*.PERSONAL INFORMATION:
*.NON-PERSONAL INFORMATION:
*.Usage Data:
*.PHONE PERMISIONS:
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MoPub, a division of Twitter, Inc., provides advertising technology services (referred to herein as the “MoPub Services”) that allow publishers of mobile applications (“apps”) to promote, and show ads in, their apps. In this Privacy Policy, where an individual or entity is working directly with us to promote their offerings, we refer to them as an “Advertiser,” and where an individual or entity is working directly with us to show ads in their apps, we refer to them as a “Publisher.” Individuals or entities working directly with MoPub may act as both a Publisher and Advertiser.
We also work with a variety of partners (collectively, “MoPub Partners”) in order to provide the MoPub Services:
- “Advertising Demand Partners” are demand side platforms, advertising networks, or other advertising demand sources that bid on ad inventory or serve ads through the MoPub Services. Individuals or entities acting as Advertisers are also Advertising Demand Partners when using the MoPub Services in that capacity. Advertising networks that are Advertising Demand Partners may also be Supported Advertising Mediation Partners, as described below.
- “Data Partners” are companies that create audience segments (including demographic and interest segments) based on device identifiers, location data, and other personal data, in order to help Advertising Demand Partners reach the right audiences.
- “Fraud and Measurement Partners” are companies that assist with anti-fraud, quality, and security efforts meant to help ensure the safety, security, privacy, and accuracy of the MoPub Services, including detection of fraudulent apps and clicks on ads in apps, and whether ads are viewable within an app.
- “Supported Advertising Mediation Partners” are companies that Publishers work with directly in order to serve ads in apps. The MoPub Services support the technical integration of these Supported Advertising Mediation Partners’ services into apps through MoPub's mediation and real-time bidding products. Supported Advertising Mediation Partners may constitute Advertising Demand Partners when engaged in real-time bidding for Publisher inventory.
Unless otherwise noted in our partner list, each MoPub Partner is an independent controller of your data. You can view a list of MoPub Partners with whom we share your data here, current as of the date listed at the top of that page. In addition, Publishers may use the MoPub Services to work with unsupported third parties in a manner similar to the way Publishers work with Supported Advertising Mediation Partners, as described above. Advertisers and Publishers are also independent controllers of your data.
This Privacy Policy explains how MoPub collects, uses, shares, and otherwise processes personal data.
- Section 1 describes how we process personal data about you through the MoPub Services, if you are an end user of apps that integrate with the MoPub Services, and how you can exercise control over such processing.
- Section 2 describes how we process personal data about you if you visit MoPub.com or other websites that link to this Privacy Policy (collectively, our “Sites”).
- Section 3 describes how we process business contact information about you if you work for or represent Publishers, Advertisers, or certain MoPub Partners.
- Section 4 provides other important information that applies to our personal data processing activities and explains how you can reach us with thoughts or questions about this Privacy Policy.
Section 1: Personal Data We Process About End Users to Provide the MoPub Services
1.1 Personal Data We Collect
If you use an app that works with the MoPub Services, we may collect personal data about you through apps and technical integrations, as well as from Advertisers, Publishers, MoPub Partners, and other third parties. The MoPub Services do not intentionally collect information such as your name, address, or email address, but the personal data we may collect could enable us to recognize your device over time and across apps. Depending on where you live and your privacy choices, the personal data we may collect includes:
- Device identifiers, including your IP address, iOS Identifier for Advertisers (IDFA), iOS Identifier for Vendors (IDFV), Android Advertising ID, a MoPub-specific identifier, and device identifiers assigned by Publishers, Advertisers, or MoPub Partners.
- Your precise or coarse geolocation, when location services have been enabled for an app. Note that when you have not enabled location services for an app, we will still infer data about your general location based on other information, including your IP address
- Information that a Publisher or Advertiser has collected about you and shared with MoPub, including demographic information (e.g., your age or gender) or information about your interests.
- Information about your device, including the type and model, manufacturer, operating system (e.g., iOS or Android), carrier name, mobile browser (e.g., Chrome, Safari), and screen size.
- Information about your app usage, including the app version, the app on your device that is requesting an ad, the start/stop time of your app session, in-app purchase information (e.g., products or services purchased and the associated cost), your current time zone, and your network connection type (e.g., WiFi, cellular).
- Information about ads served, viewed, or clicked on, including the type of ad, where the ad was served, whether you clicked on it, and whether you visited the advertised website or downloaded the advertised app.
1.2 How We Use the Personal Data We Collect
We use personal data we collect for the following purposes:
- Serving Ads: Allowing Publishers to offer advertising inventory and Advertising Demand Partners to bid on advertising inventory and serve ads.
- Personalized Advertising: Inferring—and allowing Publishers, Advertisers, and MoPub Partners to infer—your potential interests and what ads you are most likely to engage with. Then we and others serve ads to you based on these inferences. Depending on your location, MoPub may directly create a profile about you to serve you ads relevant to your interests. MoPub does not permit use of the MoPub Services for personalized advertising based on sensitive categories of personal information, such as race, religion, politics, sex life, sexual orientation, or health. Our agreements and policies prohibit Publishers, Advertisers, and MoPub Partners from engaging in such practices.
- Geo-Targeting: Allowing Publishers, Advertisers, and MoPub Partners to serve ads based on your current or prior geolocation, including through location-based targeting segments created by Data Partners.
- Reporting: Reporting to Advertising Demand Partners information about, for example, when and how you were exposed to or clicked on ads, and reporting to Publishers information about when and how ads were shown in their apps. Reports may include, for example, information about whether you downloaded an advertised app and your purchases in an advertised app.
- Ad Capping: Preventing you from seeing the same ad or similar ads too many times and preventing you from seeing ads if you reach an applicable threshold of in-app purchases.
- Fraud Detection and Prevention: Identifying invalid clicks (or ad queries) and protecting MoPub Partners from fraudulent behavior.
- Providing and Operating Our Services: Auditing, researching, and analyzing data in order to maintain, protect, and improve MoPub Services; to develop new services; and to ensure that our technologies function properly.
1.3 How We Share the Personal Data We Collect
We share personal data that we collect about you in the following circumstances:
- With Advertisers and Advertising Demand Partners for use in furtherance of their business purposes, including to understand campaign performance and effectiveness; to decide whether to bid on ad inventory or serve an advertisement; and to choose the best ad for you on our mobile advertising exchange and across the broader advertising ecosystem. For example, Advertising Demand Partners may use personal data we share with them to create audience segments, including demographic and interest segments; to improve their bidding algorithms and machine learning for use on and off of the MoPub Services; and to measure the effectiveness of advertising. Through our agreements and policies, we require Advertising Demand Partners to use the information they receive in compliance with applicable laws and regulations.
- With Data Partners so they can create audience segments, including demographic and interest segments, to help Advertising Demand Partners choose the best ad for you on our mobile advertising exchange and across the broader advertising ecosystem.
- With Fraud and Measurement Partners in order to assist with anti-fraud, quality, and security efforts meant to help ensure the safety, security, privacy, and accuracy of the MoPub Services and the broader advertising ecosystem.
- We share personal data with Publishers, Advertisers, and MoPub Partners so they can build and improve their products and services for use on MoPub and across the broader advertising ecosystem.
- With service providers we engage to perform functions and provide services to us and MoPub Partners in the United States, Ireland, and other countries. We may share the personal data we collect with such service providers, subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and subject to the condition that they use your information only on our behalf and pursuant to our instructions.
We may also share aggregate information with Publishers, Advertisers, and MoPub Partners to help them measure the effectiveness and value of MoPub Services. For example, we provide Advertising Demand Partners with reports showing how many users viewed or clicked on their ads. We also provide Publishers with reports about, for example, the types of ads served to their apps.
1.4 Controlling the Processing of Your Personal Data for Personalized Advertising
You have control over how we process your personal data for personalized advertising purposes.
1.4.1 The European Union, EFTA, and United Kingdom
If you are located in the EU, a European Union Free Trade Association (“EFTA”) State, or the United Kingdom, Publishers who would like us to serve you personalized ads must first obtain your consent so that MoPub and MoPub Partners can process your personal data for this purpose. Some Publishers may choose to obtain your consent for this purpose even if you are located outside of these regions. If you provide your consent, we will collect, store, use, share, and otherwise process all of the personal data described above for the purpose of serving you personalized advertising that MoPub and MoPub Partners believe is relevant to you.
You can withdraw your consent to MoPub’s personalized advertising experience on your device at any time by using your device settings as follows:
- On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings. (Precise directions may differ depending on the applicable iOS version.)
- On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by enabling the “Opt out of Ads Personalization” setting. (Precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer.)
If, as described above, you use your device settings to withdraw your consent to personalized advertising, then when MoPub receives notice of your consent preference, we will not collect, use, share, or otherwise process personal data from your device or that app (as applicable) to personalize your advertising experience. MoPub will also communicate a signal indicating your consent preference to relevant MoPub Partners so that they, as independent controllers of your personal data, can also respect your choice. Unless we have another legal basis for storing your personal data, if you are located in the EU, an EFTA State, or the United Kingdom, we will delete or de-identify the personal data we have stored about if you withdraw your consent.
Through our agreements and policies, MoPub (a) requires that our Advertising Demand Partners honor consent preferences expressed using these controls by serving only contextual advertisements; and (b) prohibits Advertising Demand Partners from using the data contained in ad requests to serve personalized advertising or to create a personalized advertising profile of the user or device.
If you do not consent to MoPub processing your personal data for personalized advertising purposes, we will still process certain information pursuant to other lawful bases:
- Legitimate Interests: We may process personal data for certain non-personalized advertising purposes as necessary to support our legitimate interests. For example, we may process personal data in order to serve contextual advertisements, and to conduct the Ad Capping, Fraud Detection and Prevention, and Providing and Operating Our Services activities described above under “How We Use the Personal Data We Collect.” We may also share personal data for these purposes with our service providers, Fraud and Measurement Partners, and Advertising Demand Partners. We may also continue processing personal data where we believe that it is reasonably necessary to protect the rights or safety of any person; to address fraud, security or technical issues; or to protect the rights or property of MoPub, Publishers, Advertisers, MoPub Partners, or others as described below under “Law, Harm, and the Public Interest.”
- Legal Necessity: We may process your personal data as necessary to comply with our legal obligations. For example, we will retain a record of your device for the purpose of recording when you consented and then withdrew consent to personalized advertising, and we may make this information available to Publishers, Advertisers, and MoPub Partners so that they, as independent controllers of your personal data, can also respect your choice to withdraw consent. We may also preserve or disclose information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request as described below under “Law, Harm, and the Public Interest.”
Due to the nature of the personal data that MoPub collects through the MoPub Services, we do not have sufficient information available to provide secure, authenticated access to the personal data that we store about you or to confirm that specific personal data relates to you. However, you can exercise control over how we process your personal data for personalized advertising, as explained above.
1.4.2 United States and Other Countries
If you are located in the United States or another country outside the EU, an EFTA State, or the United Kingdom, you can opt out of receiving personalized advertising by using your applicable device settings:
- On iOS, depending on the applicable iOS version, you may opt out of personalized advertising across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, you may also have the option of opting out on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings. (Precise directions may differ depending on the applicable iOS version.)
- On Android devices, you may opt out in the Google Ads settings within your Android settings by enabling the “Opt out of Ads Personalization” setting. (Precise directions and the name of the setting may differ depending on the applicable Android version and device manufacturer.)
If, as described above, you use your device settings to opt out of personalized advertising, then when MoPub receives notice of your opt out, we will not collect, use, share, or otherwise process personal data from your device or that app (as applicable) to personalize your advertising experience. MoPub will also communicate a signal indicating your opt out preference to our Advertising Demand Partners so that they can also respect your choice.
Through our agreements and policies, MoPub (a) requires that our Advertising Demand Partners honor opt out preferences expressed using these controls by serving only contextual advertisements; and (b) prohibits Advertising Demand Partners from using the data contained ad requests to serve personalized advertising or to create a personalized advertising profile of the user or device.
1.5 Privacy Practices of MoPub Partners
Through our agreements and policies, MoPub requires Publishers, Advertisers, and MoPub Partners to comply with all applicable laws and regulations, and, where applicable, to provide you with sufficient notice of their processing of your personal data.
Publishers, Advertisers, and MoPub Partners may also have separate legal bases for collecting, using, retaining, and sharing your personal data. For example, some Publishers and Supported Advertising Mediation Partners may mutually agree to process your personal data for personalized advertising purposes on the basis of legitimate interests. Although MoPub is not involved in the processing of your personal data in these cases, our agreements and policies require Publishers, Advertisers, and MoPub Partners to provide visible notice when they choose to process your personal data in this manner.
We encourage you to read the privacy policies provided by Publishers, Advertisers, and MoPub Partners to understand their privacy practices, the legal bases for their processing of your personal data, and any additional options that they provide for exercising control over such processing.
1.6 Children
Through our agreements and policies, MoPub does not permit the MoPub Services to be used to collect information from apps directed to children under the age of 13 for purposes of personalized advertising. MoPub may collect limited information from apps directed to children for other purposes, including serving advertisements based on contextual information, such as the content or type of app you are using (for example, serving an ad for a video game to a gaming app).
In addition, you must be old enough to consent to MoPub’s personalized advertising experience in your country (in some countries we may allow your parent or guardian to do so on your behalf). MoPub does not collect or otherwise process personal data from individuals whom it knows to be under the legal age of consent in their country, except to comply with law or to support our legitimate interests as described above.
Section 2: Personal Data We Process if You Visit Our Sites
2.1 Personal Data We Collect if You Visit Our Sites
When you visit our Sites, our servers automatically record certain personal data in our log files. This web log data includes information such as your IP address, browser type, operating system, the referring web page, pages visited, and cookie information. Like many websites, we use web log information, along with cookies, pixels, and similar technologies, to operate our Sites, better understand how they are used, resolve technical problems, and enhance your experience on our Sites.
A cookie is a small piece of data that is stored on your computer or mobile device. Like many websites, we use cookies and similar technologies to collect additional website usage data and to operate our services. Although most web browsers automatically accept cookies, many browsers’ settings can be set to decline cookies or alert you when a website is attempting to place a cookie on your computer. However, some features of our Sites, including certain features made available to Publishers, Advertisers, and MoPub Partners, may not function properly if you disable cookies. When your browser or device allows it, we use both session cookies and persistent cookies to better understand how you interact with our services, to monitor aggregate usage patterns, and to personalize and otherwise operate our services such as by providing account security and remembering your language preferences. We do not support the Do Not Track browser option.
2.2 Personal Data We Share if You Visit Our Sites
We use a variety of third-party services, including Google Analytics and Mixpanel, to help operate and understand the use of our Sites. We may share personal data, including cookie information, with such service providers subject to obligations consistent with this Privacy Policy and other appropriate confidentiality and security measures.
Section 3: Business Contact Information
3.1 Personal Data We Collect From Business Contacts
To access and use certain MoPub Services on behalf of a Publisher, Advertiser, or MoPub Partner, you will be asked to provide certain personal data, including your name, email address, physical address, phone number, and company name. You may be asked to provide additional personal data, including a username and password, to register for a MoPub account. This information is used to provide the MoPub Services and to send you information about the MoPub Services. To opt out of receiving promotional information, please follow the unsubscribe instructions in any of our promotional emails. If you are a Publisher, you also will be asked to provide personal data through our third-party payments processor so that we can fulfill payments to you. We will also collect web log information when you use the portals we make available on our Sites, as explained in Section 2.
3.2 Accessing or Rectifying Your Business Contact Information
We provide you with account tools to access, correct, or modify personal data you have provided to us in association with your MoPub account. You may request to delete your account by logging in and following the instructions to request account deletion. Unless we have a continuing obligation to retain your personal data, including compliance with tax or accounting laws, we will delete or de-identify the personal data we have stored about you after we receive your request to delete your account.
3.3 Personal Data We Share and Disclose About Business Contacts
We may disclose personal data about you when necessary to provide the MoPub Services, including to respond to account inquiries, to verify accounts, or to enable participation in certain features of the MoPub Services.
Section 4: Other Important Information
4.1 Law, Harm, and the Public Interest
Notwithstanding anything to the contrary in this Privacy Policy or controls we may otherwise offer you, we may preserve or disclose information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the rights or safety of any person; to address fraud, security, or technical issues; or to protect the rights or property of MoPub, Publishers, Advertisers, MoPub Partners, or others.
4.2 Information Sharing Within Our Corporate Family
We may share information described in this Privacy Policy within the Twitter family of companies, including our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.
4.3 Change of Ownership
In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal data may be sold or transferred as part of that transaction. This Privacy Policy will apply to your personal data as transferred to the new entity.
4.4 California Consumers
If you are a California consumer, please see the MoPub California Consumer Privacy Statement for additional information.
4.5 Additional Information or Assistance
If you have thoughts or questions about this Privacy Policy, let us know by contacting us here or writing to us at the appropriate address below.
If you live in the United States or any other country outside of the European Union, an EFTA State, or the United Kingdom, the data controller for your personal data is Twitter, Inc., which can be contacted at the following address:
Twitter, Inc.
Attn: Privacy Policy Inquiry
1355 Market Street, Suite 900
San Francisco, CA 94103
If you live in the European Union, an EFTA State, or the United Kingdom, the data controller for your personal data is Twitter International Company, which can be contacted at the following address:
Twitter International Company
Attn: Data Protection Officer
One Cumberland Place, Fenian Street
Dublin 2, D02 AX07 IRELAND
You can confidentially contact Twitter’s Data Protection Officer here. If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority or Twitter International Company’s lead supervisory authority, the Irish Data Protection Commission. You can find their contact details here.
4.6 Our Global Operations and Data Transfers
To bring you our services, we operate globally. Where the laws of your country allow you to do so, you authorize us to transfer, store, and use your data in the United States, Ireland, and any other country where we operate. In some of the countries to which we transfer personal data, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those of your country. Learn more about our global operations and data transfer here.
When we transfer personal data outside of the European Union, EFTA States, Brazil, Switzerland, or the United Kingdom we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws and/or contractual obligations placed on the recipient of the data (where we rely on the EU standard contractual clauses these may be requested by inquiry as described below).
Twitter, Inc. complies with the EU-U.S. and Swiss-U.S. Privacy Shield principles (the “Principles”) regarding the collection, use, sharing, and retention of personal data from the European Union, EFTA States, Switzerland, and the United Kingdom as described in our EU-U.S. Privacy Shield certification and Swiss-US Privacy Shield certification. We do not rely on the EU-U.S. or Swiss-U.S. Privacy Shield as our lawful basis to transfer personal data from the European Union, EFTA States, or the United Kingdom, however.
If you have a Privacy Shield-related complaint, please contact us here. As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Principles, we will seek to resolve it through our internal complaint resolution process, through the independent dispute resolution body JAMS, or, under certain conditions, through the Privacy Shield arbitration process.
Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, participants may be liable for the transfer of personal data from the EU, EFTA States, Switzerland, or the United Kingdom to third parties outside the EU, EFTA States, Switzerland, and the United Kingdom. Learn more about the EU-US Privacy Shield and Swiss-US Privacy Shield here.
4.7 Changes to This Privacy Policy
We may revise this Privacy Policy from time to time. The most current version of the policy will govern our processing of your personal data. If we make a change to this policy that, in our sole discretion, is material, we will notify you via a banner on one or more of our Sites as appropriate, or if you represent a Publisher, Advertiser, or MoPub Partner and have an account on the MoPub Services, we will send an email to the email address associated with your account. The revised Privacy Policy applies to you if you continue to access or use the MoPub Services or an app that uses the MoPub Services after those changes become effective.
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