This Privacy Policy
(the “Privacy Policy”) explains how information about you is collected,
used and shared by ClientConnect Ltd. d.b.a. “Trovi”, and its parent and
affiliates (“Trovi,” “we,” or “us”) when you install or
use a mobile application that utilizes our services, including our mobile
advertising platform, technology and related services (the “Service”).
PLEASE READ
CAREFULLY: BY DOWNLOADING, INSTALLING, ACCESSING, AND/OR USING THE APPLICATION
(AS DEFINED BELOW), YOU AGREE TO THIS PRIVACY POLICY, INCLUDING THE COLLECTION,
USAGE AND STORAGE OF YOUR INFORMATION AND THE TRANSFER OF IT TO THIRD PARTIES.
IF YOU DISAGREE TO ANY OF THE TERMS OF THIS PRIVACY POLICY, YOU MUST NOT DOWNLOAD,
CONNECT TO, ACCESS, ACTIVATE, OR USE THE APPLICATION, AND ARE OBLIGED TO
UNINSTALL, ERASE, OR REMOVE THE APPLICATION FROM YOUR MOBILE DEVICE.
1. How We Collect Your Data
1.1 Data Collected through Our Service.
Our Service enables mobile application developers to provide ad-supported
applications to end users. When you
download a mobile application that utilizes our Service (each, an “Application”),
we may collect, use and store information from your device, as follows:
(i) Personally
Identifiable Information (“PII”). PII is information that identifies
an individual, including amongst others, login credentials to a third-party
website, name, postal address, account information, contact lists and precise
location data. When you use the Application, you may enter certain information
that qualifies as PII, for example, when you type your own name, address and/or
other PII, whether in a web search, chat, email or other interaction in
connection with the Application.
In addition, the Application may access certain parts of your
device which store such PII including, without limitation, other applications
on your device, your friends or contacts lists, notes, internet browsing
history and photos. If you elect to permit the Application to access this
information, we may be able to see and use this information in accordance with
this Privacy Policy. By granting us permission to access this information, you
may also be changing your preexisting privacy settings on your device and for
other applications installed on your device. We recommend that you review the policies of other
applications on your device to understand how their privacy settings will be affected.
All PII collected by us shall be protected and used by us in accordance with
this Privacy Policy.
(ii) Aggregate
Information. Aggregate Information is information that cannot be used to
identify you personally, including without limitation, device ID, Advertiser
ID, device make and model, mobile web browser type and version, IP address, a
Trovi-generated ID, the Application name, a list of other applications
installed on your device and other technical data about your device. In
addition, Aggregate Information may include behavioral activity on your device
including use of other applications, web browsing activity on your device
including web searches and interactions with ad content through the Application
and other applications on your device.
(iii) Information
Collected from Device Permissions (“Device Permission Information”).
You may grant the Application permission to collect certain types of
information via a native permission screen consent process that runs on
installation. Please note that your
consent allows us to access such information. We do not control the permission
screen consent process – it is typically run by your mobile operating system
(e.g., Android or Apple iOS). We may
collect some, but not all, of the information that an Application collects in
accordance with the permissions you grant. For example, in accordance with your
permission, we may collect your contact list, precise geolocation, browser
history, country, zip code and device IDs (including IMEI, device serial number
and MAC address). Device Permission
Information may also include PII and/or Aggregate Information.
1.2 Data Collected from Other Sources.
We may also obtain information from other sources and combine that with
information we collect through our Service. For example, we may collect demographic or
interest preference information from other companies and combine that with
information we collect through the Service to deliver advertisements that may
be of greater interest to you.
2. How We Use Your Data
2.1 Our Efforts to Remove PII. We
use commercially reasonable efforts to quickly anonymize PII that we collect
from you. We also employ such filtering on our servers before information is
transferred to third parties. Such efforts include removing numbers and certain
symbols from information collected from you or changing PII into aggregate
information.
2.1 Use of All Information Collected.
We may use all information collected through our Service (including PII) for
the purposes described in this Privacy Policy, including to:
(i) Deliver, or
cause to be delivered by third parties, contextual and personalized and
interest-based content to your device such as news, messages, coupons, special
deals, ads, services, products and other relevant offers (including banners)
(the ”Content”);
(ii) Operate and
update the Service and provide you with the Service’s new and existing functionality
and features;
(iii) Monitor and
analyze trends, usage and activities in connection with our Service;
(iv) Enable quality
assurance and improve our Service including developing new features and
functionality improving and customizing your user experience of the Services;
(v) Provide
anonymous reporting for internal and external customers;
(vi) Notify you of
any updates to the Services;
(vii) Provide you
with support and handle your complaints and/or feedback;
(viii) Take any
action in any case of dispute involving you in connection with the Services;
(ix) Enforce the Service’s
Privacy Policy and to prevent unlawful activities and misuse of the Services;
and
(x) Comply with
any applicable law and assist law enforcement and governmental agencies when we
deem that our cooperation with them is compliant with applicable laws and
regulations.
2.2 Use of Non-Identifying Information.
As described above, the Service collects anonymized as well as aggregated
information, which does not identify you personally. Such information may be
used by us in any way, including posting, disseminating, transmitting or
otherwise communicating or making it available to third parties for commercial
and operational purposes as we deem necessary from time to time.
3. How We Share Your Data
3.1 How and What Information is Shared.
We may share information about you (including PII) as follows:
(i) We may
share information collected from you through the Service, including PII, with third
party advertisers and ad networks in order that we, and such third parties, can
provide you with more customized and relevant Content through the Service.
Please note that we require all third parties who receive any of your
information to comply with this Privacy Policy including the deletion of
information described in Section 5 below.
(ii) We may share
information with third party service providers and consultants who administer,
operate and maintain parts of the Service and who need access to such information
only to the extent necessary to carry out such work. We shall make best efforts
not to disclose any PII to third parties for this purpose unless absolutely
necessary.
(iii) We may share
your information with law enforcement or other competent authorities and any
third party, as may be required, if we believe that we are required by law to
disclose your information or if we reasonably believe that you have breached
this Privacy Policy, misused the Service, or in any case of dispute of any kind
involving you in connection with the Service (including but not limited to,
detect, prevent, or otherwise address fraud, security, or technical issues; to
respond to claims or satisfy any legal process, subpoena, or governmental
request; or to protect the rights, property, or personal safety of Trovi, its users,
its partners, or the general public).
(iv) In the event
Trovi goes through a business transition such as a merger, acquisition by
another company, consolidation, change of control, reorganization, bankruptcy,
or sale of all or a portion of its assets, your information will be among the
assets transferred.
(v) We may also
share PII with our sister companies, and parent companies, but their use of
such information must comply with this Privacy Policy.
3.1 Additional Sharing of Information.
In any case other than the above and as set forth in this Privacy Policy, we
will share your PII with others only if we receive your prior consent.
PLEASE NOTE THAT
ANY PII COLLECTED FROM YOU SHALL NOT BE USED BY US, OR BY ANY THIRD PARTY WHO HAS
RECEIVED YOUR PII UNDER THIS PRIVACY POLICY, FOR ANY PURPOSES OTHER THAN THE
PURPOSES SPECIFIED IN THIS PRIVACY POLICY. FOR EXAMPLE, YOUR PII SHALL NOT BE
USED TO IDENTIFY, LOCATE OR CONTACT YOU EXCEPT IN THE SPECIFIC CIRCUMSTANCES
DESCRIBED UNDER THIS SECTION 3.1 OR PURSUANT TO APPLICABLE LAW OR AN ORDER BY A
COURT OR GOVERNMENT AUTHORITY.
The Service may contain or present third party Content as well
as links to third party sites or mobile applications – all of which are not
owned or controlled by us. Using any third party Content (including by
following a link contained in the Content) may result in you sending
information to such third parties, who collect, use and store the information
in accordance with their own applicable terms and conditions and privacy
policies. Please carefully review the relevant terms and policies of such third
parties for information about their data collection, storage, and handling
practices before taking any action with respect to a third party or any
products and services offered by them.
5. Retaining and Deleting of Your
Data
We retain the information we collect as described in this
Privacy Policy for as long as necessary to fulfil our business and/or
operational purposes or comply with a legal request. We shall delete your PII
from our systems or anonymize it if we deem it no longer necessary for our
reasonable business needs.
6. Information Security
We implement measures consistent with industry standards to
secure your PII, to the extent collected, to minimize the risks of damage, loss
of information, and unauthorized access or use of information. However, these
measures are unable to provide absolute information security. Therefore,
although we make efforts to secure your PII, we cannot guarantee, nor should
there be any unreasonable expectation, that the Services and its databases are immune
from any wrongdoings, malfunctions, unauthorized interceptions, or access, or
other kinds of abuse and misuse.
7. Minors
To use the Services, you must be at least thirteen (13) years of
age. We do not knowingly collect any PII from minors under the age of thirteen
(13). Please note that we rely on the owners and distributors of Applications
to ensure that the Application is not distributed to minors. In the event that
it comes to our knowledge that a person of the age of thirteen (13) or under has
access to the Services, we will make all efforts to promptly delete and cease
the collection of any PII with regard to such a user, as applicable.
8. Access
You may send us a request to access the PII that we may collect
through your use of the Application. We may require that you provide us with
additional information to verify your identity.
9. Transfer of Information Outside
Your Territory
The Service, by its nature as an online ‘software as a service’,
may store and process information in various locations throughout the globe. If
you are a resident of a jurisdiction where transfer of your personal
information to another jurisdiction requires your consent, then you hereby
provide us with your express consent to such transfer of your data.
10. Your Choice to Opt-Out
If you would like us to cease collection of your PII, you can
opt-out by changing your advertising ID settings on your device. Please note
that opting-out will not cease operation of the Service (and display of Content
in the Application) or our collection of Aggregate Information.
If you would like us to cease collection of your information and
operation of the Service, you must uninstall the Application (and any other
application that utilizes our Service) using the standard uninstall processes
that your device requires for uninstallation and removal of an application. To
assist you in identifying Applications that utilize our Service, we instruct
the developer of an Application to provide a link to this Privacy Policy in
their Privacy Policy.
11. Changes to This Privacy Policy.
We may from time to time change this Privacy Policy. We
encourage you to visit and review this Policy frequently to stay informed.
If we implement
substantial changes, they will take effect after we have posted an initial
notification through the Service or through other reasonable means to notify
you of the changes. Other changes, including amendments made to the Privacy Policy
to comply with legal requirements, will become effective immediately upon their
initial posting, or as required. Trovi will also update the "Last updated”
date at the end of this Privacy Policy. You agree to be bound by any of the
changes made to this Privacy Policy. Your continued use of the Service or any
Application after the changes take effect will indicate your acceptance of the
amended Privacy Policy. If you do not agree with any of the amended terms, you
must avoid any further use of the Service.
12. Contacting Us
If you have any questions regarding this Privacy Policy, please
contact us by email at privacy@trovi.com, or please write to the address at
the bottom of this page.
Last Updated: 23 October 2014
