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Privacy Policy

Overview

This privacy policy (“Privacy Policy“) explains how Secco Squared collects, uses and shares your (you, the the user) information, to provide advertising and mobile distribution and promotion services to its partners and clients (“Partners“).

Please note that this Privacy Policy does not apply to information that we collect when a user visits our website, located at www.seccosquared.com.

This Privacy Policy may be updated from time-to-time with the most recent version prevailing. To access the most recent version, please go to: www.seccosquared.com/privacypolicy.

What information we collect

We collect the following categories of information for the purposes listed below:

  • Device and app information – this category includes device’s type and model, system language, the device’s operating system (such as Android or iOS), SDK version, mobile carrier name, mobile browsers installed on the device (such as Chrome or Safari), app history and usage information (such as information about running and installed apps on the device), information regarding downloads and installations of mobile applications and any information regarding in-app events (such as in-app purchases), device’s IP address, and identifiers assigned to device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or other types of unique device identifiers (a number uniquely allocated to device by the device manufacturer).
  • Ad information – this category includes information about the online ads and personalized content we have served or attempted to serve to the user. It includes things like how many times an ad has been served to user, what page the ad appeared on, whether user viewed, clicked on or otherwise interacted with the ad, ad engagement history and whether user visited the Advertiser’s website, downloaded an app or purchased the product or service advertised.
  • Location information – Secco Squared collects information about user general location (such as city and country). For example, we may use the IP address to identify user general location. This information does not tell us where the device is precisely located. This information is sent as a normal part of internet traffic. In addition, we also collect implicit location information, which allows us to infer that user is either interested in a place or that user might be at the place – this information does not actually tell us where the device is precisely located.

In addition, Secco Squared may collect the precise location of user device (using GPS signals, device sensors, Wi-Fi access points, Bluetooth signals, Beacons signals and cell tower ids that can be used to derive or estimate precise location, or other geo-location data), when location services have been enabled by the end user for the mobile app or website that uses our SDK (users typically have to choose to turn on device-based location services).

  • Log information – this category includes the app or website visited, session start/stop time, time zone, and network connection type (e.g., WiFi, cellular), and cookie information.
  • Information from advertising partners (“Advertisers”) and other third parties – this category includes information we receive from Publishers, Advertisers and other Partners that we work with to help us deliver ads and personalized content to users and recognize users across browsers and devices. This may include pseudonymous advertiser identifiers that some Advertisers or other third party ad platforms choose to share with us. This information is also used to enhance data points about a unique browser or device.

How We Use the Information We Collect

We use the information we collect for the following purposes:

  • Serving ads and promoting apps – allow our Publishers to promote advertising, apps and content in their mobile apps, and to allow Advertisers to bid on Publishers’ inventory.
  • Serve interest-based advertising and personalized content – enable our partners to infer interests and serve ads and personalized content to users based on their behavior, app activity and inferred interests. We will not serve interest-based ads or personalized content based on information that we consider sensitive, such as race, religion or health.
  • Ad reporting and conversions – measure ad performance, report to Advertisers when and how users have viewed or clicked on their ads, or visited their website, and to report to Publishers when and how ads were shown on their properties and were clicked on.
  • Analytics and frequency capping – allow our Publishers to analyze their applications (for this purpose, we use aggregated and anonymous benchmark data) and prevent users from seeing the same ad too many times.
  • Fraud detection and prevention – identify invalid or incentivized clicks (or ad queries) and protect Secco Squared and our partners from fraudulent behavior.
  • Enforce our policies, resolve disputes and communicate with user(s).
  • Providing and improving our services – audit, research and analyze information in order to maintain, protect, and improve our services and develop new services, and to ensure that our technologies function properly.

Information Sharing

We share information about users with:

  • A Publisher whose app users have access to – we share information about how users have interacted with that Publisher’s app and its ads and personalized content.
  • An Advertiser whose site or app users have visited – we share information about how users have interacted with that Advertiser’s site, app or its ads.
  • With our service providers – we contract with companies who help with parts of our business operations (for example, storage of information). We require that our service providers only use user information in connection with the services they perform for us.
  • With our subsidiaries and related companies.
  • In connection with legal proceedings – when we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of Secco Squared, our Partners or any other third party.
  • In connection with a sale of our business – if a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale.
  • In addition, we may disclose aggregated, anonymized information with other third parties. This information cannot be used to identify you.

How We Collect Information

When operating our services, we use various technological tracking tools to collect information from user devices, such as:

  • Our SDK – the SDK is a bit of computer code that app developers (such as our Publishers) can include in their apps to enable ads and personalized content to be shown, data to be collected, and related services to be implemented.
  • Along with our Partners, we may use tracking technologies such as cookies, JavaScript, beacons and Local Storage such as HTML5. Our Partners may also use Local Storage Objects (LSOs) such as Flash. Local Storage (LS) such as HTML5 and Local Storage Objects (LSOs) such as Flash are used to store content information and preferences. Various browsers may offer their own management tools for removing HTML5 LS’s. Beacons are clear graphic image(s) of 1×1 pixel that is delivered through a web browser usually as part of a webpage request. Web beacons operate as a tag that records an end users visit to a particular webpage.
  • Our Publisher may use cookies to track your behavior on their apps or websites. A cookie is a small piece of text that is sent to a browser. The browser provides this piece of text to the originating server when the visitor returns. Most web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please note that some features of Secco Squared may not function properly when cookies are disabled or removed.
  • JavaScript is a dynamic object oriented computer programming language. JavaScript is used to understand the End User’s behavior on an app or website.

End User choice

To serve personalized content and ads we may use technologies that perform similar functions to cookies. Sometimes we link the identifier used for advertising on mobile applications to an advertising cookie on the same device to coordinate ads across your mobile apps and mobile browser. This also helps us improve the reports we give to our advertisers on the effectiveness of their campaigns.

To opt out of personalized ads in apps on your mobile device, follow the instructions below.

If you have an Android device –

  1. Find Google Settings – depending on your device, it could be located here:
    1. A separate app called Google Settings
    2. In your main Settings app, scroll down and tap Google
  2. Tap Ads
  3. Switch on Opt out of interest-based ads

If you have an iOS device –

If you have an iOS device, you can opt out of interest-based or “cross-app” advertising by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to ‘ON’. You can do this by clicking on Settings -> General -> About -> Advertising and toggling Limit Ad Tracking to ‘ON’.

When you have opted out using these settings on a device, Secco Squared 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. Secco Squared requires its Partners to honor opt-out preferences expressed using these controls. However, please note that opting-out using these settings would only prevents serving tailored ads to you; this would not affect other activities, such as serving contextual advertising, ad frequency capping and analytics.

You can turn off certain third party cookies for advertising purposes by visiting the Network Advertising Initiative, located here: http://www.networkadvertising.org/choices/ or the DAA opt-out program, which are located here:http://www.aboutads.info/choices/, here (for EU/EEA citizens): http://www.youronlinechoices.eu/ and here (for mobile devices): http://www.aboutads.info/appchoices

Do Not Track Disclosure

Do Not Track (“DNT”) is a privacy preference that users may set in certain web browsers. DNT is intended to allow users another method of informing websites and services that they do not want certain information about their website visits collected over time and across websites. Because the effect of DNT signals remains unclear, and there continues to be no consistent industry understanding of how to respond to such a signal, we do not alter our privacy practices when we detect a DNT signal from your browser. Rather, we provide or respect the consumer choice options set forth in this privacy policy.

Information Retention and Access to Information

We may retain personally identifiable information we process on behalf of our Partners for as long as needed to provide services to them. We may adopt shorter retention periods if so directed by our Partners. We may retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Please note we have no direct relationship with the End Users. An End User who seeks access, or who seeks to correct, amend, or delete inaccurate information should direct his query to the relevant Publisher. If an End User requests us to remove any personally identifiable information relating to him or her, we will respond to their request within a reasonable timeframe.

Security

Secco Squared has implemented reasonable security measures in order to protect your information from loss, misuse and unauthorized access, disclosure, alteration or destruction. While we cannot guarantee that loss, misuse or alteration to information will not occur; we make good faith efforts to prevent such occurrences. We do not warrant or represent that your account or any of your information will be protected against, loss, misuse, or alteration by third parties.

International transfers

Secco Squared may transfer the information we collect about you to countries other than the country where we originally collected it for the purposes of storage and processing of information and operating our services. Those countries may not have the same information protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Policy and take steps, where necessary, to ensure that international transfers comply with applicable laws. For example, if we transfer your information from the European Economic Area to a country outside it, such as the United States, we will seek to take additional steps such as entering into EU compliant data transfer agreements with the data importer where necessary.

Children Information

Secco Squared does not knowingly collect any personally identifiable information (including persistent device identifiers) relating to children under the age of 13. In addition, we require our Publishers to certify to us that their services (such as their mobile apps) are not primarily directed to appeal to children under the age of 13, and to avoid sharing with us any personally identifiable information relating to children under the age of 13.

Please note that while we strive hard to ensure that our policies are respected, we cannot be held responsible for the practices of our Publishers. Our publishers are responsible to ensure that their privacy practices comply with applicable privacy laws and requirements, including with respect to safeguarding children’s privacy (such as by complying with the U.S. Children’s Online Privacy Protection Act of 1998).

If you have knowledge of any incident in which we may be collecting personally identifiable information relating to children under the age of 13, or that our SDK is included in any service (such as a mobile app) that is directed to or aimed to appeal to audience under the age of 13, please let us know immediately by contacting us at: [[email protected] Squared.com], and we will remove their personally identifiable information from our servers without delay.