Last modified: Dec 19, 2019
Moloco, Inc (“Moloco”) is a mobile advertising company providing ad cloud technology as a service and helping
companies achieve their mobile marketing goals through user acquisition and retargeting.
We collect information and data in the following ways:
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).
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:
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:
We process this information on the basis of our legitimate business interest.
We process this information on the basis of our legal obligations and legitimate business interest.
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 firstname.lastname@example.org.
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:
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.
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:
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.
We perform the following automated decision making processes using your personal information:
In line with best practice in our industry, we respect End User’s rights to opt-out of receiving Interest Based Advertising.
If you want to limit or stop receiving targeted ads, there are several choice mechanisms available:
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:
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.
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.
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:
If you wish to exercise any of the above rights, please write to us, either by post or by e-mail at email@example.com and we will respond within 30 days.
Moloco compiles with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.
Moloco is responsible for onward transfers to our agents under the Privacy Shield Framework. With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Moloco is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission ("FTC").
If you have any questions or concerns related to our Privacy Shield certification or to resolve any complaints about our collection or use of your personal information, you should first contact us using the information set forth below.
Moloco has further committed to refer unresolved complaints related to personal information to JAMS Privacy Shield Dispute Resolution Program. With respet ato employee and human resources data, Moloco has committed to cooperate with the panel established by the EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner. Such independent dispute resolution mechanisms are available to citizens free of charge. You may submit a complaint using the information provided below:
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution options do not satisfactorily resolve your concerns.
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 firstname.lastname@example.org.
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.
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.
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.
735 Shasta Street
Redwood City, CA 94063