users under 16 years of age (or such younger age as may be specified by the laws of a particular country).
Section 2: Data Collected from Business Partners and Visitors to Our Website
Information You Choose to Submit
You may be asked to provide personal information in certain fields on this Site, such as an email address to sign up for our marketing list. Providing this information is strictly voluntary. If we request that you volunteer personal information on the Site, we will provide an explanation of the purposes and limitations of AppOnboard’s collection and use of that data.
To become a Business Partner, you may be asked to provide certain personal information, including your name, your company name, email address, physical address, phone number, tax identification information, accounting and bank information, and payment information (including credit card information).
We provide Business Partners with tools and/or methods to access or change the information provided to us in association with your account.
Information We Automatically Collect
When you visit and use our Site, we may also automatically collect and use certain data. We collect information in standard log files that may include your IP address, your ISP, the Web browser you used to visit the Services, the time you visited the Services, which web pages you visited on the Services, and other anonymous usage data.
This website uses Google Analytics, a web analytics service of Google Inc., (“Google”). Google Analytics uses cookie text files to analyze how our websites are used. Google uses the data stored on these cookies to compile reports on website activities and to provide further services related to the use of the website. Google may also transfer this information to third parties if required to do so by law or if third parties process this data on behalf of Google.
You can object to data collection and storage by Google Analytics at any time by downloading and installing a browser deactivation add-on. This prevents Google Analytics from storing and processing data about your website visits. For more information and instructions on how to download and install, see https://tools.google.com/dlpage/gaoptout.
Do Not Track
The Site does not respond to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Information about an individual consumer’s online activities over time. Visit http://www.donottrack.us to find out more about “do not track.”
How We Use Your Personal Information
If you are an AppOnboard Business Partner, we may use your personal information to notify you of new product releases and services, to send service notifications to improve our services, to provide reporting, to conduct research. and to solicit your feedback and input about the Services.
Any use of any personal information you voluntarily submit to the website for marketing, feedback and other notification purposes will be explained at the point of collection and limited to the purposes specified at that time.
Information Sharing and Disclosure
Section 3: General Policies
How We Share Your Information
We may sometimes use other businesses (“Service Providers”) to perform certain services for us or on our behalf, such as analytics, messaging, payment processing, hosting and maintenance, and data storage and management services. We provide our Service Providers with the information reasonably necessary for them to perform the services on our behalf. Each Service Provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of the information involved in order to protect your information from unauthorized access, destruction, use, modification or disclosure.
AppOnboard may access, preserve, and disclose any information we have collected about you or that you have submitted to us as required for legal purposes, including:
a) in response to subpoenas, court orders, or legal process, or to establish, protect or exercise our legal rights or defend against legal claims;
b) to protect the rights and property of AppOnboard, Business Partners (including advertisers and publishers), our licensors, or the public;
c) if we believe it is necessary in order to investigate, prevent or take action regarding illegal activities, fraud, or violations of the personal or intellectual property rights of others or situations involving potential threats to the safety of any person;
e) if AppOnboard is acquired by or merged with another entity or in connection with a sale of our assets.
Information Collected by Others
Rights of European Union Residents
AppOnboard complies with the European Union General Data Protection Regulation (“GDPR”). The GDPR requires that AppOnboard take particular measures to protect the personal data of European residents. If there is any conflict between this policy and the GDPR, the GDPR principles shall govern with respect to residents of the European Union.
Under the GDPR, you have the right to withdraw consent that you have given us to process your personal data (Article 7); to request access to your personal data stored at AppOnboard (Article 15 GDPR) and the right to data portability (Article 20). You also have the right to request corrections (Article 16 GDPR), deletion (Article 17 GDPR) or restriction (Article 18 GDPR) of your personal data stored at AppOnboard.
If you are an end user, we kindly ask that you make these requests via the info button in one of our advertisements. This will direct you to an online form to submit your information so that we can confirm your device’s identity and ensure that we access the correct data. In order to meet these requests, we will ask you to provide a contact email address. This allows us to send you the information you requested, or to confirm completion of any requests to correct, delete or restrict data (Article 19 GDPR).
If you are not an end user, you may send your requests for access, correction, deletion or restriction to the privacy officer of AppOnboard at firstname.lastname@example.org.
If a European resident is dissatisfied with the handling of your personal data by AppOnboard, you have the right to object to processing of your personal data at any time (Article 21 GDPR). You also have the right to lodge a complaint with a supervisory authority. You may send your concerns or objections about the processing of your personal data to the privacy officer of AppOnboard at email@example.com.
We use standard security procedures and practices appropriate to the nature of the information in an effort to protect information from unauthorized access, destruction, use, modification or disclosure. We also require our Service Providers to implement and maintain reasonable security procedures and practices appropriate to the nature of the information we share with them. No data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot and do not guarantee or warrant the security of any information transmitted to or from the Services.
AppOnboard offers its services globally. AppOnboard Inc. complies with the EU-US Privacy Shield principles (the “Principles”) regarding the collection, use, sharing, and retention of personal information from the European Union.
If you have a Privacy Shield-related complaint, please contact us as explained in the “Contact Us” section below. As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Principles, we will seek to resolve it through our internal complaint resolution process, through the independent dispute resolution body JAMS, or, under certain conditions, through the Privacy Shield arbitration process.
Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, participants may be liable for the transfer of personal information from the EU to third parties outside the EU. Learn more about Privacy Shield here.
AppOnboard also applies the Privacy Shield Principles to information from Switzerland.
If you have questions about this policy, or inquiries, requests or complaints regarding your information, please contact us at firstname.lastname@example.org. For Privacy Shield inquiries, please include “Privacy Shield” in the subject of your message. For GDPR-related inquiries, please include “GDPR” in the subject of your message.