Privacy Policy - Mintegral

PRIVACY POLICY

May 7th, 2018

Mintegral entities (collectively referred to as "Mintegral", "we", "our" or "us") provide this privacy policy to explain how we collect, use, and share information. For the purposes of European data protection laws, Mintegral is the data controller of your personal information (such entities can be viewed HERE). This privacy policy ("Policy") covers Mintegral's handling of two types of information:

This Policy is subject to any service agreement between Mintegral and you. By using the Mintegral Service or Mintegral Site, you acknowledge that you have read, and understood this Privacy Policy. Please review this Privacy Policy before using the Mintegral Service or the Mintegral Site.

We evaluate this Policy and procedures to implement improvements and refinements from time to time. If we make material changes to this Policy we will notify you by means of a prominent notice on Mintegral Site prior to the change becoming effective.

Privacy Policy of the Mintegral Services

1. Introduction

This Policy applies to information collection and use by Mintegral while Users: (i) view ads served by the Mintegral Services;(ii) interact with the Mintegral Services; or (iii) interact with platforms, applications, websites or other services provided by Mintegral's business partners (e.g. app publisher, advertiser).

Our technology enables our partners to show Users more relevant advertising that is based on Users' interests and behaviors. In order to provide Mintegral Services, we may collect and use certain information about User activity and preferences. We understand how important it is to keep such User's personal information confidential and discrete, especially in today's online world. To this end, we have designed this Policy in a format that is easy to navigate and read so that our privacy practices can be clearly understood.

The Mintegral Services may link to third party websites, Apps or other third party content. Please note that we cannot control the treatment of a User's information by such third parties, and that the privacy practices of third parties likely differ from those described in this Policy.

2. How We Collect Users' Information
Depending on the nature of a User's interaction with the Mintegral Services, or any service provided by Mintegral's business partners, we may collect information directly from such User or from our business partners (e.g. mobile application developers, Ad Exchange platforms, and advertisers). For example, when we partner with an Ad Exchange platform and the Ad Exchange platform initiates an ad request to our DSP, it may share User's information with us. Where required, the publisher will obtain User consent for and on our behalf for the processing of User personal information to display advertising on a User's device. A User can withdraw their consent at any time. In addition, we may acquire information from other trusted sources to update or supplement the information that the User voluntarily provides to us or that we collect automatically or collect from our business partners (e.g. mobile application developers, Ad Exchange platforms).
3. Information We May Collect From Users

When you view ads served by Mintegral Service or interact with services provided by Mintegral's business partners, we and/or our business partners may collect your information including the following:

Device make, device model, operating system (e.g.iOS), device type (e.g. smartphone, tablet, etc.), device properties related to screen size, orientation and battery, carrier, name and properties of mobile application through which a consumer interacts with the Mintegral Services or services provided by Mintegral's business partners, country, time zone and locale settings (country and preferred language), network connection type, IP address, Internet browser user-agent used to access the Advertising Services, identifier for advertisers (IDFA), network provider, SDK version, timestamp, API key (identifier for application), application version, iOS Identifier for advertising, OS version of device, 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), GAID, etc., international mobile equipment identity (IMEI), Internet (IP) addresses or geo-location data, the content type of the ad (what the ad is about, e.g. games, finance, entertainment, news), the ad type (e.g. whether the ad is a text, image, or video based ad), device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.

We provide Mintegral Service for our mobile application developers through Mintegral. We may collect the email address, account name and password, IP address and address of individuals using Mintegral on behalf of our mobile application developers.

4. How We Use Users' Personal Information

We use your personal information to display advertising on your device, which may include interest-based advertising customized to individuals' inferred interests, preferences, locations and other features. Where required, the publisher will obtain User consent for and on our behalf for the processing of User personal information to display advertising on a User's device. A User can withdraw their consent at any time.

Where necessary in our legitimate interests we use your personal information: (i) to understand and analyze your usage trends and preferences and improve our Mintegral Service; or (ii) for purpose of anti-fraud and traffic quality monitoring in order to perform the contractual obligations to our business partners.

We may also use personal information about Users to comply with applicable laws, regulations or codes of practice, and to protect our legitimate interest and protect the rights or property of us or any other third parties.

5. Disclosure of Users' Personal Information

We may disclose the User's personal information to our business partners, including our advertisers, to report the measurement of Users' interactions with the Apps, and for anti-fraud and traffic quality monitoring in order to perform the contractual obligations to our business partners (e.g. advertisers). These business partners may use the Users' personal information to show Users relevant ads, measure Users' ad/site interaction, identify Users' interest areas, better understand the site and app traffic usage or User behavior in order to improve their services. Our business partners' use of the information that we disclose to them will be governed by their privacy policies.

We may also share aggregate or anonymous information with other third parties in accordance with the terms of this Policy.

Our affiliates may also have access to Users' personal information for the purposes set out in this Privacy Policy.

We may share Users' personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer Users' personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganisation or otherwise.

6. International Transfers

When you are located in the EEA, personal information collected from you, including though our Mintegral Service, will be transferred to recipients in countries located outside the EEA (including in China, US, India, Korea, Singapore, Australia, Japan, Canada, France, Ireland, London, Germany, Brazil), which do not provide a similar or adequate level of protection to that provided by countries in the EEA. Where required by law, the publisher and/or advertiser will obtain your consent to the transfer of your personal information to recipients, as described in this Privacy Policy, which are located outside the EEA. You may withdraw your consent at any time.

Mintegral has entered into EU standard contractual clauses ("Model Contracts") for intra-group transfers of personal information to its affiliates. You can request a copy of these Model Contracts by submitting your request via email to privacy@mintegral.com.

7. Your Data Rights

If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of you personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.

To exercise this right please contact privacy@mintegral.com.

8. Security of Users' Personal Information

The security of User's information is our utmost priority, and we take strict measures in order to protect our data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for User's information. Physical access is strictly controlled both at the perimeter and at building ingress points by our staff utilizing video surveillance and other electronic means.

We also protect User's privacy by seeking to minimize the amount of sensitive data and PRI that we store on our servers in the first place. We also seek appropriate contractual protection from our partners regarding their treatment of user data.

Mintegral may retain the information relating to you collected from our business partners as necessary for the provision of the services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

9. Children

We ensure that we complies with the Children's Online Privacy Protection Act (COPPA), and does not knowingly collect personal information about Users of Apps directed to children under the age of thirteen (13). For more detailed information please visit our COPPA policy.

If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.

10. Marketing

We may contact you periodically by e-mail to provide information regarding our products, services and content that may be of interest to you. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.

If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the communications or request to be opted-out of receiving such communications via email to privacy@mintegral.com.

Privacy Policy of Mintegral Website

1. Introduction
This Privacy Policy of Mintegral Website applies to information collection and use including while you are visiting and using the Mintegral Site. For the purposes of European data protection laws, Mintegral is the data controller of your personal information.
2. What Information We Collect
As you navigate through this Mintegral Site, some of your personal information may be actively collected (for example, names, birth dates, personal ID card numbers, addresses, telephone numbers, E-mail addresses, occupations, education, work experience and related information). In order to improve our service quality, it may be necessary to ask for personal information to fulfil your requests and provide a better service. Mintegral is entitled to take measures to validate the authenticity of personal information you provide. If you give us personal information of somebody else, we will assume that you have their permission to do so. Transmissions to and from this Site may not be confidential and consequently, may be read or intercepted by others.
3. How We Use Your Information
The provision of personal information by you may be necessary where in our legitimate interest for the following purposes: (i) to provide you with Mintegral products or services or information in relation to the same,; (ii) to sign you up for an event or training; (iii) to contact you and respond to your requests and enquiries; (iv) for business administration, including statistical analysis; (v) to personalise your visit to the Mintegral Site and to assist you while you use the Site; or (vi) to improve the Mintegral Site by helping us understand who uses the Site.
4. Disclosure of Your Personal Information

We may use selected third parties to provide us with services, including companies that assist with programming and technical aspects of hosting and operating the Mintegral Site, who may have access to your personal information. Our affiliates may also have access to your personal information including through or in connection with this Mintegral Site for the purposes set out in this Privacy Policy.

The servers used in the operation of the Mintegral Site automatically identify a computer by its IP address. Although, we will not be able to identify the computer using its IP address once you have left the Mintegral Site. If we, in good faith, determine that you have or are attempting to misuse or harm the Site, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property.

Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganisation or otherwise.

5. International Transfers

When you are located in the EEA, personal information collected from you, including via the Mintegral Site, will be transferred to recipients in countries located outside the EEA (including in Singapore where the Mintegral Site is hosted) which do not provide a similar or adequate level of protection to that provided by countries in the EEA. You hereby expressly consent to the transfer of your personal information to recipients, as described in this Privacy Policy, which are located outside the EEA.

Mintegral has entered into EU standard contractual clauses ("Model Contracts") for intra-group transfers of personal information to its affiliates. You can request a copy of these Model Contracts by submitting your request via email to privacy@mintegral.com.

6. Your Data Rights

You have the right to access, modify, correct or delete any personal data which we may have collected. To exercise this right please contact privacy@mintegral.com

If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.

7. Security of Your Personal Information

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. We will only keep your personal information for as long as necessary and in any event in relation to personal information collected by us on the Site we will only keep this personal information for one (1) year. For personal information collected via Google Analytics the following retention periods apply:

https://support.google.com/analytics/answer/7667196?hl=en

8. The Protection of Minors
The Site does not knowingly collect any personal information from minors. The personal information of any minor you provide shall be agreed by the minor's parent or guardian in advance. Minor is defined in accordance with the laws applicable to the Privacy Policy.
9. Marketing

We may contact you periodically by e-mail to provide information regarding our products, services and content that may be of interest to you. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.

If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the communications or request to be opted-out of receiving such communications via email to privacy@mintegral.com.

10. Use of Cookies and Other Tracking Technologies
Mintegral may use cookies or other technology (collectively "Cookies") to collect certain information about you when you are visiting the Site. Cookies is a small text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. The purpose of Cookies is to provide a convenience feature to save your time. By using the Site, you consent to the use of these Cookies. If you do not accept these Cookies, you can change your browser's settings to delete cookies that have already been set and to not accept new Cookies. Please however note, that, if you delete Cookies or do not accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly. To find out more about Cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.
11. Outside Sites and Linking
The Site may contain links and pointers to other sites on the Internet that are owned or operated by third party vendors and other third parties (the "Outside Sites"). Mintegral is not responsible for the availability of, or the content located on or through, any Outside Site, including any webcasting or other form of transmission received from any Outside Sites. You should contact the site administrator or Webmaster for those Outside Sites if you have any concerns regarding such links or the content located on such Outside Sites. Mintegral permits certain third party links to the home page of its Site, provided that Mintegral is provided with notice of such links and does not thereafter object to such linking. Mintegral a reserves the right to revoke unilaterally any consent that it may at any time give to any linkage, including linkages to the home page. The Outside Sites are being provided to you only as a convenience and any link or pointer contained on this Site does not imply endorsement of the Outside Sites.
12. Copyright
All Site content, design, text, graphics, images, logos, buttons, icons, interfaces, audio and video clips, and the selection and arrangements thereof are the exclusive property of Mintegral, or its respective content providers, and are protected by Hong Kong SAR and international copyright laws. All software used on the Site is the property of Mintegral or its respective software suppliers, and such software is protected by Hong Kong SAR and international copyright laws and other applicable laws and treaties. Users of this Site shall not transmit/post any information to this Site that infringes the copyright or other intellectual property rights of others.
13. Trademarks
All trademarks, service marks and trade names used on the Site (collectively the "Marks") are solely owned by Mintegral. The Marks may not be used in connection with any product or service that is not a product or service of Mintegral or that is likely to cause confusion among customers, or that in any manner disparages or discredits Mintegral.
14. Online Conduct
Any conduct by a person that in Mintegral's sole discretion restricts or inhibits any other person from using or enjoying the Site, is prohibited. You agree to use the Site only for lawful purposes and in accordance with that prohibition. You agree that you will not post on the Site or transmit any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, sexually explicit, profane, hateful, racially, ethnically, or otherwise objectionable material of any kind, including, but not limited to, any material that encourages conduct that would constitute a criminal offense, give rise to civil liability or otherwise violate any applicable local, state, national, or international law.
15. Termination of Usage

Mintegral may, without incurring any liability to you, terminate access by you or suspend any access to all or part of the Site, without notice, for any conduct that Mintegral, in its sole discretion, believes is in violation of any applicable law or this Agreement, or is harmful to the interests of another user, a third-party, a merchant, a sponsor, a licensor, a service provider, or the Site.

Due to the rapidly evolving technologies on the Internet, we may occasionally update this policy. All revisions will be posted to this website www.mintegral.com.

Contact Us

If you have any question or comment about this Policy, please contact Mintegral's Data Protection Officer at privacy@mintegral.com. You can also write to the data protection representative Eurocore B.V. in the EEA at:

Hullenbergweg 278, 1101BV Amsterdam

You can also write to Mintegral International Limited at:

RM701A, 7/F.,
OfficePlus @Prince Edward,
794-802 Nathan Road, KL,
Hong Kong 999077

Please be sure to include your personal name (and the full company name, if you are inquiring on behalf of such company), address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.