What Information Do We Collect and Why?
We do not collect name, email address or contact information from Users. However, in order to support the Phluant Platform and to display ads to Users we may automatically collect certain information from Users within an Internet or mobile site or application (“Site”), including:
IP Address, Android ID, MAC Address, Apple’s IDFA, UDID, and other unique identifiers; Activities and page views within a mobile Site; and Language information, device make and model, device connection, height and width of device, device volume, time zone and city, state-level location information, and operating system type, name, and version, browser types, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity.
We use various tracking technologies to collect this information, such as pixel tags, pixel impression trackers from Phluant’s or other third party services and other mobile tracking technologies. We may also receive a list of unique identifiers from Publishers and Advertisers, which we may use to determine to what End Users to display (or not display) certain ads.
Publishers may transfer certain information to Phluant that we use to enable the delivery of relevant advertisements to consumers on their mobile phones by our Clients. When our Publisher’s End User devices interact with our Platform, it may automatically pass information that our Publishers provide or is otherwise accessible on the advertising request. Phluant endeavors to receive the assurance from our Publishers that, through clear notice mechanisms, the Publisher has the right to pass such information to the Platform. This Publisher notice should advise the End User why the information is being collected and that it’s being used for advertising purposes. Phluant regularly works with its partners to provide improved mechanisms to manage consumer notice and control over their advertising experience in the mobile environment.
Phluant may also collect information about how End Users interact with ads delivered, such as anonymously counting clicks. Further, when available, Phluant, for the benefit of its Client, may partner with third-party companies that enable targeting of advertising based on information that is in addition to what the Publisher may provide or is otherwise available to Phluant. When partnering with these third-party data providers, Phluant does not accept, use or store this information. These services may have information about Users past browsing or application use, which can be used to enable the delivery of more relevant advertising to the User or for use in brand and ad effectiveness studies.
How We Use Your Information
We use the information that we gather in order to support Phluant Services and deliver ads to End Users, including:
- To display ads to End Users, to customize the ads we display to End Users and to optimize the display of ads;
- For performance tracking and frequency capping, such as tracking views of ads, as well as click-throughs and other ad interaction metrics;
- For billing purposes;
- To provide aggregate reports to Publishers and Advertisers; and
- To improve our Services and for other research and analytical purposes; and
- To send our Clients marketing and promotional information; we do not send such communications to End Users.
How We Share Your Information
We may share the information that we collect about End Users as follows:
Publishers and Advertisers
We may share aggregate information with Publishers and Advertisers about the advertising displayed to End Users and the success of ad campaigns. For Ads delivered by the Platform, we may share device attributes in order for Advertisers to successful deliver an ad opportunity.
We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on behalf of Clients.
In Response to Legal Process
We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
To Protect Us and Others
Aggregate and De-Identified Information
We may share aggregate or de-identified information about Users with third parties for marketing, advertising, research or similar purposes.
Ads within the Phluant Platform may contain links to third-party websites and mobile apps. Any access to and use of such linked websites or mobile apps is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties.
Opting out & Unsubscribing
How Can I Opt Out of Behavioral Targeting?
If you’d like to opt-out from having this information used to tailor advertising to you, please follow the instructions provided below. Note, we do not collect your name, email address, contact information, or other personally identifiable information.
Once you’ve opted out, we will no longer use information about your activities to deliver behaviorally targeted advertising to your device. You will continue to receive advertising after you opt-out, but it may not be tailored to your interests.
Depending on the type of device you have, you will need to either change settings on the device or submit your Device ID to us as noted below.
Opting out on iOS devices such as iPhones, iPads or iPods
If you have an Apple device, you can opt out of interest-based advertising by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to ‘ON.’ You can do this by going to your Settings, and clicking on ‘Privacy,’ then ‘Advertising,’ and then turning the ‘Limit Ad Tracking’ setting to ‘ON.’ Our system is designed to respect your choice and not use information to provide interest-based advertising when this setting is ON.
Opting Out on Android Devices
If you have an Android device and would like to opt out of our interest-based advertising, you can do so by entering your phone’s Android ID by going to your Settings, and under the Accounts section click on “Google” then click on “Ads” and then click on the ‘Opt out of interest-based ads’
How Can I Unsubscribe from Marketing Emails?
We may send periodic promotional or informational emails to our Clients (but not their End Users). Clients may opt-out of such communications by following the opt-out instructions contained in the e-mail, or by emailing us at firstname.lastname@example.org. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you transactional e-mails about your account or any services you have subscribed to.
What about COPPA?
We are not responsible for the information practices of our Publisher clients. Publishers are responsible for ensuring that their mobile sites and apps comply fully with the Children’s Online Privacy Protection Act (“COPPA”), including where relevant by obtaining parental consent prior to the collection of personal information.
Unique identifiers (e.g., IP address and device identifiers) are the only “personal information” under COPPA that Phluant collects from End Users. Phluant only uses the unique identifiers (and other associated information) it collects from End Users to support its internal operations.
We have implemented technical and administrative security measures to safeguard the information we collect from End Users.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at email@example.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site, at www.phluant.com/privacy.