Effective Date: 03/09/2017
EU-U.S. Privacy Shield
Liftoff Mobile, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Liftoff Mobile, Inc. is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]
Liftoff Mobile, Inc. is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Liftoff Mobile, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Liftoff Mobile, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Liftoff Mobile, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Please note that this policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
(i) The information we collect;
(ii) Our use of the information;
(iii) Our sharing of the information; and
(iv) Your options for opting out of these practices.
II. WHAT INFORMATION DOES LIFTOFF COLLECT?
Depending on your interaction with the Services, Liftoff may collect information automatically and or when you voluntarily choose to provide it. We may also acquire information from other trusted sources to update or supplement the information that you voluntarily provide to us or that we automatically collect.
A. Information We Collect from Advertising Partners
If you are one of our Advertising Partners, we may collect the following information from you:
- Browser information
We also collect, from you, the following information about your contacts when you nominate a hero:
- Full Name
- Work email address
When you provide us with personal information about your contacts we will only use this information for the specific reason for which it is provided. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at email@example.com.
B. Information We Collect From Consumers
If you are a Consumer that uses or otherwise interacts with our website or the services, we may collect and transfer non-sensitive device information provided by our advertising exchange partners that may consist of the following:
- Generic geographic location
- Device make, Manufacturer, Operating system and Language Settings
- Name of application interactive with Liftoff Services
- IP Address
- Android ID or Identifier for Advertisers (IDFA)
- Connection speed
C. Information You Provide to Us
We receive and store any information you knowingly provide to us. For example, we collect Personal Information such as your name, email address, browser information. You can choose not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features.
If you have provided us with a means of contacting you, we may use such means to communicate with you. For example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Services. Also, we may receive a confirmation when you open a message from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by changing your user preferences. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the services, and you are responsible for reviewing such legal notices for changes.
Additionally, you may sign up to receive reports and communications from us. If you would like to discontinue receiving any information that you receive from us, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or at your member profile on our website or by contacting us at firstname.lastname@example.org.
D. Information Collected Automatically:
As is true of most websites and advertising companies, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
User Data Supplementation
We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, deliver our marketing services and provide products and services that may be of interest to you. If you provide us Personal Information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Advertising Partners wishing to opt out from information from Liftoff can click “UNSUBSCRIBE” in marketing emails or email us at email@example.com.
Examples of the types of Personal Information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include purchased marketing data from third parties that is combined with information we have been provided by business partners , to create more tailored advertising and products.
Cookies and Tracking Technologies
III. WHAT DOES LIFTOFF USE THE PERSONAL INFORMATION FOR?
Uses of Information We Collect
IV. WILL LIFTOFF SHARE ANY OF THE PERSONAL INFORMATION IT RECEIVES?
Sharing of Information We Collect
We neither rent nor sell your Personal Information in personally identifiable form to anyone. However, we do share your Personal Information with third parties as described in Section II and in this Section:
Affiliated Businesses and Third Party Websites We Do Not Control.
In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies. If you have any questions about these practices, please contact us at firstname.lastname@example.org.
We employ other companies and people to perform tasks e.g., provide computer and network infrastructure services on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
User Profiles and Submissions
Certain user profile information, including without limitation a user’s name, location, and any content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for Company’s services.
We may also disclose your Personal Information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
If Liftoff Mobile, Inc. is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.
V. HOW CAN I OPT OUT OF SEEING INTEREST-BASED ADVERTISING FROM LIFTOFF?
Refer to our opt out page for instructions.
The security of your Personal Information is important to us. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once it is received. If you have any questions about the security of your Personal Information, you can contact us at email@example.com.
Upon request, Liftoff Mobile, Inc. will provide you with information about whether we hold any of your Personal Information. You may access, correct, or request deletion of your Personal Information by contacting us at firstname.lastname@example.org. We will respond to your request within a reasonable timeframe.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Service / Analytics Platform Disclosure
If you are using our analytics platform, the use of information collected through our service shall be limited to the purpose of providing the service for which you have engaged Liftoff Mobile, Inc.
Liftoff Mobile, Inc. collects information under the direction of you and its customers, and has no direct relationship with the individuals whose personal data it processes. If you are a client 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.
Liftoff Mobile, Inc. acknowledges that you have the right to access your Personal Information. Liftoff Mobile, Inc. has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Liftoff Mobile, Inc.’s customer (the data controller). If requested to remove data we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of our customers for as long as needed to provide services to our customer. Liftoff Mobile, Inc. will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Liftoff Mobile, Inc.
541 Cowper Street
Palo Alto, CA 94301