Airpush
Technology Privacy Statement

Last Updated: June 15th, 2016

How We Collect Your Data and Data We Collect
How We Use Your Data
How We Share and Combine Your Data
Security and Integrity of Your Data
Cross-Border Transfer
Retention
Your Information Choices
Contacting Us
Enforcement
Privacy Complaints by European Union and Swiss Citizens

This Technology Privacy Statement (“Statement”) explains how Airpush, Inc. and its subsidiaries and affiliates (“Airpush,” “we,” or “us”) collects, uses and shares your information when you install or use a mobile application or visit a mobile website that utilizes our services, including our mobile advertising platform, any of our software development kits, technology, content personalization product, and related services (“Service”).

Child-Directed Sites or Services

We require publishers to use a specific version of our Service in connection with applications that are directed to children under the age of 13.  This child-directed version of our Service collects limited information about users’ devices, such as unique device identifiers and IP address, and we use such information solely for ad-serving purposes, including ad delivery and frequency capping.  If you believe you have a children’s app, please contact: childapp@airpush.com.

Modifications

Airpush may change this Statement from time to time.  If we make any changes to this Statement, we will change the “Last Updated” date above, and in some cases we may provide you with additional notice.  If you have any questions about this Statement, please contact Airpush at privacy@airpush.com.

I. How We Collect Your Data and Data We Collect

A.  How We Collect Data

We collect data through our Service, which utilizes technology such as our software development kit installed in applications and through ad tags or cookies.   Cookies are small files sent to your device when you visit a website.  A cookie allows the site to remember your preferences.  A beacon, pixel or tag is code utilized for tracking. We utilize cookies, beacons, JavaScript tags, pixels, or other similar technology provided by advertisers or us to collect data when you use Applications or interact with ads that integrate our technology.

B. Data We Collect Through Our Service

Our Service enables mobile applications that utilize our Service to serve ads and content from advertisers that is targeted to your interests.  When you download a mobile application that utilizes our Service (each, an “Application”), we may automatically collect certain information from your device on a regular basis, including, but not limited to:

  1. Device identifiers. Unique device identifier, such as Android Advertising ID, iOS Identifier for Advertisers (IDFA), device serial number (IMEI), MAC address, an Airpush-generated ID, SIM Serial number;
  2. Information about your device. Such as device make and model, mobile web browser type and version, and IP address;
  3. Log information. Such as the Application name, cookie information, time zone, and other technical data about your use of your device;
  4. Ad performance and your response. Data about the ad served and how you respond to the ad;
  5. Non-personal data. This non-personal data may be about you or your interests, such as demographic information, including designated marketing area or location, or a list of mobile applications on your device; and
  6. Encrypted email or phone number. With your permission, hashed or encrypted values of your email address and phone number.  We hash or encrypt such information on your device before collecting it, so we do not ever collect your actual raw email address or phone number.  We will maintain such information in encrypted form and will not attempt to re-identify it but may compare it against other hashed values.
  7. Personal and Other Information. With your permission, we may collect browsing activity like list of websites visited, precise geo-location information, zip code, and other information that may be considered personal data in your jurisdiction.

When you install an Application that utilizes our Service, you may also grant the Application permission to collect certain types of information.  We do not control this process – it is typically run by your mobile operating system (e.g., Android or Apple iOS).  Based on the permissions you grant, we may collect some or all of the information that an Application collects.

Your operating system may allow you to restrict the collection of some of the values listed above.

C. Data You Volunteer Through an Ad

When you volunteer personal or non-personal information through an ad, including, but not limited to your name, email, or phone number, to sign up for purposes specified in the ad, such as direct marketing, Airpush will share the information you provide with the advertiser. Data you volunteer through an ad will not be hashed or encrypted prior to sending so that the advertiser may access it.

For such ads, Airpush will require that the advertiser provide their privacy policy within the ad.  Airpush is not responsible for the content of the advertiser privacy policy, advertiser use of your personal information, or any communications to you based upon the data you volunteer.  We encourage you to read the advertiser privacy policy before providing your data to any advertiser through an ad.

D. Notice of Data Collection

We require Application publishers to provide notice to end users of our collection, use, and sharing of information about end users via the Service. However, we are not responsible for any Application’s privacy practices and have no control over how the publisher of an Application collects, uses, or shares your information.  For information about how an Application collects, uses, or shares your information, please see the applicable Application’s privacy policy.

E. Data Collected from Other Sources

We may also obtain information from other sources and combine that with information we collect through our Service or our Website.  For example, we may collect demographic or interest preference information from other companies and combine that with information we collect through the Service for interest-based advertising purposes, fraud detection, or information collected from our Website to send you tailored marketing communications.

F. Third Party Analytics

We utilize third party analytics providers which may use cookies, web beacons and other technologies to collect information about your use of our Website, including your IP address, web browser, pages viewed, time spent on pages and links clicked.

G. Cookie Policy

When we serve ads on the mobile websites, we set cookies for ad serving and opt-out purposes.  We contractually require our partners not to alter or interfere with any technology we provide, including cookies.

guid This cookie has a randomly generated unique ID and is used for ad serving, ad measurement, and payment for ads.
Airpush optout This cookie is set when a user chooses to opt-out of mobile web interest-based ads.

II. How We Use Your Data

We may use information we collect for the purposes described in this Statement, including to:

  1. Carry out, operate and improve our Service and our Website;
  2. Monitor and analyze trends, usage, and activities in connection with our Website and Service, including to provide reports to Application publishers and to advertisers;
  3. Prevent fraudulent transactions;
  4. Provide you with customer service as well as administrative and support service and communication;
  5. Communicate with you about offers, promotions, contests, events, and other products and services by us and our partners;
  6. Combine data to better understand your needs and enhance our products and Services;
  7. Deliver content and ads to your device, such as ads and content tailored to your interests on behalf of advertisers across sites and over time, including via:
    1. push ads, which are displayed in the device notification tray;
    2. icon ads, which are sponsored shortcuts that appear on the home screen of your device; and
    3. in-app ads, which appear within an Application that you have opened on your device.

See “Your Information Choices” below for information about how to opt-out of receiving push, icon, or interest-based ads.

III.  How We Share and Combine Your Data

A. Data Sharing

We may share information about you as follows:

  1. With third party vendors, consultants, and other service providers who work on our behalf and need access to your information to carry out their work for us and may use your information in connection with the provision of such services;
  2. With our payment related vendors and processor to carry out their services;
  3. With advertisers and Application publishers;
  4. With third party companies for various purposes, such as advertising and marketing, ad serving, fraud detection, market research, user trends and adoption measurement, targeting (including retargeting or remarketing), segmentation and interest-based profiling, analytics, and optimization;
  5. In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
  6. If we believe your actions are inconsistent with the spirit or language of our policies, or to protect or enforce the rights, property, and safety of Airpush or others;
  7. In connection with, or during negotiations of, any merger, sale of Airpush assets, financing or acquisition of all or a portion of our business to another company;
  8. Any information, including personal information, you volunteer through an ad may be directly shared with an advertiser; and
  9. With your consent, including if we notify you on the Service that the information you provide will be shared in a particular manner.

When we share hashed or encrypted information with third parties, we will require that they agree not to attempt to decrypt and re-identify this information; however, such information may be matched against other hashed or encrypted values.

B. Combined Offline Data

We and other third parties with whom we share your information may combine your information with data collected offline for various purposes, including but not limited to fraud detection, retargeting, segmentation and interest-based profiling, and interest-based advertising.  For example, a third party may combine the information we share with your offline purchase information to provide you with more relevant advertising.

IV. Security and Integrity of Your Data

Airpush takes reasonable precautions to safeguard the information we collect through our Service in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction.

V. Cross-Border Transfer

Airpush is based in the United States and the information we collect is governed by United States law.  By accessing or using the Service or otherwise providing information to us, you consent to the worldwide processing and transfer of information to the United States and other countries.

VI. Retention

We retain information collected through our Service for as long as we deem necessary to fulfill our business purposes in this Statement and as required or permitted by law.

VII. Your Information Choices

Based on the information we collect, we may require an Application publisher to provide an Airpush privacy notice when you first open the Application.

A. Push and Icon Ads Opt-Out

For push ads, we also label each push ad with the name of the Application that has enabled the distribution of the push ad and the URL of our opt-out web page, where you can opt-out of receiving push ads and icon ads (as described below).

You may opt-out of receiving push ads and icon ads delivered by Airpush in the following ways:

  1. You may install and run the Airpush opt-out application

Download Opt-Out App

Airpush will not use information it obtains during the installation of our opt-out app for any purpose other than to fulfill your opt-out request. Please note that after installing this opt-out app, you may still continue to receive in-app ads delivered by Airpush, including in-app ads that are tailored to your interests unless you opt-out of interest-based ads.

ii. You may provide a device ID, including IMEI, MEID, or ESN, through our opt-out web form:

Manual Opt-Out

For some phones, you may find these device IDs by viewing Menu –> Settings –> About Phone –> Status –> IMEI/MEID/ESN.  Please note that after providing a device ID, you may still continue to receive in-app ads delivered by Airpush, including interest-based in-app ads unless you opt-out of interest-based ads.

B. Interest-Based Advertising Opt-Out and Mobi Data Marketplace Opt-Out

Airpush shares data with its partners to help you receive more relevant advertising that is based upon your interests.  You may receive interest-based advertising on other devices.

     i. Device-Based Opt-Out for Applications

For Android devices, you may signal your desire to “opt-out of interest-based ads” through your device settings.  For iOS devices, you may signal your desire to “limit ad tracking” through your device settings.  If you enable this device-based preference, Airpush will still serve ads, but no longer serve interest-based ads to the device where you exercised this choice.

     ii. Mobi Data Marketplace Opt-Out

For devices opted-in to the Mobi Data Marketplace, you may signal your desire to “opt-out of interest-based ads” through your device settings to opt-out of data collection by the Mobi Data Marketplace.  You may also see a clickable icon (↓) on your device with a link to an opt-out or directions on how to opt-out.

In the event Airpush receives a device-based opt-out preference from you after you have opted-in, Airpush will make reasonable efforts to share your opt-out preference with those third parties with whom Airpush shares data for the Mobi Data Marketplace or other interest-based advertising and marketing analytics, segmentation, or market research.

     iii.  Opt-Out Cookie for Mobile Web

For mobile web, you may opt-out of interest-based ads by installing our opt-out cookie below on your device.  If you have installed this cookie, Airpush will no longer serve interest-based ads to the browser on the device where you have installed this cookie; however, you will continue to see Airpush ads that are not based on your interests.  If you use a different browser, clear your cache, or otherwise clear cookies from your browser, you will have to reinstall this cookie.

Click to Opt-Out

     iv. Third-Party Opt-Out Mechanisms

You may opt-out of interest-based advertising by some (not all) of our third-party advertising partners by visiting:

  1. Network Advertising Choices: http://www.networkadvertising.org/choices
  2. Digital Advertising Alliance: http://www.aboutads.info/choices/
  3. Downloading the Digital Advertising Alliance’s Mobile Application, AppChoices (via app store)
    1. Apple App Store: https://itunes.apple.com/us/app/appchoices/id894822870?mt=8
    2. Google Play: https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en
  4. European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu/
  5. Your Online Choices (Australia):
    1. http://www.youronlinechoices.com.au/opt-out

These opt-out choices only apply to the device from which you have opted-out and applicable advertising channel (e.g. a mobile website opt-out will not work for in-app advertising).  If you reset your advertising identifier, clear cookies on your device or otherwise take an action to affect the opt-out preference, you may have to opt-out again.  Airpush does not control and is not responsible for these third-party opt-out mechanisms and encourages you to read the accompanying policies.

C. Your Privacy Rights

If you are a California resident, then once per year you may request what personal information of yours we share with businesses for direct marketing and for what purpose.  Please contact us at privacy@airpush.com or write the address below to request such information.

D. Collection of Information

To opt-out of Airpush’s data collection from your device or to opt-out of receiving all ads from Airpush, you must manually uninstall all existing Applications on your device that utilize our Service as well as not visit any website from which we collect information.  Please note that if you ever install another Application or visit a website that utilizes our Service or visit the Airpush Website in the future, Airpush will subsequently be able to collect and use your information as described in this Statement.

E. Third Party Sites

If you click an ad or visit an advertiser’s site, any information collected by a third party will be subject to that third party’s privacy practices.  Airpush is not responsible for the privacy practices of such third parties and has no control over how third parties collect, use, or share your information.  We encourage you to visit that site’s privacy policy for more details.

VIII.  Contacting Us

If you have any questions regarding this Statement, please contact us by email at privacy@airpush.com, or by mail at the address below.

Airpush, Inc.
ATTN: Privacy
7900 E. Union Avenue, Suite 1100
Denver, CO 80237

IX. Enforcement

We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.

X. Privacy Complaints by European Union and Swiss Citizens

We comply with the U.S.-EU Safe Harbor Framework and the U.S. Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. We have certified that Airpush adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification, please visit http://www.export.gov/safeharbor/.

In compliance with the U.S.-EU and U.S.-Swiss Safe Harbor Principles, Airpush commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union and Swiss citizens with inquiries or complaints regarding this Statement should first contact Airpush at privacy@airpush.com.

Airpush has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, 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 SAFE HARBOR website at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint:

Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor
3033 Wilson Boulevard, Suite 600
Arlington, VA 22201
U.S.A.

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