ADDENDUM FOR CALIFORNIA RESIDENTS:
CALIFORNIA PRIVACY RIGHTS

Last Modified:  Jan 31, 2020

NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] - CALIFORNIA CONSUMER PRIVACY PROTECTION ACT

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services. This Addendum supplements the information in the Privacy Policy . However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.

In the below tables and sections, we describe (as required by the CCPA):

1.   Our Collection of Personal Information  – the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from,

2.   Our Disclosure and Sale of Personal Information  – the types of recipients to whom we disclose or sell Personal Information.

3.   Our Business Purposes  -  our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.

4.   Your California Privacy Rights and Choices– what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:

1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.

Category  
Categories of Sources
Identifiers,

E.g.,  IP address; mobile ad identifiers.
The names, addresses, phone numbers, etc. of our customers (for our own marketing and customer contact purposes).
Data compilers, mobile applications, advertising networks and platforms.
Geolocation  data
Mobile applications, data compilers, government agencies, such as the US Postal Service.

2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION

We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers. The chart below explains how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.

Category  
Categories of Third Parties We Share With
Whether We “Sold” This Category of Personal Information in the Last 12 Months
Identifiers, e.g., mobile ad identifiers; other device or online identifiers; IP address.
Advertising networks (e.g., demand-side platforms, agency trading platforms), agencies and advertisers, data compilers and resellers, data analytics providers, marketing research providers, financial institutions, government entities, and information services and publishers (“Our Customer Categories”).
Yes  
Geolocation data
Our Customer  Categories
Yes
Inferenced data
E.g., inferences based on a device’s location or traffic history.
Our Customer  Categories
Yes

We also may share any of the personal information we collect as follows:


Sharing for Legal Purposes:

In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g., a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public.

We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.  

Sharing In Event of a Corporate Transaction:

We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing With Service Providers:  

We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.

Sharing of Aggregate Information:  

We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”).  We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

Generally speaking, we collect and share the Personal Information that we collect for the following purposes, as we also have described in our Privacy Policy:

Our Purposes for  collecting, using and sharing Personal Information
Online advertisement targeting, for example:
  • Assisting advertisers, agencies and the platforms that they access (a) to deliver advertising and marketing to send, tailor, optimize and analyze advertising, in mobile apps and across other advertising channels and platforms and (b) to measure and analyze such advertising and marketing.  
  • Create “audience segments” based on inferences about consumer preferences, products and activities for purposes of online and mobile advertising.
  • Assisting Clients by creating “identity” graphs, to help locate users across various channels, such as connecting identities based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).
Marketing, analytics, and other research, for example:
  • Providing information for research purposes related to human traffic patterns, including for purposes of market, public health, civic or transportation, financial, or consumer research.
Operating our Services, for example:  
  • Improving, testing, updating and verifying our own data and data services.
  • Developing new products.
  • Operating, analyzing, improving, and securing our Services.
Other internal purposes, for example:  
  • For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. We use the information collected from our own website, from social networks, from other “business to business” interaction (such as at trade shows) or from data compilers for for the above, as well as for our own marketing purposes.

4. YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, to the extent as act as a “business” (as opposed to a “service provider”) for purposes of handling personal information. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)

a. Right to Opt-out of the sale of your personal information.

California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.”

We may act as a “business” or a “service provider” under the CCPA.  When we act as a business under the CCPA, you may “opt out” of our “sale” of your personal information (as those terms are defined by the CCPA)  by following the directions on the NAI (Network Advertising Initiative) page addressing how consumers may opt out of cross-app advertising through their device settings. 

If you opt out as described at the NAI (Network Advertising Initiative) page, that will signal to the mobile apps and platforms with whom we have relationships to cease making their data available to us.  You may additionally go to our own “Do Not Sell” web page, here , if you wish to manually input your information, which in some cases may provide an additional measure of protection against certain information being transferred.   In most cases, however, the opt out described at the NAI page will provide a more efficient, immediate and uniform – and easier to instantly access – way to opt out than a more manual “opt out” process.

(You may also make such a request by sending an email to [email protected]; but we will need to direct you to the above device-based methods to identify your device.)

b. Right to request deletion of your personal information

As a California resident, you may also request that we delete any personal information that we collected from you, such as if you have been a customer of ours.  (This is usually not the case as to the data used in our services.).  To make such a request, please send an email to [email protected], submit a request here, or contact us at (415) 966-1152.   However, please note that a “deletion” request is different from a request that we  “opt out” of or stop selling your personal information, which is described above if what you really want is for us to cease selling your information and place your mobile identifiers on a suppression list (to avoid future sale), please go to our “opt out” page, here, or to the NAI page referenced above.

Please also note that we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations.  Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

c. Right to request access to your personal information

California residents also have the right to request that we disclose what categories of your personal information we collect, use, or sell.  To make such a request, please send an email to [email protected] or submit a request here.  We will then request certain information about you, including your device identifier (and we may request a screen shot of that identifier).  

California residents likewise have a right to request and receive access to the specific pieces of personal information that has been collected about them, upon making a verifiable request.    We are not able to provide such specific pieces of personal information, because we are not able to verify to a reasonably high degree that the personal information we have pertains to the person who has submitted the request, or whether either the person in possession of a device or the person requesting the information is the actual device owner.   For instance, a number of people may be temporarily in possession of another person’s phone – e.g., a partner, friend or work colleague – whether consensually or not.  We seek to avoid (and believe California law requires us to avoid) a situation where such a person might obtain potentially detailed and sensitive records pertaining to the phone’s owner.  (A recent study concluded that one half of mobile phones were not password protected.). 

Moreover, because we do not collect information such as name, address or email address (which we avoid, to protect consumer privacy), we do not have other, more conventional ways to verify the identity of an actual device owner. 

If you are uncomfortable with your device information being used in the ways described above, we recommend that you request an “opt out” of your information as described above. As noted, comprehensive information about how to opt out can be found here, on the website of the Network Advertising Initiative, a leading self-regulatory organization of which we are a member.

d. Right to nondiscrimination

We do not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

e. Information About Persons Under 16 Years of Age  

We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).

f. Authorized Agents

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person (i.e., the California resident) seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.