Last Updated: July 26, 2018
Vungle, Inc. and its group companies (“Vungle”, “we” or “us”) respect your privacy. This privacy notice (“Notice”)explains who we are, how we collect, use and share personal information about you, and how you can exercise your privacy rights.
This Notice covers personal information we collect:
- when providing the Vungle Ad Services (see Section 2); and
- when you visit one of our Websites, and in the usual course of our business, such as in connection with our events, sales and marketing activities (see Section 3).
We recommend that you read this Notice in full to ensure you are fully informed. However, to make it easier for you to review those parts of this Notice which apply to you, we have divided up the document into the following sections:
- 1. WHO WE ARE (applicable to everyone)
- 2. PRIVACY FOR THE VUNGLE AD SERVICES (applicable to End Users)
- 3. PRIVACY FOR THE VUNGLE WEBSITES (applicable to End Users and visitors to our Websites)
- 4. GENERAL INFORMATION (applicable to everyone).
- 4.1 How do we share your information?
- 4.2 Your data protection rights
- 4.3 Legal basis for processing personal information (EEA residents only).
- 4.4 Third-Party Websites and Apps
- 4.5 How do we keep your personal information secure?
- 4.6 Data Retention
- 4.7 International Data Transfers
- 4.8 EU-U.S. Privacy Shield Notice
- 4.9 Changes to this Notice
- 4.10 Contact Us
We participate in and comply with the EU-U.S Privacy Shield Framework to cover data we process from the European Union (“EU”). For further information, please review our EU-U.S. Privacy Shield Notice
- WHO WE ARE
Vungle is an ad network providing a technology platform (“Platform”) for Clients that want to advertise and/or monetize their applications, games, and other products. Our “Clients” include “Advertisers” that wish to distribute ad content through the Vungle Platform, and “Publishers” of applications that want to display relevant ads to end users (“End Users”) of third party applications (“apps”) that use our SDKs, APIs, hosted video advertising platform and/or any of our related advertising tools (collectively, the “Vungle Ad Services”).
Advertising revenue helps keep many games and apps free. We work hard to ensure that the ads that pay the app developer bills are interesting, relevant, and safe for End Users.
- PRIVACY FOR THE VUNGLE AD SERVICES
This Section describes how Vungle collects and uses information we receive from End Users (“you”) of apps that use the Vungle Ad Services.
2.1 What information do we collect?
When you visit an app that uses Vungle technology, we use and deploy “tracking technologies” (see Section 2.3, below) to automatically collect certain information about your device. Some of this information (including for example, your IP address and certain unique identifiers), may identify a particular computer or device and may be “personal data” in some jurisdictions, including the EU. We collect this information the first time Vungle’s SDK is initialized on a Publisher Client’s app. Note, however, that Vungle’s Ad Services do not collect any information that that enables us to identify End Users personally (such as your name, address, or email address).
We may also combine, merge, and/or enhance the information we collect about your device, including the personal data, with information we may collect about your interactions with other Publisher Client’s Apps and ads served through Vungle’s Platform, or with information collected from our Clients and third parties (such as data providers). This may include, for example, mobile device IDs, demographic or interest data, and content viewed or actions taken on an app to help make the ads served to you more relevant while limiting your exposure to less relevant ads. We (or our third party partners) may also use this additional information to undertake “user matching,” which means that in addition to the ID an End User has been assigned in our system, we may also receive a list of unique IDs our external partners or Clients have assigned to an End User.
There may also be situations where Vungle’s SDK is not incorporated into the Publisher Client’s app, but we still receive some of the same data listed above in order to respond to an Ad request from a Publisher Client’s app.
2.2 How do we use your information?
We use the information we collect (sometimes in combination with information provided and sourced by independent validation partners) for a variety of business purposes. For example, we use the personal information we collect for the following purposes:
- Serving Ads: To allow Publishers to offer advertising inventory in their apps, and Advertisers to bid on and display ads in that inventory.
- Ad Reporting and Conversions: Reporting to Advertisers information about when and how End Users have been exposed to their ads, clicked on their ads, or visited their website.
- Frequency Capping: Preventing End Users from seeing the same ad too many times.
- Customizing Ads: To customize and more effectively tailor the ads we display to you and to optimize the display of ads (including limiting your exposure to less relevant ads).
- Performance Analytics: To analyze ad performance, such as tracking views of ads, as well as click-through rates to websites or app stores and/or installs of apps that have been advertised.
- Fraud Detection and Prevention: Identifying invalid clicks, installs, or ad queries, and protecting us and our Clients from fraudulent behavior.
- Providing and Improving the Vungle Ad Services: Auditing, researching, and analyzing data in order to provide, protect, and improve the Vungle Ad Services and to ensure that our technologies function properly.
2.3 How do we use tracking technologies to collect information?
We use standard tracking technologies to collect information automatically from your device so that our backend operations can use it to perform many of the functions described in “How do we use your information?” above. To opt out of our use of such technologies, please follow the instructions for opting out in the apps, as described in “Opt-Out Choices” below.
2.4 Your Opt-Out Choices.
You can opt out of having your information being used by Vungle for performance-based advertising by accessing your mobile device settings and following the most recent published instructions. If you limit ad tracking, you will still see advertisements (even ones sourced from Vungle’s network), but Vungle will no longer be able to use the personal information described above in Section 2.1 to serve you with more relevant ads. In addition, the advertising identifier (along with any information collected about that identifier) that was previously assigned to you will also be disassociated. This means that if at a later stage, you decide to opt back in, we will not be able to use any of your past information, and you will for all practical purposes be a new user to our system. You may also stop the collection of location information by particular apps by changing the preferences on your mobile device.
2.5 How Do We Share Information?
Please see Section 4.1, below for information concerning how Vungle shares the information collected.
2.6 Privacy Practices of Vungle Clients.
Vungle is not responsible for the information practices of our Clients. We require our Clients to comply with all applicable laws and regulations and to provide End Users with notice of the collection of data for advertising purposes as outlined in this Notice. We encourage you to review the privacy policies of apps you visit for information about those apps’ data collection and use practices.
Our Clients are responsible for ensuring that their mobile apps comply fully with applicable children’s data privacy protection legislation, such as the United States’ Children’s Online Privacy Protection Act (“COPPA”), including where relevant by obtaining parental consent prior to the collection of personal information. With respect to COPPA specifically, we rely upon our Publisher Clients to confirm whether or not their app is subject to COPPA. As required by COPPA, Vungle will enable a flag in our system such that the End User’s device history is disassociated, and the only End User “personal information” used by the Vungle Ad Services would be Publisher-specific unique digital identifiers (e.g., IP address and device identifiers) to support Vungle’s internal operations.
- PRIVACY FOR THE VUNGLE WEBSITES
This Section describes how we collect and use Information in the usual course of business, including through our websites (such as https://vungle.com or any other website on which this Notice is posted) and other corporate services, web portals, and dashboards we make available to our Clients and End Users (collectively “Websites”), as well as in connection with our events, sales and marketing activities.
3.1 What information do we collect?
- Information that you provide voluntarily: Certain parts of our Websites may ask you to provide personal information voluntarily. For example, when registering for a Vungle account, expressing an interest in obtaining additional information about Vungle or our products and services, subscribing to marketing or otherwise contacting us, Vungle collects personal information from you. The personal information that you are asked to provide (and the reasons why you are asked to provide it) will be made clear to you at the point we ask you to provide your personal information. We will also let you know prior to collection whether the provision of personal information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information.
- Information we collect automatically: When using our Websites, we may automatically collect certain information from your device. In some countries, including countries in the EU, this information may be considered personal data under data protection laws.
- Information we collect from third party sources: We may obtain information about you from other sources, such as public databases, joint marketing partners, data providers and social media platforms. Examples of the information we receive from other sources include account information, page-views, and browsing information.
3.2 How do we use your information?
We use the information we collect or receive to:
- Send you marketing and promotional communications. For example, we and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. However, you will always be able to opt-out of our marketing at any time (see the “Your Choices” section above).
- Send administrative information to you. For example, to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
- Engage in and process transactions. For example, we may use your personal information along with financial, credit card, and/or payment information that you provide to us to process your transactions and for billing purposes.
- Respond to your requests. For example, we may use your personal information to fulfill your request for a quote or customer support, or to provide you with information you have requested about the Websites or Vungle Ad Services.
- Post testimonials. We post testimonials on the Websites that may contain personal information. Prior to posting a testimonial, we will obtain our consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at firstname.lastname@example.org and be sure to include your name, testimonial location, and contact information.
- Manage your account and provide support or other services. For example, for the creation or administration of your Vungle account, to communicate with you, and to provide you with customer support or other services you have ordered, such as product updates, product patches and fixes and other similar operational communications.
- Select content and improve quality. We may use your information to help improve the Website, Vungle Ad Services, and to ensure that content on the Websites is presented in the most effective manner for your device (for example, by presenting products and offers tailored to you).
- Protect the Vungle Websites. We may use your information as part of our efforts to keep the Websites safe and secure (for example, for fraud monitoring and prevention).
- For our business purposes. We may use your information for our business purposes, such as data analysis, audits, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our products, services, marketing, and client relationships.
3.3 Cookies and Similar Tracking Technologies
3.4 How Do We Share Information?
Please see Section 4.1, below for information concerning how Vungle shares the information collected.
- GENERAL INFORMATION
4.1 How do we share your information?
We may disclose your personal information to the following categories of recipients:
- Advertiser Clients. If you are an End User, we may share information we collect in connection with the Vungle Ad Services with our Advertiser Clients for purposes relevant to our business relationships with them, such as for billing purposes, dispute resolution, or fraud prevention, and to help them identify and/or buy our Publisher Client’s advertising inventory. Our Advertiser Clients are obligated to use the information they receive in compliance with applicable laws and regulations.
- Attribution Partners. Acting on behalf of our Advertiser Clients, if you are an End User, we may share your information (such as your mobile device ID) with our Advertiser Clients’ attribution partners to validate and measure the success of ads delivered via the Platform for billing purposes.
- Vendors, consultants and other service providers. We may share your information with third party vendors, service providers, contractors or agents who perform functions required for the operation of our business. Examples include to provide data storage and processing services, fraud prevention, technical support for our Platform, analyzing data and performing analysis related to the Website, Platform and related services, and delivering content.
- Compliance with laws. We may disclose information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Disclosures for national security or law enforcement. Under certain circumstances, we may be required to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Vungle affiliates. Vungle is headquartered in San Francisco, CA, but we have subsidiary and affiliate offices in New York, NY; London, UK; Berlin, Germany; Tokyo, Japan; Seoul, Korea; Beijing, China; and Singapore, Singapore. A list of our group companies is available here. We may share information with our parent companies, subsidiaries and/or affiliates for use and processing purposes described in this Notice.
- Business transfers. We may share or transfer information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Notice.
- Website advertising partners. We may partner with third party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share your personal information with them for this purpose.
- Consent. We may share your information with any other person with your consent to the disclosure.
4.2 Your data protection rights:
You have the following data protection rights:
- You can request access to or that we change, update or delete your personal information at any time by contacting us at email@example.com. Please note that we may impose a small fee for access and disclosure of your personal information where permitted under applicable law, which will be communicated to you.
- In addition, if you are a resident of the European Economic Area, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. To exercise these rights email firstname.lastname@example.org.
- You can opt out of receiving promotional emails from us by clicking the “unsubscribe” link in the email, by emailing email@example.com. If you choose to no longer receive marketing information, we may still communicate with you regarding such things as your security updates, product functionality, responses to service requests, or other transactional, non-marketing/administrative related purposes.
- If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area (” EEA“)are available here.
Please note that because most of the information we store can only identify a particular browser or device, and cannot identify you individually, you will need to provide us with some additional information to enable us to identify the personal information we hold about you and ensure that we accurately fulfil your request.
4.3 Legal basis for processing personal information (EEA residents only).
If you are an individual from the EEA, our legal basis for collecting and using personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we normally rely on our legitimate interest to collect personal information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to process your personal information, they include the interests described in the sections headed “2.2 How do we use your information?”, “3.2 How do we use your information?” above.
In some cases, we may rely on our consent or have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person. If we rely on consent to collect and/or process your personal information, we will obtain such consent in compliance with applicable laws.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the details provided under the heading “Contact Us” below.
4.4 Third-Party Websites and Apps:
This Notice only applies to the Vungle Websites and Vungle Ad Services. We are not responsible for the privacy practices or disclosures of websites, developers, or apps that use or access the Vungle Services or Vungle Ad Services. In addition, ads within the Vungle Platform may contain links to third-party websites and apps. Any access to and use of such linked websites or apps is not governed by this Notice, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties.
4.5 How do we keep your personal information secure?
We use appropriate administrative, organizational, technical, and physical safeguards to protect the personal information we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe, secure, and only available to you and to those you provided authorized access. Specific measures we will use include hashing and pseudonymization of data prior to storage. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so you should take care in deciding what information you send us in this way.
4.6 Data Retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such data or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
- If you are an End User, we typically store the personal information we collect about you, such as your IP address and other information described above, for 13 months from the date of collection before we delete, overwrite, or anonymize that data, unless we are required to keep it to comply with a legal or audit obligation.
Please contact us at firstname.lastname@example.org if you have any questions about the information we collect and/or how we use the information we collect.
4.7 International Data Transfers:
The Vungle Ad Services and Vungle Websites are provided, supported, and hosted in the United States. If you are using the Vungle Ad Services and Vungle Websites from outside the United States, be aware that your information may be transferred to, stored, and processed by Vungle in our facilities and by those third parties with whom we may share your personal information, in the United States and other locations including London, Berlin, Tokyo, Seoul, Beijing and Singapore, where we have offices. These countries may have data protection laws that are different to the laws of your country.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
4.8 EU-U.S. Privacy Shield Notice
Vungle, Inc. is located in the United States and participates in and complies with the EU-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from EU member countries in the United States.
Vungle adheres to and will abide by the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability when processing such personal information.
Vungle is responsible for the processing of personal information it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal information from the EU, including the onward transfer liability provisions.
With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review our certification on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.
Questions or complaints
You can direct any questions or complaints about the use or disclosure of your personal information to us at email@example.com. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of personal data within 45 days of receiving your complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider, JAMS, free of charge at https://www.jamsadr.com/eu-us-privacy-shield.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with us and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. To find out more about the Privacy Shield’s binding arbitration scheme please see https://www.privacyshield.gov/article?id=My-Rights-under-Privacy-Shield.
4.9 Changes to this Notice:
Vungle will review and update this Notice periodically and will note the date of its most recent revision above. If we make material changes to this Notice, we will notify you either by prominently posting a notice of such changes prior to implementing the changes or by directly sending you a notification. We encourage you to review this Notice frequently to be informed of how Vungle is protecting your information.
4.10 Contact Us:
If you have questions about our privacy practices, or would like to make a complaint, please contact Vungle’s Data Protection Officer by email at firstname.lastname@example.org or by post using the details provided below:
Residents outside of the European Economic Area (EEA)
185 Clara Street, San Francisco, CA, 94107, United States
European Economic Area (EEA) residents
- Vungle Limited
Attn: Data Protection Officer
Clover House, 147-149 Farringdon Road, London, England, EC1R 3AB