Effective: January 1, 2020
Our Services provide advertising and business intelligence solutions to our clients and partners, which include working with publishers, advertisers, data partners, and third party ad exchanges across a network of mobile applications (“Apps”) and websites (“Sites”). We provide UberMedia advertising optimization and measurement tools to advertisers and publishers and We utilize data science and technology to provide a variety of businesses with useful reports, analytics and information. The Services use our proprietary technology to understand mobile location information for providing businesses with insights, analytics and research.
HOW IS INFORMATION COLLECTED
UberMedia is able to collect first party data directly from individuals (“Users” or “Data Subjects”) of its mobile apps such as Echofon and UberSocial and from mobile apps of its publisher partners that utilize an UberMedia SDK. UberMedia owned apps and publishing partners utilizing an UberMedia SDK are required to notify users and gain consent that the data is being captured and will be shared with third parties.
Our technology collects information about the geolocation of mobile devices. We receive geolocation data from mobile devices (using the manufacturers’ advertising device id) provided by mobile App publishers (via SDK or other methodologies), other media supply sources in conjunction with the opportunity to purchase advertising inventory, and via data providers. We may collect this information over time and across websites, mobile apps and devices. We also purchase data sets from select third parties where we get sufficient comfort that the data was obtained in conformance to current privacy regulations. When we receive geolocation data, we rely upon the mobile app publishers and other media supply sources that are responsible for enabling your connection to our Services to request and obtain consent for the collection and use of your geolocation data. You may also control your mobile device directly by enabling or disabling your location settings on your device.
WHAT INFORMATION IS COLLECTED
When Users visit an App that uses our SDK or the SDK of our partners, We and the partners will collect certain information about devices. Some of the this information may identify a particular device and may be “personal information” under some jurisdictions. PI, Personal Information, as the term used in the United States, or Personal Data as referred to pursuant to the European Directives 95/46/EC and 2002/58/EC (EU General Data Protection Regulations Legislation, also known as “GDPR”) (hereinafter “PI”) has different definitions. Different regulations around the world may use different terminology and apply a different description of what information is considered personal information, so we encourage you to visit our jurisdictional specific pages as applicable (i.e. GDPR Notice).
Generally we try to minimize the PI we collect (“Non-PI”). Non-PI includes: information such as type of browser used (Chrome or Safari), device model and operating system information and version (e.g. iOS ver 10 ), language preferences, as well as other aggregated and de-identified information.
The information we collect from devices that may be considered PI are:
- Unique device Identifiers: The unique IDs that we collect are IDFAs for iOS, and Android Ad IDs for Android
- IP addresses and general location data that can be extrapolated from an IP address level (city or postal code)
- Information about a User’s interaction with advertising on Apps (advertising click-stream information such as type of ad, type of App, where served, whether User clicked on ad)
- Latitude and longitude geolocation information if a User has provided consent from the relevant App and enabled the mobile device to share location information. If you have previously given consent for collection of geolocation information, You are always free to turn off geolocation (or limit it to certain mobile applications) or to adjust your advertising settings on your device
For clarity, and without limiting the above, we do not collect information that directly identifies a natural person, including the following information, among other information: names, email addresses, cell phone or home phone numbers, login passwords, social security, drivers licenses. We also do not collect financial or other sensitive information.
PIXELS, COOKIES AND OTHER PERSISTENCE TOOLS
Our Services may use persistent cookie-like tools on mobile devices to enable us to measure the effectiveness related to serving advertising and for business intelligence about the activities of Users on Apps and Sites. You are free to set your consents on the settings of your browser, operating system and device to de-activate the ability to identify your device persistently. Please refer to these settings for more information on how to disable your browser or operating system from receiving cookies and controlling your preferences, including to disallow sharing of device level information or to disable geolocation access.
HOW INFORMATION WE COLLECT IS USED
Our Services include business intelligence services, which involve robust data information and reporting to clients. We use our proprietary tools to transform raw mobile device information collected as described above, including geolocation information, into useful insights for our clients. We utilize our data science technology to provide our clients with trend and statistical analyses, such as identifying patterns that will enhance the relevance of ads, providing advertisements to certain types of audiences, identifying and optimizing trade areas and business locations, and for helping our clients make informed business decisions about consumer behavior with trend and movement information. We provide insights, patterns and commonalities to help our clients understand trends and make evaluations about the products and services they offer, such as informing a Partner’s real estate decision about where to locate a store.
With respect to the manufacturer advertising device identifier (MAID) we collect, we store it in our systems as an anonymized, hashed id. Much of the information is further anonymized into aggregated files and use of data points without unique identifiers or only with a hashed identifier. The geolocation we collect is also randomly jittered as another step in making the data less personal. We sell hashed device identifiers with jittered geolocation information to clients and partners that utilize our business intelligence Services. This information is used in a number of ways to offer such clients information about business trends, reports, patterns. Our policy is to sell unhashed MAIDs only to clients who need such for cases of targeting advertising, measurement and matching.
UberMedia does not collect data or create data segments that are based upon what we consider to be sensitive information (for example, we don’t create segments to determine religion or credit worthiness). UberMedia may create health-related segments such as an inferred interest in diet and wellness, but not sensitive health data such as medical conditions or diseases. All of our clients who purchase our Services are required to conform to applicable privacy regulations as well as our contractual requirements. UberMedia prohibits the use of its Services by others for DAA proscribed uses ((a) employment, credit or health care eligibility; (b) insurance eligibility, underwriting, or pricing; (c) unlawful tracking or surveillance of individuals or for generating personally identifiable information. As a matter of policy, beyond legal requirements, UberMedia does not sell its data products to law enforcement agencies for use in law enforcement activities or to monitor the movement of individuals or groups.
Our Services also include advertising services that allow us to help our advertising and publishing clients provide more relevant advertising and content on the Sites and Apps on our Network. In general, we use the information collected from and about you and from partners to enhance our advertising services by providing ad content that is more closely related to your interests. For example, the information is used to create audiences that are grouped together based on shared preferences (e.g., Sports Fans, car enthusiasts, movie goers) and to measure the effectiveness of ad campaigns. Data used to create online audiences is de-identified, helping ensure that neither the ad server nor our cookies contains PI, but will include a mobile advertising device id. We may assign an UberMedia ID to your browser, computer or mobile device when we serve an ad to it or we identify it on a client’s website or mobile app. The UberMedia ID and other information collected via the Services can also help our advertising clients measure the effectiveness of advertisements delivered via the Services. They enable the Services to determine within a reasonable level of confidence that a computer or device is the same as one with which the Services has previously interacted. For instance, the Services can determine that a computer or device to which we served an ad on Monday may be the same computer or device for which we observed a purchase on Tuesday. In other words, in such cases we are able to infer that a device (e.g. your computer) and another device (e.g. your smartphone) are used by the same owner. Where we are able to make such inferences, we may use this information to deliver targeted ads across multiple computers or devices. This is sometimes referred to as cross-device advertising.
The ad network providers we work with will only pass MAIDs and other information to Us if consent has been obtained from Users. The publishers of the Sites and Apps request consent from individuals using the Site or Apps and upon our ad exchange partners in passing the information to us. In addition, for advertising targeted to Users in the EU, Uk, and Switzerland, UberMedia is an approved status vendor and participates in the IAB Europe Transparency and Consent Framework (see more at https://advertisingconsent.eu/about/). Legally sufficient consent is obtained using this framework from those publishers whose Apps utilize the framework. In addition, You have the ability to withdraw consent at any time by contacting the publisher of the relevant App or Site and checking your privacy settings on your devices and with the Apps and Sites you visit from time to time.
WHEN WE SHARE INFORMATION
UberMedia shares PI and Non-PI that we collect with advertisers, clients, customers and partners as described above. We may also share PI information, for the following purposes:
- during due diligence or in preparation for or after a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation.
- with those entities that are helping us make the Sites, Apps, and Services available and functional, like technical agents, payment processing vendors, other subcontractors, and our affiliates and consultants under contract and with safeguards. These functions include, for example, web site hosting, maintenance, data analysis, customer support, email delivery services, infrastructure services, technical agents, analytics and metrics services. These third parties will be restricted in the way they can use PI and will need to keep your information confidential and secure.
- if permitted or required by law or where we believe such action is necessary in order to protect or defend our interests or the interests of our users, clients, partners, or business partners.
- When businesses (not consumers) subscribe to our Services, the order process may request a credit card transaction. Order information is encrypted when it is transmitted for credit card processing to the credit card services provider and when returned to us. Encryption is a process by which we use software to scramble information in transit. We use a third party service provider to process payments for our Services, so your credit card information is not collected and retained by Us.
- We may disclose your PI to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). If we have to disclose PI to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of PI.
WHAT ARE MY CONSUMER CHOICE/DATA PROTECTION/OPT OUT RIGHTS
For personal information access, opt out and deletion requests with respect to any PI processed by UberMedia, and for personal data of data subjects for residents of EU, UK and Switzerland, you can follow the instructions on our Consumer Choices page. Please note that we will need your Mobile Ad ID in order to identify your device in our systems.
While CCPA only covers California residents, We voluntarily extend its core rights for people to control their data to all of our users across the United States, not just those who live in California.
All of the User Information is kept on servers that UberMedia manages, using reasonable administrative, technical and physical safeguards designed to protect against unauthorized access or disclosure of data. Please be aware that no data transmission over the Internet or information contained in our servers can be guaranteed to be 100% secure. As a result, while we strive to use commercially acceptable means to protect information, we cannot guarantee or warrant its security.
We do not knowingly collect or distribute information from or about children under age 13 (or up to age 16 in certain countries). If you believe your child has provided UberMedia with PI, such as by registering at one of our Apps without parental consent, and you would like to have the data removed, please contact us using the contact information below.
EUROPEAN UNION, UK AND SWITZERLAND ADDITIONAL NOTICE
If you are a resident in the European Economic Area and want to find out more about your data protection rights, please see our separate section called “EU Privacy Notice – GDPR.”
WHO WE ARE. CONTACT US
Or you can contact us by mail at:
130 West Union Street
Pasadena, CA 91103
Attn: Privacy Officer