Privacy Shield Framework Notice
Effective as of September 30th, 2016
Conformance to Principles
Airpush, Inc. adheres to the U.S.-EU Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Economic Area (EEA) member countries as to personal data submitted by Airpush customers, publishers/developers, or collected by Airpush through its products and services. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
Personal Data Collection
From our website, we collect any information that you actively provide us by signing up as an advertiser or publisher. Although each user decides what to provide, this data typically includes email address, phone number, name, address, billing details, payment information, social security number, tax ID number, demographic, or other information you choose to provide us. For all visitors, our website also passively collects log information, including your IP address.
From our products, we collect personal data:
(i) with your consent, when you input personal data through an ad hosted by us. This data may include name, email address, or other personal data you decide to submit that is requested by an advertiser.
(ii) with your consent, via an opt-in notice. This data may vary based on which version of our product a publisher uses and typically includes: your hashed email address or phone number (always kept in hashed form); unique identifiers, such as device identifier, IMEI, device serial numbers, and advertising identifier; zip/postal code; list of sites visited in your browser; and precise geolocation.
(iii) any time a publisher integrates our products, this typically includes log information, including IP address and advertising identifier.
Purposes for which we collect Personal Data
For personal data collected via our website, we use collected information to: operate and improve our site and products; process payments; carry out our advertising services and related operations; provide customer service; monitor and analyze trends, activity and usage of our site, products and services; communicate with you about marketing, news, and products offered by us and our partners; and analyze your needs and provide you better service.
For personal data collected via our products, we use collected information to: carry out, operate and improve our products and services; deliver content and advertising to your device, such as interest-based ads across sites and devices; prevent fraudulent transactions; provide customer support to you and our customers or partners; communicate with you about marketing offers by us and our partners; and with combined data to better understand your needs and enhance our products and services.
In compliance with the U.S.-EU Privacy Shield Principles, Airpush commits to resolve complaints about your privacy and our collection or use of your Personal Information. EEA residents with inquiries or complaints regarding this Statement should first contact Airpush at firstname.lastname@example.org.
Airpush has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Airpush, please visit the BBB EU PRIVACY SHIELD website at http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint or write to:
Council of Better Business Bureaus, Inc.
BBB EU Privacy Shield
3033 Wilson Boulevard, Suite 600
Arlington, VA 22201
Third parties that receive Personal Data
For personal data collected via our website, we may share some or all such personal data with our chosen service providers, which carry out our services, and provide support, such as technical assistance, analytics, and payment processing, such as Tipalti.
For personal data collected via our products and services, Airpush shares data with third party vendors and service providers to carry out our services and with third parties for analysis and marketing purposes, including ad serving, retargeting, segmentation, interest-based profiling, analytics, optimization, market research and trend analysis by these third parties and their customers.
Choice, Access, and Means to Limit Disclosure
If you are an EEA resident, you have the right to access your data and limit use and disclosure. For personal data collected via our site, you may log into your account and access your data.
For personal data collected via our services, you may limit collection and third party disclosure through your signal your desire to “opt-out of interest-based ads” or “limit ad tracking” through your device settings. Depending on the product, this may opt you out of all or some personal data collection by Airpush. In the event that Airpush receives this signal from your device, Airpush will reasonable efforts to share your opt-out preference with those third parties with whom Airpush shares data. If you have any other questions about accessing your data, please contact Airpush at email@example.com.
Subject to FTC Jurisdiction
Airpush’s adherence to the Privacy Shield Principles is subject to the regulatory and enforcement powers of the Federal Trade Commission.
Airpush may be legally compelled to disclose personal data to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.