This Privacy Notice applies to personal information processed by MOLOCO Inc. (“MOLOCO,” “we,” “us,” and “our”) through our demand-side platform services that we offer to advertiser clients (“Advertising Services”).

 

ABOUT MOLOCO

MOLOCO provides a demand-side platform that allows buyers of digital advertising inventory (i.e., advertisements displayed in mobile applications) to achieve their mobile marketing goals through user acquisition and retargeting.

 

How it works: When a mobile application wants to provide in-app advertisements, it can work with ad exchanges and/or supply side platforms to reach potential advertisers. To do this, the mobile application will share certain device level data with the ad exchanges and/or supply side platforms when someone is using its mobile application and it wants to show them an advertisement. The ad exchanges and/or supply side platforms then make this device level information available to demand-side platforms in the form of “bid requests” (i.e., a request to bid on displaying an advertisement to the mobile app user).

 

Once a demand-side platform (e.g., MOLOCO) receives a bid request, it will help its advertiser clients decide how much to bid on displaying an advertisement based on a variety of factors.

 

MOLOCO determines this using various machine learning techniques. For example, we may use the event data provided to us by our advertiser clients (described below) to build lookalike targeting models that help our advertiser clients show advertisements to other mobile app users who are similar to their existing userbase.

 

Using these insights allows us to help advertiser clients decide which mobile app users to target and how much to spend on advertisements. Whenever our advertiser client has the highest bid to display an advertisement, it will win the bid request and the mobile app user will see its advertisement.

 

PERSONAL INFORMATION WE COLLECT

A Quick Note: Before we describe the types of information collected by the Advertising Services, it is important to understand that all information processed by the Advertising Services is solely at the device level and cannot, by itself, be used to identify a natural person in the real world. However, certain privacy and data protection laws still consider this device level data to be “personal information” which is why we use this terminology in our Privacy Notice.

 

Below are the types of information collected by the Advertising Services:

 

Event Data. MOLOCO’s advertiser clients often provide us with device level data that they have collected about users of their mobile applications. This information provides insight into the activities that the users have engaged in on the advertiser client’s mobile application. MOLOCO uses this information to create models that help the advertiser client determine what sort of users it should target with advertisements online and how much it should spend on advertisements. MOLOCO is a “processor” or “service provider” of event data and may only use this data in accordance with our advertiser client’s written instructions.

 

Bid Request Data. When MOLOCO receives a bid-request from an ad exchange or a supply side platform, we collect device level data contained in the bid-request which may include:

 

  • Advertising IDs (IDFA/GAID);
  • Device make, model and operating system;
  • Device properties related to screen size & orientation, audio volume and battery, device memory usage;
  • Carrier;
  • Operating system;
  • Name, properties, and other user info of mobile application through which a device interacts with the Advertising Services;
  • Country, time zone and locale settings (country and preferred language);
  • City- and/or country-level geolocation data;
  • Network connection type and speed;
  • IP Address; and
  • Internet browser user-agent used to access the Advertising Services.

 

Impression Data. When an advertiser client wins a bid and has its advertisement displayed to the mobile app user, MOLOCO collects information related to this transaction including the Advertising ID (IDFA/GAID) which was shown the ad.

 

HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including:

 

  • Providing the Advertising Services;
  • Developing machine learning models;
  • Serving tailored ads on behalf of our advertiser clients;
  • Measuring the performance of and optimizing advertising campaigns on behalf of our clients;
  • Analyzing trends;
  • Deriving insights;
  • Pursuing legitimate interests, such as fraud prevention, frequency capping, research and development (including marketing research), and network and information security;
  • Generating de-identified and/or aggregated data;
  • Improving the Advertiser Services;
  • Developing new products and services;
  • Ensuring internal quality control and safety;
  • Enforcing our agreements;
  • Complying with our legal obligations; and
  • As you otherwise consent.

 

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

We may share personal information with the following categories of third parties:

 

Advertiser Clients. If we deliver an advertisement to a mobile application user on behalf of an advertiser client, we may share information related to that transaction with our advertiser client and/or its mobile measurement partners. Your personal information may be subject to the advertiser client’s and/or its mobile measurement partner’s privacy policy. We are not responsible for the advertiser client’s or the mobile measurement partner’s processing of your personal information.

 

Service Providers. We may share any personal information we collect about you with our third-party service providers that help us provide the Advertising Services.

 

Affiliates. We may share personal information with MOLOCO’s affiliated entities.

 

Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.

 

Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, Belgium, Taiwan, the United States, or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

YOUR CHOICES

 Personalized Advertisements. You may limit ad tracking in mobile application environments by following the instructions for Android, iOS and others. For the most effective and up-to-date limit ad tracking methods, you should consult instructions provided by your device manufacturer.

 

YOUR PRIVACY RIGHTS

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

 

We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

 

Please note that because we are unable to authenticate any individuals whose device level data we receive from ad exchanges and/or supply side platforms, we are unable to fulfill such requests. In addition, we are not able to fulfill requests we receive where we act as a “processor” or “service provider” of personal information as our advertiser clients are the “controller” or “business” of this information and responsible for managing these requests.

DATA RETENTION

We store the personal information we receive as described in this Privacy Notice for as long as necessary to fulfill the purpose(s) for which it was collected, provide our Advertising Services, resolve disputes, establish legal defenses, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

 

SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE

 

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information MOLOCO, in its capacity as a business, has collected about them and whether MOLOCO disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

 

Category of Personal Information Collected by MOLOCO

Categories of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers

·        Service providers

Commercial information

·        Service providers

Internet or other electronic network activity

·        Service providers

Inferences drawn from other personal information to create a profile about a consumer

·        Service providers

 

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, MOLOCO does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

 

CHILDREN’S INFORMATION

The Advertising Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

 

SUPERVISORY AUTHORITY

 

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

 

CHANGES TO OUR PRIVACY NOTICE

 

We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you by posting an updating notice online.

 

CONTACT US

 

If you have any questions about our privacy practices or this Privacy Notice, please contact us at:

 

Attn: Privacy Group

MOLOCO Inc.

735 Shasta Street

Redwood City, CA 94063

 

privacy@molocoads.com