MOLOCO

Information we Collect

We collect information and data in the following ways:

Information You Give Us

When you ask to be contacted or have questions about our products and services and you provide us with your contact information (like your name and email address).

Information We Collect from Customers and Partners

If you are one of our Customers or Partners (or a representative of one of our Customers or Partners), we collect
personal information from you in connection with our contractual obligations and legitimate business interests. This information is used to appropriately target advertisements as part of our Services and to set up a user accounts and profiles as necessary. This information may also be used to contact you, to fulfil your requests for certain products and Services, to analyze how Customers utilize the Services, to generate leads and to create industry influencers. We collect the following information:

• Name
• Email
• Address
• Phone Number
• Payment Information from Partners
• Customers and Partners wishing to opt out of receiving information from Moloco can click “UNSUBSCRIBE” in
  marketing emails or email us at marketing@molocoads.com.

Information We Collect and Use About Targeted End Users When They Interact With Our Customers’ Mobile Applications

If you are a Targeted End User to our consumer, we collect certain device information provided by our advertising exchange Partners or our Customers to serve targeted ads to you, to measure the performance of and optimize our Customers’ marketing campaigns to you, to analyze trends in aggregated data and to analyze data to identify the demographic and interests of Targeted End Users across the app ecosystem (all of which could include the sharing of data with the applicable Customer for such purposes).
This information includes:

• Generic geographic location consisting of IP address and explicit geographical categorization such as country or
  zip code and then granular latitude and longitude coordinates (please note that this is subject to the capability of
  the advertising exchange that we use, and so this data is not always collected by us)
• Mobile Carrier
• Device make, manufacturer, operating system and language settings
• Name of Mobile Application(s) installed on user's device
• Internet Protocol Address
• Device ID
• Browser type
• Internet service provider (ISP)
• Advertising ID: Android ID or Identifier for Advertisers (IDFA)
• Connection speed
• App usage data
• Referring / exit pages
• Files viewed on our Site (e.g. HTML pages, graphic, etc.)
• Date / time stamp
• Clickstream data

We process this information on the basis of our legitimate business interest.

Data we collect if you are an Employee, Contractor, Job Applicant or Former Employee

• Applying to work at Moloco: If you apply to work at Moloco, we process personal information about you and your professional experience, education and training such as your application, your name (and any former names), postal address, email address, phone number, universities attended, academic degrees obtained, grades, professional certifications and licenses, employment history, and curriculum vitae or resume.
• Offer of employment or contractor position: Prior to making an offer of employment or a contractor position, we process personal information to conduct professional reference checks in accordance with applicable laws. If we extend an offer of employment or a contractor position at Moloco to you, we will process personal information about the position to which you have been appointed, your job title at Moloco, the compensation or project-based contractor rate we offer to you, whether you accept the offer, your signature, and your starting compensation or project-based contractor rate, and your start date at Moloco.
• Employment-Related Background checks: Prior to commencement of your employment with us, we may engage service providers to conduct background checks that involve the necessary personal information processing as permitted by the laws in the location in which you reside and/or work. More details are provided to you in the context of our request to you to complete these checks.
• As an employee or contractor of Moloco: we may process personal information about your benefits, nationality, residency status, email address, office or other workplace location, work phone number, mobile phone number, photographs, passport, visas, marital status, beneficiaries, emergency contact details, financial account information, social security number or other government-issued identification number, holiday and paid time off days, salary, incentive compensation, Moloco stock options granted, Moloco stock ownership, assigned projects, performance against your assigned goals, training completed, any performance improvement plans, any disciplinary actions taken, system accounts, technology and physical assets provided to you, your role and actions taken in connection with Moloco projects and processes.
• If your employment with Moloco ends, we process personal information necessary to offboard you from Moloco, including deactivation of your access to our systems, fulfilling our financial, benefits, and related obligations with respect to the end of your employment with Moloco.
• In certain countries, supplemental privacy notices will be provided to Moloco employees and contractors, and where applicable, consent will be obtained, to ensure compliance with local requirements.

We process this information on the basis of our legal obligations and legitimate business interest.

Information Related to Data Collected through the Service

If you are using our service, the use of information collected shall be limited to the purpose identified by your engagement with Moloco.

Moloco collects information under the direction of its Customers, and has no direct relationship with the individuals whose personal information it processes. If you are a Targeted End User of one of our Customers and would no longer like to be contacted by one of our Customers that use our service, please contact the Customer that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Customers. For additional information you can contact Moloco at privacy@molocoads.com.

Data We Receive from Others

We may receive information about you from other sources as required in connection with our legitimate interests, including publicly available databases or third parties from whom we have purchased data (including marketing data).

We also may receive data that was initially collected (over time and across websites, mobile apps, and mobile devices) by our data partners (such as mobile app publishers and developers, advertising networks, advertising exchanges, mobile measurement platforms, supply side platforms and other websites and services), which may include:

Ad Data

We receive advertisement requests (to display an advertisement on mobile app or device, and a website) along with its associated data, such as a device identifier, the IDFA and AAID, or another similar identifier, the browser or device type, IP address, app publisher, operating system, location, and other similar device-specific information.

We use your IDFA or Advertising ID, information about any Client app you download and supplemental information associated with your device IDFA (e.g., the apps you download and any publisher-provided data) to provide best ads experience to you on behalf of our clients.

How We Use the Information We Collect

We associate the data and information that we collect with the data and information we receive from others. Our technology contextualizes and aggregates this data. The location intelligence we derive (and infer) from the data and the information we amass is the basis of the services we provide:

• For marketing and advertising purposes (such as to display and optimize advertisements, to create audience segments, and to provide measurement and reporting services),
• For capturing and understanding the interests, activities, and trends of consumers (online and in the real world),
  for data analytics and data services (such as for marketing and advertising, trend analysis, or market research), and
  for providing, maintaining, and improving the products and services we offer (and to develop new products and services).

Note about personally identifiable information

In some cases, we receive information that can identify a specific person (like a name and address). We use this type of information for statistical, analytical, and logistical purposes and for improving the products and services we offer. We do not use this type of information for targeting advertisements (other than at an aggregated level, such as zip code), although we do use personally identifiable information to help synchronize our data sets with our customers’ or our partners’ data sets (to find matches through a common identifier).

We do not display or target advertisements based on information or an activity that is deemed to be “sensitive” (based on local laws or applicable industry standards).

We may use (and store) the data and information we collect and receive on servers that may be located outside the country where you live.

Automated decision making

We perform the following automated decision making processes using your personal information:

• To build lookalike targeting models to target users who are similar to the Customer’s existing users.
  Our Machine Learning does this automatically for every Customer.
• To power predictive machine learning features e.g. users who have purchased in the past are much more likely to purchase again in the future
• To exclude existing users from User Acquisition campaigns, and power targeting rules for re-engagement campaigns e.g. target users who have registered but not purchased.

Information We Share with Others

We share the data and information we compile about someone in an aggregated or anonymized way using advertising IDs or another type of anonymous identifier:

• To display and optimize advertisements (like improving the relevancy of the advertisements displayed, tailoring them to certain interests, or creating audience segments),
• For measurement, statistics, usage reporting, and other data analytics, and
• For industry analysis, demographic profiling, market research and other such purposes.

In certain cases, we share personally identifiable information:

• When a person has given their consent to do so (like where you are notified that the information you submit will be with service providers who help us provide our services (if it is necessary, but they are not permitted to disclose or use that information for any other purpose),
• We may provide the collected information to our subsidiaries, third party partners and agents to improve advertisement targeting, make and create offers, provide reporting to advertisers and clients, and to improve our systems and products. They but they are not permitted to disclose or use that information for any other purpose,
• When we believe that we are legally authorized or required to do so, or where doing so is reasonably necessary or appropriate to comply with the law or legal processes or to respond to lawful requests or legal authorities (such as a subpoena or court order),
• If it is necessary to defend or to protect our rights, property, or interests, and in connection with a corporate
  transaction (like a financing, acquisition, sale of company assets, or bankruptcy) where this information would be disclosed or transferred as one of our business assets.

We will try to honor the opt-out signals for personalized advertising that are provided directly to us or that we receive from our data partners.

Your Rights

Opting Out of Advertising

In line with best practice in our industry, we respect End User’s rights to opt-out of receiving Interest Based Advertising.

Personalized Advertising

If you want to limit or stop receiving targeted ads, there are several choice mechanisms available:

On Mobile Devices

You may limit ad tracking in mobile app environments on your device. For the most effective and up-to-date methods for doing so, you should consult instructions provided by those device manufacturers. We offer the following information solely for informational purposes, and we cannot guarantee that the methods below are the most current:

• Apple instructions for how to Limit Ad Tracking on devices such as iPhones and iPads
• Google instructions for how to express choice on Android devices

Where possible when Moloco receives a request to limit ad tracking, we will collect and store information from your device only as needed to honor your choice and for limited research and development purposes to improve our device-recognition technology, which also helps to improve our ability to honor your choice.

Other Options and Considerations

You can opt-out for web browsers, mobile apps, and mobile devices. Some mobile devices may not support the use of cookies. If you clear your cookies from your browser, or use a different browser, you may need to renew your opt-out choice. These opt-out choices only stop you from receiving tailored ads from the selected source. Even after opting out, you will continue to receive generic ads and you may continue to receive tailored ads from other advertisers and services (if you have not opted out from their services explicitly). We do not link web browsers and mobile devices, however, in some cases, we may partner with a company that does cross-device linking for personalized advertising purposes (in which case you would need to perform an opt-out for each browser and mobile device you don’t want linked and/or used for these purposes).

Location Settings

If you want to limit or prevent location data from your device from being collected, you can adjust this capability through your mobile device settings. See instructions on how to manage your location settings for your Apple and Android devices.

Your Data Subject Rights

You have basic rights under privacy and data protection laws related to the data we process about you. You do not have to pay a fee, and we will aim to respond to your request within 30 days. We will try to honor the requests you make related to your rights as the law allows, which means in some cases there may be legal or other reasons that we may not be able to address the specific request you make related to your rights. You have:

• The right to ask us to provide you (or another data controller) with copies of the personal information that we hold about you at any time.
• The right to ask us to update or correct any out-of-date or incorrect personal information that we hold about you
  (in accordance with applicable data protection laws);
• The right to ask us not to process your personal information for the legitimate interests that we have set out above.
  In certain circumstances we may not be able to stop using your personal information but, if that is the case, we will let you know and tell you why; and
• The right to opt out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.

If you wish to exercise any of the above rights, please write to us, either by post or by e-mail at privacy@molocoads.com and we will respond within 30 days.

Children’s Privacy

Moloco adheres to the Children’s Online Privacy Protection Act[VS14] . We do not create nor use any behavioral advertising segments of children under 13 as part of our Services. Our Site is not directed at children under the age of 13. If we are made aware that we have received personally identifiable information from someone under 13, we will use reasonable efforts to remove that information from our records. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible unless your parent or guardian has provided us with their consent for your use of our Site or Services. If you believe that we might have any information from or about a child under 13, please contact us at privacy@molocoads.com.

International Transfer of Data

In limited instances, Moloco may transfer data outside the EEA. As part of Moloco’s global operations, our data flows between the EEA, the United States and APAC. To ensure that EEA Data is adequately protected when transferred outside the EEA, the Data Protection Directive 95/46/EC and, as of May 25, 2018, the General Data Protection Regulation mandate that such transfers take place using certain legal mechanisms.
When transferring EEA data to the United States, Moloco relies on the European Commission’s approved Standard Contractual Clauses, which are contractual privacy and security commitments between companies that transfer personal data. Moloco and its Affiliates have accordingly adopted Standard Contractual Clauses to ensure the legality, privacy, and security of the data flows necessary to provide, maintain, and develop our services.
Note: Moloco currently stores Customer, User, and Visitor Information in data centers located in the United States, Taiwan and Belgium.

Security and Data Retention

We take appropriate security measures to protect personal information against loss, misuse, and unauthorized access, alteration, disclosure or destruction. We also have implemented measures to maintain the ongoing confidentiality, integrity and availability of the systems and services that process personal information.

Changes to This Privacy Policy

We may make changes to this Policy from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes we make to the Policy in the future will be posted on this page, and where we change this Policy in ways that also affect how we process personal information about you, where appropriate, we will notify you directly via email or other direct contact with you, and we also will post a notice on our home page that this Policy has changed.

Contact Moloco

If you have any questions or concerns regarding this Privacy Policy, Complaints or questions regarding your Data Subject Rights please email us at privacy@molocoads.com or you can contact: