This policy applies to the information MobileFuse LLC (“MobileFuse,” “we” or “us”) collects and receives from individuals (“end users” or “you”) who interact with Digital Media Properties (defined below) that use MobileFuse’s technology to provide you with ads. MobileFuse is committed to transparency, and we want you to fully understand how we may collect, use, and share information relating to individuals (like you), and the choices that are available to you.
MobileFuse provides a digital advertising technology platform and related services that connects advertising buyers (advertisers) with sellers (publishers) of advertising inventory (in other words, the opportunity to display a buyer’s advertisement on a seller’s Digital Media Property). In this policy, we refer to our buyers and sellers collectively as “clients”.
For example, advertisers (or their agents) use our technology to buy advertising for display on publishers’ websites, mobile applications, and other digital media properties (which we collectively refer to as “Digital Media Properties”).
Information We Collect
When you visit a Digital Media Property that uses our technology, we collect certain information about you and your device (collectively, “User Information”). This information does not directly identify you – we don’t collect your name, email address, phone number, and address – but it may be considered “personal data” or “personal information” under applicable privacy or data protection laws.
In particular, we collect identifiers such as your IP addresses and mobile device identifiers. These identifiers may identify a particular computer, mobile device, or other device. We also collect information about your activity online, including the following categories of internet or electronic network activity:
How We Collect User Information
We use standard web technologies to collect information automatically from your device when you engage with a Digital Media Property that uses our technology.
We also work with third-party advertising platforms that separately collect and use User Information to enable our and their customers to deliver targeted advertisements using our advertising technology. As an example, we work with third-party advertising companies that use information about your visits to various websites or applications across multiple devices in order to provide you content and ads of interest across devices that they think are associated with you or your household, including web browsers, mobile apps, and televisions. Our clients may use this third-party data in combination with the User Information we collect to deliver you targeted ads across multiple devices.
Note that while we may share information your information with partners to provide analytical and/or targeting services, MobileFuse does not sell your personally-identifiable data nor will your personally-identifiable data be shared by our partners with other entities.
How We Use User Information
Our clients use User Information in order to buy and sell advertising space on Digital Media Properties. In particular, our clients use information we provide, in conjunction with other information they have independently collected, to deliver end users targeted advertising they believe will be of particular interest to those users. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
We also use the User Information we collect for our legitimate business interests, some of which are “business purposes” under California law, including:
Sharing of User Information
We disclose User Information that we collect as follows:
Information Our Customers and Vendors Collect
Our clients, our vendors, and our clients’ vendors, who use our technology may use their own tags, pixels, cookies, or other similar technology (or those of their other affiliates) within their advertisements. We are not responsible for our clients’, vendors’ and/or our clients’ vendors’ use of such tracking technologies or for their privacy practices.
Your Opt-Out Choices
There are several ways to opt-out of receiving targeted advertising our clients may initiate using our technology. Note that different devices use different identifiers and different technologies, so that you must opt out separately from each browser and each device that you would like to be opted out. If you opt-out of targeted advertising, we will no longer collect User Information described above from the opted-out device.
Your device should give you the ability to opt-out of the use of information about the apps you use in order to serve you ads that are targeted to your interests (see “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” under your settings menu on Android devices or “Limit Ad Tracking” under your settings menu on iOS devices).
You may stop the collection of location information by particular apps or from your device as a whole at any time by changing the preferences on your mobile device. For more information on how to change your preferences, please see http://www.networkadvertising.org/mobile-choice.
Your Choices and Rights
If you live in certain jurisdictions such as the European Economic Area (“EEA”), the United Kingdom (“UK”), Switzerland, or California, you have certain rights and protections under the law regarding the collection, processing, and use of information about you.
In particular, you have the right to: (i) request access and obtain a copy of your User Information, and (ii) request erasure, or deletion of your User Information. You may also have the right to request rectification of your User Information, to obtain your User Information in a portable format, to object to or restrict the processing of your User Information, to prevent the use of your User Information for particular purposes, and to not be discriminated against for exercising your rights.
If you would like to exercise any of these rights, please see our Opt Out policy for instructions on how to do so.
We typically store the User Information we collect from your device, such as Unique Device ID, IP address and other information described above, in our systems for up to 90 days before we anonymize and aggregate that data into summary reports.
In some cases, we may keep some of the User Information for longer periods of time where required under certain laws or to comply with law enforcement or regulatory requests – for example, those relating to corporate governance, taxation, money laundering and financial reporting legislation.
We use industry-standard technical and organizational security measures to help protect information transmitted over or stored on our systems. Please note that no transmission or storage of information, however, can ever be guaranteed to be completely secure, though we take all reasonable precautions to protect against security incidents.
Additional Information for California Residents
If you are a resident of California, please review these additional privacy disclosures.
California law requires us to disclose the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information, which we have explained above. We are also required to communicate information about rights you have under California law—for information about these rights, please see the “Your Choices and Rights” section above. You also have the right to request what information we collect and how we use and disclose it. You may exercise these rights by visiting our Opt Out policy. Please note that because most of the information we store can only identify a particular browser or device, and cannot identify you individually, you need to provide us with some additional information to enable us to identify the User Information we hold about you, if any, and ensure that we accurately fulfill your request. If you have any questions about your rights or our disclosures, you may reach us at firstname.lastname@example.org.
In addition, we are required to provide you certain information about the business and commercial purposes for which we collect and share your personal information. We use and disclose the information we collect for the business purposes described in the “How We Use User Information” section of this policy, including: to allow our clients to select and display advertisements, to understand how users interact with our services, for auditing purposes, to detect security incidents, to prevent fraud, debug, and repair errors, and for other purposes described above.
Do Not Sell My Personal Information
MobileFuse does not sell User Information, but our clients may use our technology to buy or sell personal information as defined by California law. If you wish to opt out of the use of your personal information for interest-based advertising purposes, you may do so by following the instructions under Your Opt-Out Choices above.
MobileFuse also adheres to IAB CCPA Compliance Framework for Publishers & Technology Companies found here: https://www.iab.com/wp-content/uploads/2019/12/IAB_CCPA-Compliance-Framework-for-Publishers-Technology-Companies.pdf
Changes to this Policy
We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. If we make material changes to this policy, we will notify you of any material changes by posting the revised policy on this website, and where necessary, by any other means required by applicable law.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact MobileFuse’s Privacy Team by e-mail at email@example.com or by mail using the details provided below:
Attn: Compliance Team
25 E21st Street, 10th Floor
New York, NY 10010
You can also contact MobileFuse’s Data Protection Officer at firstname.lastname@example.org.
MobileFuse respects the data protection and privacy rights you may have under applicable privacy laws (often referred to as “data subject rights“ or “consumer privacy rights”).
For that reason, in order for us to honor any data protection and privacy requests you submit, we need you to provide us with your Digital Identifiers and certain other information. This is necessary to locate any records we hold about your device or browser. We explain below how to do this, and use this additional information only for the purpose of processing your data protection and privacy requests.
Your Rights Explained
Residents of some jurisdictions (for example the European Economic Area (“EEA”), the United Kingdom (“UK”), Switzerland, and California), have certain rights available to them under the laws of those jurisdictions.
These rights may include the right to request access to, rectify, or request erasure/deletion or portability of, personal information. Residents of these jurisdictions may also have a right to object to, or request that we restrict, processing of their personal information. Where such rights apply, we will comply with requests to exercise these rights in accordance with applicable data protection laws. We will also make efforts to honor such requests even in jurisdictions that do not provide for these rights
If you make a request to access the specific pieces of personal information we hold about you in accordance with applicable law (also known as an “access request“), we will provide the Digital Identifiers of your browser(s) and/or device(s) that MobileFuse may store. Additionally, we may also provide you with certain other information that we may have stored and associated with your Digital Identifiers.
Please note, however, that we have a very short retention period for the data we associate with Digital Identifiers. As a result, we may not be able to provide you any records in response to an access request. In such cases, however, we will inform you that we have not been able to locate any records associated with your Digital Identifiers.
Important Note: We have a responsibility to verify your identity before we respond to an access request. This is to make sure that we provide a copy of your personal information only to the person who is entitled to it – you. If you wish to make an access request, we kindly ask that you contact us directly, with sufficient details for us to verify your identity (as explained below).
How To Make A Data Subject Rights (Opt-Out) Request
If you wish to exercise a data subject rights request, please follow the steps described below:
Step 1: Locate Your Digital Identifiers
In order for us to locate relevant records, we will need you to provide us with your Digital Identifiers. You can find your Digital Identifiers as follows:
Mobile Devices and other Internet Connected Devices
Certain mobile devices (for example, mobile phones or tablets using the iOS or Android operating systems) generate a persistent “Advertising Identifier” per device, which, among other things, can be used by third parties, like MobileFuse, for purposes of providing you with targeted advertising.
On iOS devices, your Advertising Identifier may be referred to as an “IDFA,” “IFA,” or an “ID for Advertising.” On Android devices, your Advertising Identifier may be referred to as an “Advertising ID.” Please follow instructions from your mobile device manufacturer on how to locate your specific Advertising Identifier. The following link may also help you http://www.networkadvertising.org/mobile-choice.
Step 2: Verify Your Digital Identifiers
In order to make sure that we are responding to the correct person, we also will need some supporting proof to demonstrate that the devices that have the Digital Identifiers you located in Step 1 are yours and that the information you are requesting relates to you. For Digital Identifiers located on a mobile device, please take a screenshot of the screen that displays the Digital Identifier.
We may also request that you respond to a few questions, so that we can appropriately verify your identity. Doing this helps us to validate that you have access to the device on which the Digital Identifiers have been placed (and that you are not an unauthorized third party attempting to “guess” Digital Identifiers).
Step 3: Submit to MobileFuse
Once you have located your Digital Identifiers and can provide us with verification (screen shots) of those Digital Identifiers, please contact us with details of the rights you wish to exercise. The easiest way to do so would be to submit the relevant information to our privacy email at email@example.com. We request the following information:
Also, please note that MobileFuse also follows the IAB CCPA Compliance Framework for Publishers & Technology Companies found here: https://www.iab.com/wp-content/uploads/2019/12/IAB_CCPA-Compliance-Framework-for-Publishers-Technology-Companies.pdf