Privacy Policy - Mintegral

Privacy Policy

August 26, 2020

Mintegral entities (for purpose of European data protection laws, Mintegral entities providing Mintegral Service which are subject to GDPR can be viewed HERE, collectively, “Mintegral”, or “we”, “us”, “our” ) 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. This privacy policy (“Policy”) covers Mintegral’s handling of two types of information:

  • (1)Information we receive about end users of third-party mobile applications (“Apps”) that use our Software Development Kit (“SDK”), Application Programming Interface (“API”), Demand Side Platform (“DSP”) or other services or technologies (collectively, the “Mintegral Services”), users that use Mintegral Services (Collectively “User”, “you” or “your”), and information we receive about Users while Users interact with platforms, applications, websites or other services provided by Mintegral’s business partners (e.g. app publisher, advertiser);
  • (2)Information we receive through our website at www.mintegral.com, www.mintegral.net or any other website on which this Policy is posted, as well as information we get through other corporate services and web portals we make available to clients and business partners (“Mintegral Sites”, “Website”, “Site”) from Mintegral Website visitors (“Visitors”, “you” or “your”).

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, understood and agreed to 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.

Data protection and ensuring our business partners’ and your trust is at the core of Mintegral’s business principles. Accordingly, being compliance with applicable data protection laws is our top priority and this Policy is updated to be compliance with the applicable data protection laws, including EU General Data Protection Regulation (“GDPR”), the Children’s Online Privacy Protection Act (“COPPA”), the California Customer Privacy Act (“CCPA”) and the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais) (“LGPD”).

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. 
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.  

Where Mintegral acts as supplied side platform (“SSP”), we or our business partners may collect your personal information including the following: device make, device model, operating system (e.g.iOS) and the OS version of the device, device type (e.g. smartphone, tablet, etc.), device properties related to screen size, orientation and battery, carrier, name, properties and version 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, network provider, SDK version, timestamp, API key (identifier for application), network status such as WiFi, the identifier for advertiser (e.g. IDFA), international mobile equipment identity (IMEI), 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.

Where Mintegral acts as Demand Side Platform (“DSP”) serving ads to Ad Exchange, we or our business partners may collect your personal information including the following: device properties related to screen size & orientation, device make, model, operating system, operating system version, device type, name and properties of mobile application through which a consumer interacts with the Mintegral Services, carrier name, network connection type, IP address, Internet browser user-agent used to access the Mintegral Services; country, time zone and locale settings (country and preferred language) and identifier for advertisers (e.g.IDFA).

Notwithstanding the forgoing, Mintegral will only collect your personal information which are transferred from our partnered Ad Exchange through their ad request. Mintegral will not collect any information beyond the scope of the information transferred from our partnered Ad Exchange through their ad request.

We provide Mintegral Service for our business partners such as mobile application developers and advertisers. We may collect name, job title, email address, account name and password, IP address and address of individuals using Mintegral Services on behalf of  our business partners, such as employees of our mobile application developers or advertisers.

4. How We Use Users’ Personal Information

Your device might be distinguished from other devices based on information it automatically send, such as IP address or browser. Your device may be identified based on a scan of your device’s unique combination of characteristics. Identifier for Advertiser or other information may be stored or accessed on your device for purposes presented to you under this Policy. Your device can receive and send information that allows you to see and interact with ads and content. We use your personal information to display ads on your device. Ads may be shown to you based on the content you’re viewing, the app you’re using, your approximate location, or your device type. We may build profile about you and your interest and to show you personalized ads or behavioral ads which are relevant to you and customized to your inferred interests, preferences, locations and other features based on profile about you. Where required, our business partners (e.g. publishers) will obtain User consent for and on our behalf for our processing of User personal information for profiling and displaying ads, including personalized ads or behavioral ads, 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 measure the performance and effectiveness of ads that you see or interact with, including measuring the traffic quality in order to perform our contractual obligations to our business partners; (ii) to understand and analyze your usage trends and preferences, improve our Mintegral Service, and to develop new products; (iii) for purpose of monitoring and preventing fraudulent activity, and ensuring systems and processes work properly and securely. 

We may also collect and use personal information of Users who are representing our business partners to use Mintegral Service (e.g. employees of our publishers or advertisers) for purpose of business contact and direct marking (e.g. sending marketing emails). Where required, our business partner will obtain such Users’ consent for and on our behalf for our processing of their personal information.

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 the performance and effectiveness of ads that User see or interact with, including measuring the traffic quality in order to perform our contractual obligations to our business partners (e.g. advertisers), and to prevent fraudulent activity.. These business partners may use the Users’ personal information to measure Users’ ad/site interaction and evaluate the performance and effectiveness of ads that User see or interact with, 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 use third party technical service providers (e.g. cloud service provider) to process the Users’ personal information for purpose of ensuring systems and processes work properly and securely, and for purpose of data storage.

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 through our Mintegral Service, will be transferred to recipients in countries located outside the EEA, including in China, US and countries which may not be decided by the European Commission that it provides an adequate level of protection to personal information. Where required by law, the publisher and/or advertiser will obtain your consent to the transfer of your personal information to Minegral, Mintegral’s affiliates, and/or any 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 as permitted by GDPR): (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.

If you are residents of the State of California in the United States, effective from January 1, 2020, you have a right to:

(i) exercise certain consumer rights such as request to know, disclose, access or delete your data, collected in the last 12 months, by writing to us at privacy@mintegral.com; and (ii) opt out of selling of your data by clicking on the following link: DO NOT SELL MY DATA.

Guidance of Opt out

You can opt-out from receiving interest-based advertising or behavioural advertising from Mintegral on supported devices following the guideline below.

  • • Your iOS mobile device may provide a «Limit Ad Tracking» setting. On Android devices, your settings may allow you to «Opt out of Interest-Based Ads.» When you have opted out using this setting on a device, Mintegral will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests.

  • • Your mobile web browser may also provide a «Do Not Track» browser setting. When you have enabled this setting in your browser, Mintegral will not use mobile web browsing information from that browser to infer your interests or serve ads to that device that are targeting based on your inferred interests.

If you have question about your data 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 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 comply with the Children’s Online Privacy Protection Act (COPPA). Publishers with apps directed to children under the age of thirteen (13) must enable the COPPA settings when using the Mintegral Services. This allows Mintegral to ensure that any persistent identifiers collected about Users of apps that are flagged as “child-directed” will be processed according to the requirements of COPPA, including not being used to serve behaviorally-targeted ads or track users for such purposes. In addition, we will not knowingly collect any other personal information (such as the precise geo-location of Users’ devices) from Users of Apps that we know to be directed to children under the age of thirteen (13).

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), or passively collected (which you did not actively provide) such as your browser type, domain name, IP address, pages visited, and the length of your user session using various technologies and means, such as Internet Protocol Address, cookies, Internet Tags and navigational data collection. 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.

We may also use Google Analysis that assists us with analysing the usage of our website and help to improve the service quality of our website. For the personal information that may be collected by Google Analysis and its processing activities, please visit: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631.

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 personalize 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.

We may also contact you periodically by e-mails 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.

4. Disclosure of Your Personal Information

We may use selected third parties to provide us with services who may have access to your personal information, including companies that assist with programming and technical aspects of hosting and operating the Mintegral Site, technical service provider (e.g. Google Analysis) that assists with analyzing the usage of our website, or email service provider. 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, reorganization or otherwise.

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, reorganization 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 and other countries which may not be decided by the European Commission that it provides an adequate level of protection to personal information. You hereby expressly consent to the transfer of your personal information to recipients including Mintegral’s affiliates and any other 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.

If you are residents of the State of California in the United States, effective from January 1, 2020, you have a right to:

(i) exercise certain consumer rights such as request to know, disclose, access or delete your data, collected in the last 12 months, by writing to us at privacy@mintegral.com; (ii) opt out of selling of your data by clicking on the following link: DO NOT SELL MY DATA.

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 this Privacy Policy of Mintegral Website.

9. 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. Please read our Cookies Policy for more details.

10. 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.
11. 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.
12. 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.
13. 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.
14. 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.

Mintegral Cookies Policy

What are cookies?

Cookies are small text files that websites place on your device as you are browsing. They are processed and stored by your web browser, and can typically be read on your future visits.

In general, there are four types of cookies based on what purpose they serve.

  • Strictly necessary cookies — These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site.
  • Preferences cookies — also known as “functionality cookies,” these cookies allow a website to remember choices you have made in the past, like what language you prefer, what region you would like weather reports for, or what your user name and password are so you can automatically log in.
  • Statistics cookies — Also known as “performance cookies,” these cookies collect information about how you use a website, like which pages you visited and which links you clicked on. Their sole purpose is to improve website functions. This includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited.
  • Marketing cookies — These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad.
What type of cookies does Mintegral use?

Mintegral only uses the following two type of cookies for the following purposes.

  • Preferences cookies- Mintegral solely uses the preferences cookie to remember your set-up in the past in order to optimize the information presented to you.
  • Statistics cookies- Mintegral also uses third party cookie of Google Analytics for purpose of helping us understand how the website is being used. Google Analytics collects first-party cookies, data related to the device/browser, IP address and on-site/app activities to measure and report statistics about user interactions. Google uses Google Analytics to provide the Google Analytics measurement service to Mintegral. For more information about the Google Analytics cookies, please read here .
Opt out

To opt out of our cookies used to remember the language you select when you visit our website, please find the guidance of managing and deleting cookies via www.allaboutcookies.org. To opt out of the third party cookie of Google Analytics, please click here .

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:

Room 1204, 12/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.

By clicking “Accept”, you agree us to use Cookies to optimize the information presented to you, and analyze the traffic of our website. If you want to opt out of our cookies, please read our Cookies Policy for your guidance.