Vungle Privacy Notice

LAST UPDATED: December 17, 2019

Vungle, Inc. and its group companies (“Vungle”, “we” or “us”) respect your privacy. This privacy notice (“Notice”) explains who we are, how we collect, use and share personal information about you, and how you can exercise your privacy rights.

This Notice covers personal information we collect:

(a) when providing the Vungle Ad Services (see Section 2); and
(b) when you visit one of our Websites, and in the usual course of our business, such as in connection with our events, sales and marketing activities (see Section 3).

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We recommend that you read this Notice in full to ensure you are fully informed. However, to make it easier for you to review those parts of this Notice which apply to you, we have divided up the document into the following sections:

• Section 1 WHO WE ARE (applicable to everyone)
• Section 2 VUNGLE AD SERVICES (applicable to End Users)
• Section 3 VUNGLE WEBSITES (applicable to visitors to our Websites)
• Section 4 GENERAL INFORMATION (applicable to everyone).

We participate in and comply with the EU-U.S. Privacy Shield Framework to cover data we process from the European Union (“EU”). For further information, please review our EU-U.S. Privacy Shield Notice.

1. WHO WE ARE

Vungle is an ad network providing a technology platform (“Platform”) for Clients that want to advertise and/or monetize their applications, games, and other products. Our “Clients” include “Advertisers” that wish to distribute ad content through the Vungle Platform, and “Publishers” of applications that want to display relevant ads to end users (“End Users”) of third party applications (“apps”) that use our SDKs, APIs, hosted video advertising platform and/or any of our related advertising tools (collectively, the “Vungle Ad Services”).

Advertising revenue helps keep many games and apps free, and Vungle works hard to ensure that our ads are interesting, relevant, and safe for End Users.

2. VUNGLE AD SERVICES

This Section describes how Vungle collects and uses information we receive from End Users (“you”) of apps that use the Vungle Ad Services.

2.1 What information do we collect?

When you use an app supported by Vungle technology (see Section 2.3, below), our services can collect certain information about your mobile device. Some of this information (including for example, your IP address and certain unique identifiers), may identify a particular computer or device and may be “personal information” or “personal data” as defined under law in some jurisdictions (including in California and the EU, respectively) (hereinafter, collectively referred to as “personal information”). We collect this information the first time Vungle’s SDK is initialized on a Publisher Client’s app. Note, however, that Vungle’s Ad Services do not collect any information that that enables us to identify End Users personally (such as your name, address, or email address).

The information we collect includes:

• Information about your device, such as the type and model, manufacturer, operating system (e.g. iOS, Android, etc.), carrier name, time zone, network connection type (e.g., Wi-Fi, cellular), IP address, Vungle SDK version, information about the Publisher Client’s app currently active on your device (but not any other apps), and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID (AAID or GAID), or other unique device identifier (a number uniquely allocated to your device by your device manufacturer or Publisher Client’s app).
• Information about your behavior on our Publisher Client’s app, such as information about the activities or actions on those apps, and session start/stop time. Historic versions of Vungle technology may also collect geolocation information (e.g., latitude and longitude co-ordinates), but only (i) if the Publisher Client’s app has enabled location services on your device and (ii) you have granted the Publisher permission to collect this information). However, versions that are current as of the date of this Notice no longer collect geolocation information.
• Information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether you clicked on it, the number of times you have seen the ad, the number of Vungle ads viewed per session, and whether you visited the Advertiser’s website or relevant app store and/or purchased or installed the product or service advertised.
We may also combine and/or enhance the information we collect about your device, including the personal information, with information we may collect about your interactions with other ads served through Vungle’s Platform that you may view on other Publisher Client’s Apps, or with information collected from our Clients and third parties (such as data providers). This may include, for example, mobile device IDs, demographic or interest data, and content viewed or actions taken on an app to help make the ads served to you more relevant while limiting your exposure to less relevant ads. We (or our third party partners) may also use this additional information to undertake “user matching,” which means that in addition to the ID an End User has been assigned in our system, we may also receive a list of unique IDs our external partners or Clients have assigned to an End User.

2.2 How do we use your information?

We use the information, including the personal information, we collect (sometimes in combination with information provided and sourced by independent validation partners) for a variety of business purposes, including the following:

• Serving Ads: To allow Publishers to offer advertising inventory in their apps, and Advertisers to bid on and display ads in that inventory.
• Ad Reporting and Conversions: To allow Vungle to confirm with Advertisers information about when and how End Users have been exposed to their ads, clicked on their ads, or visited their website and to ensure accurate billing for advertising services rendered.
• Frequency Capping: Preventing End Users from seeing the same ad too many times.
• Customizing Ads: To customize and more effectively tailor the ads we display to you and to optimize the display of ads (including limiting your exposure to less relevant ads).
• Performance Analytics and Optimization: To analyze and optimize ad performance, such as tracking views of ads, implementing end user “whitelists” or “blacklists” (to ensure, in some cases, that certain ads are being viewed by appropriate audiences), as well as click-through rates to websites or app stores and/or installs of apps that have been advertised.
• Fraud Detection and Prevention: Identifying invalid clicks, installs, or ad queries, and protecting us and our Clients from fraudulent behavior.
• Providing and Improving the Vungle Ad Services: Auditing, researching, and analyzing data in order to provide, protect, and improve the Vungle Ad Services and to ensure that our technologies function properly.

2.3 How does Vungle use its technology to collect information?

We use our technology (in some jurisdictions, such as the EU, these may be referred to as “tracking technologies”) to collect information automatically from your device to perform many of the functions described in “How do we use your information?” above. To opt out of our use of such technologies, please follow the instructions for opting out in the apps, as described in “Your Opt-Out Choices” below.

The kinds of technologies collecting information that we use to provide our services include:

(i) Mobile “SDKs” or “Software Development Kits”: These are blocks of code that are embedded into an app allowing Vungle to collect certain information (as described in “What information do we collect?” above) relating to your use of apps using our technology. The embedded code from Vungle’s SDK allows the app to “speak” with Vungle’s Platform for purposes of delivering ads.
(ii) Mobile device identifiers: We also use standard device identifiers, for example the IDFA advertising identifier used on Apple’s iOS devices and the GAID advertising identifier used on Android devices, to monitor and improve the performance of the ads we show you.
(iii) Third-Party Ad Measurement URLs/Links: Additionally, in providing the Vungle Ad Services to our Advertiser Clients, the Vungle ads may include URLs or links from the Advertiser Client’s chosen third-party measurement partner to collect information about your interaction with those ads. The information collected is used for ad delivery, reporting, and billing purposes and may also be used for performance optimization.
(iv) “Tags and Pixels”: These are blocks of code that we and our Clients may use to monitor your interaction with apps using our technology. We may use these to synchronize information that we have collected with information independently collected by our Clients and other third party advertising platforms and advertisers that are interested in providing you with ads.

2.4 Your Opt-Out Choices.

You can opt out of having your information being used by Vungle for performance-based advertising by accessing your mobile device settings and following the most recent published instructions. If you limit ad tracking, you will still see advertisements (even ones sourced from Vungle’s network), but Vungle will no longer be able to use the personal information described above in Section 2.1 to serve you with more relevant ads. In addition, the advertising identifier (along with any information collected about that identifier) that was previously assigned to you will also be disassociated. This means that if at a later stage, you decide to opt back in, we will not be able to use any of your past information for advertising purposes, and you will (for all practical purposes) be a new user to our system. For apps using older versions of the Vungle SDK, you may also stop the collection of location information by particular apps that may allow collection of location of this information by changing the preferences on your mobile device.

2.5 How Do We Share Information?

Please see Section 4.1, below for information concerning how Vungle shares the information collected.

2.6 Privacy Practices of Vungle Clients.

Vungle is not responsible for the information practices of our Clients or their agents. We require our Clients to comply with all applicable laws and regulations and to provide End Users with notice of the collection of data for advertising purposes as outlined in this Notice. We encourage you to review the privacy policies of apps you visit for information about those apps’ data collection and use practices.

2.7 Minors and Children.

Our Clients are responsible for ensuring that their mobile apps comply with data privacy protection legislation applicable to minors and children, such as the United States’ Children’s Online Privacy Protection Act (“COPPA”), including where relevant by obtaining parental consent prior to the collection of personal information. With respect to COPPA specifically, we rely upon our Publisher Clients to confirm whether or not their app is subject to COPPA. As required by COPPA, Vungle will enable a flag in our system when a Client indicates their app is subject to COPPA such that the End User’s device history is disassociated, and the only End User personal information used by the Vungle Ad Services would be persistent identifiers (e.g., IP address and device identifiers) to provide “support for internal operations” of the Vungle Ad Services (as permitted by COPPA).

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