PRIVACY POLICY

LAST UPDATED: APRIL 30th, 2018

EFFECTIVE: APRIL 30th, 2018

 

  1. INTRODUCTION

MAGGOMEDIA is committed to respecting and protecting individuals’ privacy rights. This Privacy Policy explains how MAGGOMEDIA, its subsidiaries and affiliated companies (collectively, “MAGGOMEDIA” or “we”, “us”, “our”) collect, use, secure, and/or disclose end users’ (“you” or “your”) device-related information when (i) you view ads served by MAGGOMEDIA on third party websites or mobile apps (see the section below labeled “MAGGOMEDIA Ad Network”), and (ii) you visit the MAGGOMEDIA website at www.maggomedia.com (see section below labeled “MAGGOMEDIA Website”).

Any content aggregation services or features (such as displaying of stories, articles, pictures, blogs etc.) (whether through an app or other software integration) provided by MAGGOMEDIA on a device it is not, and will not be covered under the terms of this Privacy Policy, except to the extent the app or software promotes any interest based advertising by MAGGOMEDIA. We urge you to refer the applicable privacy policies of such services, separately, as and when such policies are made available by the respective issuers.

  1. MAGGOMEDIA ADVERTISING

2.1 WHAT IS THE MAGGOMEDIA AD NETWORK?

MAGGOMEDIA is a global ad network with a suite of ad tech products. MAGGOMEDIA partners with third-party mobile website publishers and mobile app developers to serve ads, on their respective sites and/or apps.  MAGGOMEDIA may also serve ads on sites and mobile applications owned or partially owned by MAGGOMEDIA. These ads may be customized to meet their respective users’ interests and geographic locations, which we may be obtained, derived or inferred from information that MAGGOMEDIA collects form users. Such information may include, among others, the patterns in which those users interact with such sites and apps (this type of advertising is often called “interest-based advertising” or “targeted advertising”). This enables MAGGOMEDIA’s partnering publishers and developers to provide content-rich services that are more relevant to the users, often utilizing the advertising revenues the ads generate to offer services free of charges or at subsidized prices. Further, MAGGOMEDIA may also obtain user data from its data partners, advertisers and/or advertisers’ partners to optimize digital advertising and/or for analytical purposes; including but not limited to, the provision of relevant advertising and reporting. Please note that collection, use or storage of such data is governed by the privacy policy of the issuing third party partners and/or advertisers.

MAGGOMEDIA 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. MAGGOMEDIA, or third parties engaged by MAGGOMEDIA to provide the cross-device data collection service, may use cross-device data to provide interest-based advertising services and deliver tailored ads to users across multiple devices.

2.2 WHAT INFORMATION DOES MAGGOMEDIA COLLECT?

When you view a MAGGOMEDIA ad on a site or app, MAGGOMEDIA may collect information about your device on which you have viewed the ad. This information enables MAGGOMEDIA to improve its services; including its ability to recognize your device when you use other sites and apps that are partnering or have partnered with MAGGOMEDIA.

(a) Information about your device

MAGGOMEDIA 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, MAGGOMEDIA may 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, MAGGOMEDIA ensures compliance with applicable laws in its collection or use of the same, to the extent applicable in such jurisdictions.

MAGGOMEDIA may collect the geo-location of your device only when an app or site, which leverages MAGGOMEDIA’s offerings through integration of MAGGOMEDIA’s technology/software (whether SDK, API or other integration) is active on the device. One way MAGGOMEDIA derives a device’s location is by collecting the device’s latitude and longitude coordinates through GPS. MAGGOMEDIA may infer the geo location of a device based on data collected through a WiFi identifier to which the device may be  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, MAGGOMEDIA 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

MAGGOMEDIA 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, MAGGOMEDIA’s partnering mobile publishers or app developers may also disclose to MAGGOMEDIA certain information, such as email addresses of users in a hashed format (not in raw format) that they have separately collected about you so that MAGGOMEDIA may improve the relevance of the ads served to you on their behalf. MAGGOMEDIA’s partnering mobile publishers or app developers do this in accordance with their own specific privacy policies and subject to their own applicable legal requirements. MAGGOMEDIA does not use the received aforementioned information for any purpose other than to serve you with interest-based ads or for reporting or analytical purpose(s).

2.3 HOW DOES MAGGOMEDIA USE THE INFORMATION COLLECTED?

MAGGOMEDIA uses the information collected from your device to display advertising on your device, which may include interest-based advertising customized to individuals’ inferred interests, preferences and locations and to perform analysis aimed at improving MAGGOMEDIA‘s services.

The information collected from your device also helps MAGGOMEDIA 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. This helps MAGGOMEDIA’s publishers and developer clients, among other things, avoid presenting you ads that you have already seen, and hence serve advertisements that are more likely to be of interest to you.

2.4 WHO DOES MAGGOMEDIA SHARE INFORMATION WITH?

(a) Publishers, Developers, Advertisers, Data Partners and Measurement Companies

MAGGOMEDIA may share the information it collects or receives regarding you as described in this Policy with its 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 users’ behavior in order to refine and improve their services. Such partners’ use of the information shared by MAGGOMEDIA will be governed by their respective privacy policies.

(b) MAGGOMEDIA Affiliates

MAGGOMEDIA may also share your information with MAGGOMEDIA’s affiliates so that it can better provide advertising that is relevant to you.

(c) Third parties such as advisors and law enforcement authorities

From time to time, MAGGOMEDIA may also need to disclose your information to other third parties, such as law enforcement authorities or MAGGOMEDIA’s legal advisers, where such disclosures are necessary to: comply with the law or regulations; enforce or apply MAGGOMEDIA’s users’ terms and conditions; protect MAGGOMEDIA’s rights, or; preserve the safety of MAGGOMEDIA’s users. This may include exchanging information with other companies and organizations for fraud protection.

MAGGOMEDIA may also share your information in connection with any merger, a sale of MAGGOMEDIA’s assets, or a financing transaction or acquisition of all, or a portion of MAGGOMEDIA’s business interest to a third party.

2.5 HOW DOES MAGGOMEDIA KEEP INFORMATION SECURE?

MAGGOMEDIA uses reasonable technical and organizational measures to protect the information it collects about you and your device. MAGGOMEDIA may anonymize the information it collects using one-way hashing technology before sharing it with any third parties. MAGGOMEDIA also seeks appropriate contractual protection from its partners regarding the treatment of user data.

2.6 HOW LONG DOES MAGGOMEDIA KEEP INFORMATION FOR?

MAGGOMEDIA 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, MAGGOMEDIA may retain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes and enforce agreements.

2.7 OPTING OUT OF INTEREST-BASED ADVERTISING

If you prefer not to receive interest-based advertising from MAGGOMEDIA, you may opt out of interest-based advertising at any time by going to the MAGGOMEDIA Opt Out page and submitting your device ID.

Please note that if you opt-out of interest-based advertising you will continue to receive “generic” ads from MAGGOMEDIA.

To effectively opt-out of MAGGOMEDIA’s cross-device data collection activities, you must opt-out on every device browser and device using the appropriate opt-out methods.

  1. INTERNATIONAL TRANSFERS

MAGGOMEDIA may share your information with clients, affiliates and other third parties described above that 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.

While some countries may not have data protection laws that are equivalent to those of the country in which you reside, MAGGOMEDIA will take reasonable measures to protect your information in accordance with this Privacy Policy.

  1. INFORMATION COLLECTED ON BEHALF OF THIRD PARTIES

MAGGOMEDIA 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. 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 forwarded directly to the relevant advertiser and will be governed by the advertiser’s privacy policies in place at the time of transfer. This information may be temporarily stored by MAGGOMEDIA solely for the aforesaid purpose, subject to applicable legal requirements.

  1. COOKIES

MAGGOMEDIA uses cookies and beacons to aid in the collection of some of the information described above. This may be done when you interact with MAGGOMEDIA’s advertising or publishing partners who enable MAGGOMEDIA to collect data related to your interaction with their apps or sites for the purpose of serving relevant Ads to you and/or improve MAGGOMEDIA’s services.

MAGGOMEDIA may also use cookies to provide website functionality and advertising to you, and to save you having to provide the information you have already provided MAGGOMEDIA on subsequent visits to its 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 of third party apps, services or sites that you directly interact with to learn how such third parties use cookies.

  1. MAGGOMEDIA AND CHILDREN

MAGGOMEDIA complies with the Children’s Online Privacy Protection Act (COPPA) in the U.S. and does not knowingly collect personal information about users of sites directed to children under the age of thirteen (13). For more detailed information please visit MAGGOMEDIA’s COPPA policy.

  1. OTHER WEBSITES

MAGGOMEDIA’s website and the ads we service may contain links to other websites. You should be aware that MAGGOMEDIA is not responsible for the privacy practices of such other websites. You assume full responsibility for your navigation of said websites, which are not owned or controlled by MAGGOMEDIA, and which may have different privacy policies and terms of use. You acknowledge and agree that MAGGOMEDIA has no control over these links and shall not be held responsible for your use of any such websites.

  1. CHANGES TO THIS PRIVACY POLICY

MAGGOMEDIA may amend this Privacy Policy at any time. The amended Privacy Policy will be displayed on MAGGOMEDIA’s site. If MAGGOMEDIA makes any material changes we will notify you by means of a notice posted on this site prior to the changes becoming effective. Please check MAGGOMEDIA’s Privacy Policy regularly to ensure you have read the latest version.

  1. YOUR RIGHTS

Much of the information MAGGOMEDIA hold is purely technical in nature, and relates to the devices that interact with its website or its ads. Information on how to refuse use of this information for interest-based advertising purposes is provided above in the section “Opting Out of Interest-based Advertising”.

In the instances in which MAGGOMEDIA does hold limited personal information about you (such as personal information about your MAGGOMEDIA account), you may request  MAGGOMEDIA  access to said personal information, to correct or update any inaccuracy of the records, to stop sending you direct marketing or to stop using your personal information altogether.

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 MAGGOMEDIA using the details provided below.

  1. YOUR INTERACTION WITH MAGGOMEDIA WEBSITE

10.1 INFORMATION THAT MAGGOMEDIA COLLECTS

If you choose to create an account on the MAGGOMEDIA website MAGGOMEDIA  will collect your username, password, email address, country, and preferred account type when you register.

You may also provide MAGGOMEDIA with other optional information, such as your name, picture, postal address, phone number, social network profiles, questionnaire responses, general business information, and other personal, biographical, or demographic info. This optional information is not necessary for you to use the MAGGOMEDIA site or to maintain an account with MAGGOMEDIA, but by sharing this information MAGGOMEDIA may better serve you and improve your overall website experience.

If you provide the name and email address of a friend or colleague, MAGGOMEDIA will use that information to send the individual a one-time invitation to visit or register with MAGGOMEDIA’s site.

10.2 THE USAGE INFORMATION WE COLLECT

In addition to the personal information described above, MAGGOMEDIA also collects certain information about your usage of the site. Specifically, MAGGOMEDIA’s servers collect the following information automatically about your usage of the site:

  1. The type of web browser you use (e.g. Internet Explorer, Mozilla Firefox, Google Chrome or another)
  2. Where you navigate within the site (e.g. the pages that you visit within the MAGGOMEDIA site)
  3. Your browsing preferences, such as your screen size, resolution and other viewing preferences
  4. The links and adverts that you click on
  5. Information about how you arrived at MAGGOMEDIA’s site (e.g. whether you were directed to our site by a search engine or another third party website)
  6. Information about how you leave MAGGOMEDIA’s site (e.g. which website you visit immediately after visiting MAGGOMEDIA’s site).

MAGGOMEDIA may use cookies to collect and store this information, as described in more detail in the cookie policy.

10.3 HOW DOES MAGGOMEDIA USE THE INFO IT COLLECTS?

MAGGOMEDIA uses the account information and other personal information you provide to manage your account, communicate with you, conduct business with you (e.g. reporting and payment), personalize your experience of the MAGGOMEDIA website, comply with your requests, and inform you about products and services in accordance with your marketing preferences.

MAGGOMEDIA uses your usage information to analyze its 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.

10.4 WHO DOES MAGGOMEDIA SHARE INFORMATION WITH?

MAGGOMEDIA will share your personal information only in the ways that are described in this Privacy Policy. MAGGOMEDIA does not, and will not sell your personal information to third parties.

From time to time, MAGGOMEDIA may need to disclose your information to third parties such as law enforcement authorities or MAGGOMEDIA’s legal advisers, where such information is necessary to comply with applicable laws or regulations; enforce or apply MAGGOMEDIA’s user terms and conditions; to protect MAGGOMEDIA’s rights, or to preserve the safety of MAGGOMEDIA’s users. This may include exchanging information with other companies and organizations for fraud protection.

MAGGOMEDIA may also share your personal information with entities that support MAGGOMEDIA’s business activities (e.g. processing payments or submitting emails to you on MAGGOMEDIA’s behalf), in connection with any merger, a sale of MAGGOMEDIA assets,  a financing transaction or acquisition of all or a portion of MAGGOMEDIA’s business to another entity. Whenever MAGGOMEDIA shares your personal information for the aforementioned reasons, MAGGOMEDIA will ensure that the recipient is bound by all appropriate confidentiality obligations and that it commits to using your personal information only for the purposes for which you originally provided it.

You should also be aware that the information submitted to public areas, such as MAGGOMEDIA’s blogs, may be read, collected, and used by others who access them.

If you interact with social media features on MAGGOMEDIA’s site, such as the Facebook Like button, or use your social network credentials to comment on MAGGOMEDIA’s blog, these features may collect information about your use of this site as well as post information about your activities on this site to your profile page. Your interactions with MAGGOMEDIA’s site through the aforementioned social media features are governed by the privacy policy of the social media companies that provide them.

10.5 INTERNATIONAL TRANSFERS

MAGGOMEDIA may share your information with its 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, MAGGOMEDIA may share your information with its non-EU clients or affiliates). While some countries may not have data protection laws that are equivalent to those of the country in which you reside, MAGGOMEDIA will take all reasonable measures to protect your information in accordance with this Privacy Policy and all applicable legal requirements.

10.6 HOW DOES MAGGOMEDIA KEEP INFORMATION SECURE?

MAGGOMEDIA uses appropriate technical and organizational security measures to protect the information it collects. MAGGOMEDIA uses multiple electronic, procedural, and physical security measures to protect against unauthorized or unlawful use or alteration of information, and against any accidental loss, destruction, or damage to information. However, you acknowledge and agree that no method of transmission over the Internet, or method of electronic storage, is completely, one hundred percent (100%) secure.

10.7 HOW LONG DOES MAGGOMEDIA KEEP INFORMATION?

MAGGOMEDIA retains information for only as long as it is necessary to fulfil the purposes outlined in this Privacy Policy, unless otherwise required by law.

  1. HOW TO CONTACT MAGGOMEDIA

If you have any questions about this Privacy Policy, please contact MAGGOMEDIA  at privacy@maggomedia.com.