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Privacy Policy

This Privacy Policy describes how the mobile advertising and business intelligence services (the “Services”) of 36 PRESENTS. (“36 PRESENTS” “We or “Us”) collect, store, and use information We receive about end users. Our Services provide advertising and business intelligence solutions to our clients and partners, which include working with publishers, advertisers, data partners, and third party ad exchanges across an advertising network of mobile applications (“Apps”) and websites (“Sites”). This Privacy Policy is subject to our Terms of Service.If you are interested in the privacy practices for the websites and mobile Apps owned by 36 PRESENTS, please email us at [email protected]

Information collected

Our Services receive information from and about end users (“Users” or “Data Subjects”) from our own Sites and Apps, from third party Sites and Apps that utilize affiliate software development tools or other collection interfaces, through our own and third party ad exchange services and data aggregation services we work with to provide the Services. As more described in this Policy, We may collect information such as your device ID (except in the EEA); IP address; geolocation data (if you have enabled your device to share location information); browser type; the website from which you accessed the Site or App; click-stream data about your activity on the Site or App such as the times you access the Site or App, and the pages and content you visit; and the types of products, services, and content along with retail locations in which you may be interested based on your online and App activities.Generally, the information we collect is not information that identifies you personally (“Non-PII”) Non-PII is information that is linked or reasonably linkable to a particular computer or device, including over time, but does not directly identify the individual. Non-PII may include browser, operating system and device information (except, for citizens in the European Economic Area (EEA)—see below), pages visited, language preferences, date and time an ad was served, clicks on ads, and other anonymous traffic data; geolocation data, a unique identifier (which may collect and use certain characteristics of your device to help us identify a device in connection with our Services over time); and aggregated information. If you have previously given consent for collection of geolocation information, You are always free to turn off geolocation (or limit it to certain mobile applications) or to adjust your advertising settings on your device.

Pixels, cookies and other persistence tools

Our Services may use cookies, pixels, or other tools that enable us to measure the effectiveness related to serving advertising and for business intelligence about the activities of Users on Apps and Sites. You are free to set your App and Sites consents, as well as your browser, operating system and device settings to de-activate the ability to identify your device persistently. Please refer to your mobile device settings, and your web browser and operating system’s settings, and your App privacy settings, for more information on how to disable your browser or operating system from receiving cookies and controlling your preferences, including to disallow sharing of device level information and to disable location access by the Site or App.

Information use

Our Services include advertising services that allow us to help our advertising and publishing clients provide more relevant advertising and content on the Sites and Apps on our Network and determine general interest in certain locations. In general, we use the information collected from and about you on Sites, Apps and from partners to enhance our advertising services by providing advertising and content that is more closely related to your interests. For example, the information is used to create audiences that are grouped together based on shared interests or preferences (e.g., Sports Fans, car enthusiasts, movie goers) and to measure the effectiveness of ad campaigns. Data used to create online audiences is de-identified, helping ensure that neither the ad server nor our cookies contains PII. While our advertising services are targeted, our system is set up to create anonymous user profiles and not to identify individuals specifically. We may share Non-PII, aggregated information, and de-identified information with our clients, advertisers and partners.Our Services also include business intelligence, data and attribution services, which involve robust data information and reporting to advertising clients and other customers, which look to us to provide reporting on trends and aggregated data activities. We use our internal, proprietary tools to manipulate the information collected as described above, including geolocation information. We only collect geolocation data if you have enabled it on your device and given permission to the Site or App. We utilize our technology to derive and provide our clients and customers with trend and statistical analyses, such as identifying patterns that will enhance the relevance of ads, providing advertisements to certain types of audiences, identifying and optimizing trade areas and business locations, and for helping our clients make informed business decisions about consumer behaviour with trend and movement information.36 PRESENTS does not knowingly collect data or create data segments that are based upon what we consider to be sensitive information (for example, we don’t create any data segments to determine religion, or credit worthiness). 36 PRESENTS may collect data to create health-related segments such as an inferred interest in diet and wellness, but not comprised of sensitive health data such as medical conditions or diseases. 36 PRESENTS does not sell its data products to law enforcement agencies for use in law enforcement activities or to monitor the movement of individuals or groups.We also receive pseudonymous information from third parties, when they choose to provide it to us. This information may include identifiers (like mobile advertising IDs) and interest-based advertising data tied to those identifiers, including segments provided by third-party data providers for our clients to use in targeting ads through the Services. 36 PRESENTS does not use this data to personally identify you.We may assign an 36 PRESENTS ID to your browser, computer or mobile device when we serve an ad to it or we identify it on a client’s website or mobile app. The 36 PRESENTS ID and other information collected via the Services can also help our advertising clients measure the effectiveness of advertisements delivered via the Services. They enable the Services to determine within a reasonable level of confidence that a computer or device is the same as one with which the Services has previously interacted. For instance, the Services can determine that a computer or device to which we served an ad on Monday may be the same computer or device for which we observed a purchase on Tuesday.In some cases, 36 PRESENTS is also able to infer within a reasonable probability that a particular computer or mobile device should be associated with the same 36 PRESENTS ID that we have previously assigned to another computer or mobile device. In other words, in such cases we are able to infer that a device (e.g. your computer) and another device (e.g. your smartphone) are used by the same user. Where we are able to make such inferences, we may use this information to deliver targeted ads across multiple computers or devices, and to improve the services we provide to our clients. This is sometimes referred to as cross-device advertising.

Information sharing

36 PRESENTS may share Non-PII with advertisers, clients, customers and partners as described above. We may also share information that includes PII, for the following purposes:
  • during due diligence or in preparation for or after a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation.
  • to another entity that is helping us make the Sites, Apps, and Services available and functional, like technical agents, payment processing vendors, other subcontractors, and our affiliates and consultants under contract and with safeguards. These functions include, for example, web site hosting, maintenance, data analysis, customer support, email delivery services, infrastructure services, technical agents, analytics and metrics services. These third parties will be restricted in the way they can use your Personal Information and will need to keep your information confidential and secure.
  • if permitted or required by law or where we believe such action is necessary in order to protect or defend our interests or the interests of our users, clients, partners, or business partners.
  • When businesses subscribe to our Services, the order process may request a credit card transaction. Order information is encrypted when it is transmitted for credit card processing to the credit card services provider and when returned to us. Encryption is a process by which we use software to scramble information in transit. We use a third party service provider to process payments made on our Sites, so your credit card information is not collected and retained by Us.

Security

All of the User Information is kept on servers that 36 PRESENTS manages, using reasonable administrative, technical and physical safeguards designed to protect against unauthorized access or disclosure of data. Please be aware that no data transmission over the Internet or information contained in our servers can be guaranteed to be 100% secure. As a result, while we strive to use commercially acceptable means to protect your information, we cannot guarantee or warrant its security.