End User Privacy Policy

Last updated: 15.03.2022

 

The present document offers information about Mobinner's Demand Side Platform (Mobinner DSP) and our advertising technology. Mobinner LLC is a Delaware entity with a principal business address at 1330 Avenue of the Americas, Suite 23A, New York City, NY 10019, USA. The entity is incorporated under the laws of the United States of America, EIN: #37-1951556. It owns and develops digital advertising technology that allows advertisements (also known as "ads") to appear on websites (desktop and mobile) and mobile apps. This document is meant to provide transparent insight into how the Mobinner DSP platform works and how it processes, collects, and stores data. We understand the terminology related to the topic may sound complicated, so we will present the information in simple terms to make our data processing policies clear.

Mobinner is fully dedicated to the protection of Internet user privacy and the promotion of users' confidence in online marketing and advertising. As such, we follow strict industry guidelines, including those established by the Interactive Advertising Bureau and along with any other relevant guidelines. Additionally, we are committed to evaluating improved measures to keep users' privacy protected while also delivering relevant and customized advertising experiences to users on our clients' behalf.

This document provides a complete outline of Mobinner's End User Privacy Policy to provide a clear understanding of how we may collect user information and process it in connection to the services we provide. Please note that if you reside in California, the Additional Notice for California End Users applies to you, in accordance with the California Consumer Privacy Act effective since January 1, 2020.

Our End-User Privacy Policy is aimed exclusively at end-users, meaning users of Internet-connected devices, which refers to website visitors, mobile app users, IoT device users, and visitors on advertisements, landing pages, or campaigns. If you are a customer, our Privacy Policy is more relevant to you and you can read it by clicking here.

Customers use our Mobinner DSP technology to launch digital advertising campaigns. These operations allow customers to have direct (when advertisements are clicked) and indirect (when advertisements are displayed on websites and apps) interactions with Mobinner servers.

 

I. Glossary

 

  • Applicable laws: It refers to all the laws that apply to the collection, processing, and storage of data, especially data protection laws. Such as the California Consumer Privacy Act ("CCPA"; California Civil Code Section 1798.100 et seq.).

 

 

  • Ad exchange: It refers to a platform where people can offer and purchase ad placements for online advertisement. Think of it as a digital marketplace where people auction unsold ad placements through real-time bidding. Anyone can purchase them, including platforms or ad exchanges that also sell advertisements placements.

 

  • Ad server: It refers to servers that store, manage, and deliver advertisements to website end users. Additionally, it might feature a reporting module to track the performance of the advertisements.

  • Cookie: It refers to small text files that websites or ad servers store locally. Cookies allow web browsers or ad servers to store certain information to remember user preferences and recognize what websites you visit and what web browsers you use to visit one site or another. For further understanding of cookies and how to disable them, go to All About Cookies.

 

  • Customer: It refers to the party that registers to Mobinner's platform on the registration page and makes use of it for advertisement purposes.

 

  • Demand Side Platform (DSP): It is the technology used by the buy/demand party through a single interface.

 

  • Domain name: It refers to the character string that allows you easily access a website without having to commit IP addresses to memory. Domain names must be unique and it allows users to navigate websites and discover online ads.

 

  • Do Not Track (DNT): It refers to an option provided by web browsers. Once enabled, your web browser sends a request to your web app to disable tracking of an individual user.

 

  • End-user (visitor): It refers to users of devices that are connected to the internet. That includes mobile app users, website visitors, IoT device users, and visitors of ads, landing pages, or campaigns.

 

  • Geographic location: It is information that relates to your location and it's based on IP address. It refers to the location of your device, which is connected to the internet, and it allows us to identify the country, region, city, and Internet Service Provider (ISP) of said device.

 

  • HTTP request header: HyperText Transfer Protocol (HTTP) is used worldwide. Almost all the content that you can find on your browser is transmitted to your device over HTTP. For example, when you opened this policy in your browser, it sent several HTTP requests. Each of the requests featured an HTTP request header with information about the kind of browser you use, the page you've requested, servers, and more.

 

  • HTTP request parameters: These are additional pieces of information sent from one device to another. This is what you see on your browser's address bar in the form of name=value pairs separated from the URL by a question mark (?). There might be several name=value pairs separated by an ampersand (&).

 

  • IP address: An Internet Protocol (IP) address is a unique set of numbers that each device has to connect with other devices over the Internet. It allows the information to be delivered to the right user. Each time information is sent, a device needs to communicate with other devices in the network to deliver that information. Whether that's an email, application downloads, Internet surfing, etc. The IP address is the identification number of devices. Without it, it would be impossible for the right information to reach the right users.

 

  • Personal information/data: It refers to information related to an identified or identifiable natural person, as defined by applicable laws, more specifically Section 1798.140 of the CCPA.

 

  • Processing: It refers to any operation that is related to personal data, whether it's automatic or not. That includes collection, organization, recording, storage, adaptation or alteration, retrieval, discussion, usage, divulging by transmission, publishing or alternatively making available, arrangement or unification, hindrance, deletion, or destruction. This meaning extends to process, processes and processed.

 

  • Real-time bidding: Mobinner clients with access to the Mobinner DSP area are able to make real-time biddings on online ads offered by ad exchanges. The winner of the auction will be able to display the ad on a website.

 

  • Referrer domain: It refers to the website address that leads you to another page.

 

  • Retargeting: It refers to an online targeted advertising strategy where the information is collected to address the preferences of visitors based on past actions or choices. For example, when you search for a new pair of shoes, the ad shown to you will be of shoes you might like.

 

  • Request time: It refers to the time when a query is sent to the Mobinner database, which is each time you click on an advertisement. This way, the Mobinner platform can store the information related to your website visitors.

 

  • User agent: It refers to the information of the device, operating system, and web browser you use to visit a website.

 

  • You (visitor): It refers to the person who can visit digital advertising campaigns on the Internet.

 

II. An Introduction to Mobinner

 

Mobinner is an advertising technology platforms that serves digital advertisers. It allows them to launch and keep track of the progress, success, and profitability of online marketing and advertisement campaigns.

Mobinner collects and processes all kinds of data to create statistics and reports. This creates a record of information that allows our advertisers to create meaningful and effective campaigns online. In the following sections, we will explain the kind of information Mobinner stores and how it relates to the actions you take as a visitor and Internet user.

 

III. Mobinner's Role in Processing Personal Information

 

Mobinner is the data controller of the end-user data we've collected. Mobinner LLC is a Delaware company EIN #37-1951556, having a principal address at 1330 Avenue of the Americas, Suite 23A, New York City, NY 10019, further referred to as "Mobinner".

Acting as a data controller for Mobinner DSP allows us to process end-user data legally, following the legal basis described in section VII. Legal Basis for Processing User Information.

IV. What Kind of Data Does Mobinner Collect and What For?

 

To perform the services already described, Mobinner collects and processes certain information from end-users and their devices. Some of the information we collect, such as the IP address, may identify particular computers or devices, so it may be considered personal data in certain jurisdictions, including the state of California. This is the type of data that allows us to create aggregated reports and analyses on the performance of ad campaigns.

Mobinner doesn't collect any data that can identify individuals by itself, such as names, phone numbers, addresses, email addresses, etc. We also don't collect "sensitive" or "special categories of personal data. Additionally, we don't collect personal data of children, as defined by applicable laws.

Let's break down the kind of data we collect and process on the Mobinner platform:

  • IP Address

IP addresses are utilized to determine the location of devices and, to a certain extent, the location of the user. Based on the IP address, we can collect information such as country, region, and city visitors are from to characterize and store that data on our platform.

Additionally, we process certain technical specifications, such as a mobile carrier or Internet Service Provider (ISP) of the users, as well as what kind of connection you have. This information is stored to allow clients to make changes to the online ads that are shown on websites. Also, it allows us to identify automatic computer software that could affect our clients' reporting. The IP address also allows us to limit how many times visitors are shown a specific ad.

  • User Agent

A user agent allows us to identify the type of device and model visitors are using to be on the internet. Whether that's a desktop computer, laptop, tablet, mobile phone, smart TV, etc. We store this information to determine the parameters of the device, including the browser and the OS, as well as the version being used. Also, it helps us detect automatic computer software and fraud efforts. A user agent also limits the number of times visitors are shown a specific ad.

  • HTTP Request Header

We use the information on the HTTP request header to identify the language and referrer domain of visitors. This information is used to show visitors appropriate ads and it's also stored for analysis.

  • HTTP Request Parameters

We use the HTTP request parameters to send data from third-party services to our platform, and vice versa. This way, our clients can effectively find target audiences and send their messages via appropriate channels. Additionally, this data is stored for analysis.

  • Device ID

A device ID is exactly what it sounds like. It's a unique identifier that allows us to measure the actions of a specific device. The device ID is important for personalization, distribution, and the performance of the traffic visitors receive.

This allows us to perform cross-device matching, which means clients can display ads on a specific device of particular users. So, if you own several devices connected to the internet, the device ID helps us identify you and the ads you've been shown so you don't get repeated ads.

  • Request Time

The request time refers to the exact date and time of interaction with our servers at Mobinner. This information helps us present appropriate ads to end-users and we also store them for analysis.

  • Unique Identifier (UID)

Unique identifiers are created by Mobinner and it allows us to match registered events and manage their frequency on our platform. Do keep in mind that publisher partners may provide us with additional demographic information (age, gender, etc.) for more exact targeting. This information is not used to create user profiles on our database.

 

V. How Does Mobinner Collect Data?

 

The Mobinner platform makes use of cookies, to collect data from the devices or web browsers visitors use. Mobinner takes advantage of persistent cookies which help to improve the web visitor experience surfing through websites on the internet.

Persistent cookies are stored in visitors' devices and their web browser may use the information on subsequent visits to websites.

In other words, persistent cookies store user preferences so our clients can personalize the content of their advertisements.

  

 

Mobinner DSP

The digital advertising tool Mobinner DSP uses the following technology to collect information:

  • Sync cookies. This type of cookie stores data to let us know if visitors have seen advertisements before. This way, we can vary the content so visitors don't see the same ads over and over. It also allows clients to improve ad selection. Sync cookies provide visitors with a unique number whenever an ad is shown to them for the first time, this is how it keeps track and it lasts 30 days.

 

  • Opt-out cookies. This cookie determines the information visitors don't want us to track on mobile and desktop environments. The cookie lasts up to 2 years.



  • Tracking pixels. This is a 1x1 pixel tag, so it's tiny, and Mobinner clients can place it on websites. So, when a visitor opens the tagged website, Mobinner will receive the information. Pixel tags are combined with cookies to follow people's activities while they use particular web browsers and devices to surf the web.



 

VI. Why Does Mobinner Use End-User Data?

 

Mobinner collects and stores data to improve advertisement relevance and adjust advertisement display so it can address the evolving needs of visitors. More specifically, the end-user data collected by Mobinner is used for the following purposes:

  • Cross-Device Matching. We use data to identify the devices a visitor uses to reduce the repetition of advertisement displays.

  • Fraud Detection. We use data to track the traffic quality for clients and blacklist the sources that generate fake clicks or website visits.

  • Frequency Capping. We use data to limit the number of times users see a particular ad.

  • The Report, Analysis, and Optimization. We use data to see how effective online advertisement campaigns are. This allows us to show ads to the right audience based on data. This improves campaign performance and also allows us to determine how visitors respond to ads.

  • Retargeting. We use data so our clients can address visitor preferences based on the actions or decisions they've made before while visiting a website or interacting with ads.

 

VII. Legal Basis for User Data Processing

 

Mobinner DSP and Mobinner LLC do not operate in the European Economic Area (“EEA”) or the European Union (“EU”). If end-users live in the EU or EEA, the legal basis Mobinner follows to collect and use end-user data as described above will depend on the visitor's information and the specific context in which it was collected.

Mobinner depends on your consent when we process personal information to provide end-users with targeted ads and we use cookies on end-user devices. If we depend on consent to collect and/or process end-user data, we will obtain said consent following applicable laws.

Mobinner may also use end-user personal information based on our legitimate interest to:

  • Run our technology and make improvements

  • Facilitate standard ad controls

  • Create reports to summarize visitor activity

  • Analyze ad performance (including views on ads and click-through rates), and create reports for ad performance, campaign performance, and campaign forecasting

  • Investigate, discourage, and defend against fraudulent, unauthorized, or illegal activity

If you have any questions, concerns, or need further information about our legal basis for collecting and using end-user data, don't hesitate to Contact Us.

 

VIII. How Long Does Mobinner Keep End-User Data?

 

Data collected by Mobinner is stored following the accepted security standards. We retain the data on our platform for 2 years (24 months) from the day users registered their accounts. The data will be used for analysis and reports. When clients remove data, storage and retention of that data are ruled by our Privacy Policy and the relevant regulations. The process of data removal from the Mobinner platform may take around 30 days.

 

IX. End-User Choices and the Opt-Out Option

 

The opt-out option is available for end-users who see an online ad provided by a client. Ad visitors that are part of the Mobinner DSP have the choice to opt out. We will explain how to proceed when choosing this option in the following section.

If you want Mobinner to stop tracking your desktop or mobile environments, you should use the opt-out option. Mobinner clients must deliver this option and make it accessible to all ad visitors. Our platform goes above and beyond to support clients so they can provide end-users with this option.

  

The Opt-Out Option on Mobinner DSP

If you want to opt-out of being tracked on desktop and mobile environments from Mobinner DSP, click here (note that third-party cookies must be enabled).

Desktop Website Environments

To stop being tracked on desktop website environments, here's what you need to do on Google Chrome:

  1. Go to your web browser menu, which you'll find at the top right corner of the window.

  2. Go to Settings and click on "Advanced."

  3. Go to Privacy and Security > Content Settings > Cookies.

  4. Click on the "Block third-party cookies" toggle to turn it on.

If you're using the Safari web browser, follow these steps:

  1. Go to the main menu, click on "Safari" and then "Preferences".

  2. Go to Privacy and check the "Block all cookies" box.

  3. Click on "Block All" to confirm.

 

Mobile Website Environments

To stop being tracked on mobile website environments, here are the steps to follow on Google Chrome:

  1. Go to your web browser menu.

  2. Tap "Settings" and swipe down to see the "Advanced" options and tap on "Site Settings".

  3. Tap on "Cookies".

  4. Unselect the option "Allow third-party cookies".

On Safari, you need to:

  1. Go to Settings on the browser.

  2. Tap "Settings" and then "Privacy".

  3. Swipe down to find the "Advertising" section.

  4. Toggle the option "Limit Ad Tracking".

Once you opt-out, this is valid for at least 2 years. Meaning that your data won't be tracked on the web browser where you set the opt-out option. That means that if you use other browsers, you will have to repeat the opt-out procedure on those browsers as well. After 2 years, the opt-out option will expire so you will need to opt-out again if you wish to not be tracked.

 

The Do Not Track Option

You can opt out of being tracked on desktop and mobile environments from Mobinner DSP.

 

Desktop Website Environments

If you want to turn on the Do Not Track option, follow these steps on Google Chrome:

  1. Go to the web browser Menu.

  2. Click on Settings and scroll down to "Advanced".

  3. Go to "Privacy and Security" and go to "Send Do Not Track Request". Toggle on the option.

  4. Click on "Confirm" to activate the option.

If you're using Safari, here's what you should do:

  1. Go to the main menu and click on "Safari"> "Preferences".

  2. Go to "Privacy" and click on "Ask websites not to track me."

Mobile Website Environments

To turn on the Do Not Track option on your mobile browser, follow these steps for Google Chrome:

  1. Go to your web browser menu.

  2. Tap "Settings" and swipe down to the "Advanced" options.

  3. Tap "Privacy"> "Do Not Track" and toggle the option to turn it on.

If you use Safari, here's what you should do:

  1. Go to your device settings.

  2. Tap "Safari" and swipe down to the option "Ask Websites Not to Track Me".

  3. Toggle the option to activate it.

 

X. European Data Subject Rights

 

Mobinner does not operate in the European Union or the European Economic Area. If you live in the European Union or the European Economic Area, you enjoy additional rights and protections under the law for collecting, processing, and use of data.

Under certain circumstances, users may also object to Mobinner's processing of end-user data when it includes personal information based on legitimate interests and there's no overriding this to allow us to continue processing personal information, or if your information is processed for direct marketing objectives.

If you consent to the processing of your data, you can likewise withdraw that consent and it won't affect the compliance of the processing that was already conducted on its basis before you withdrew consent.

Additionally, you have the register a complaint with the relevant Supervisory Authority if you determine that Mobinner has not responded to your requests to solve an issue. You may find the contact details of the data protection authorities by visiting ec.europa.eu

 

If you have any questions about your rights, please contact us at: legal@mobinner.comPlease make sure to include all the relevant information so we can verify your identity. Or you can use the opt-out option at https://mobinner.com/opt-out.html

 

 

XI. Information Transferred from Third-Party Services (Mobinner DSP)

 

The end-user privacy policy only applies to data usage by Mobinner and it doesn't explain the practices of third-party services such as networks or advertisers. We don't have any control over the privacy policies of third-party services, so it's your responsibility to familiarize yourself with their policies. To make it a bit easier for you, here is a full list of the privacy policies of third-party services:

  1. AdColony, Inc. Privacy Policy

  2. Adnow.com Privacy Policy

  3. AdUnity Privacy Policy

  4. Adventure Alternative Policies

  5. ADYOULIKE Privacy Policy

  6. AerServ LLC Privacy Policy

  7. AppNexus Platform Privacy

  8. Axonix Ltd Privacy Policy

  9. Beachfront Media, LLC

  10. BIDSWITCH Privacy Notice

  11. Bidtellect, Inc. Privacy Policy

  12. British Virgin Islands Company, an exclusive agent of Revmob, Privacy Policy

  13. Cox Media Group, Gamut, Privacy Policy

  14. Engageya Privacy Policy

  15. ENVISIONX Ltd Privacy Policy

  16. Fyber Group Privacy Policy

  17. glispa Privacy Policy

  18. Inneractive: Fyber Group Privacy Policy

  19. ironSource Ltd. Privacy Policy

  20. Ligatus GmbH, Christophstraße 19, 50670 Cologne, Germany Privacy Policy

  21. LiveIntent Services Privacy Policy

  22. MADS Mobile-First Advertising Platform

  23. MGID Privacy Policy

  24. Mobfox Privacy Policy

  25. MoPub Privacy Policy

  26. Native Ads Privacy Policy

  27. Nativo, Inc., a Delaware corporation Privacy Policy

  28. Oath Privacy International

  29. OpenX Software Ltd. Privacy Policy

  30. Outbrain Privacy Policy

  31. Playtem Terms and Conditions (French)

  32. Polymorph Labs, Inc. Privacy Policy

  33. PubMatic, Inc. Privacy Policy

  34. PubNative GmbH, Greifswalder Str. 212, 10405 Berlin Privacy Policy

  35. PulsePoint, Inc. Ad Exchange Privacy Policy

  36. Purch Group, Inc. Privacy Policy

  37. PowerInbox Privacy Policy

  38. Revcontent Privacy Policy

  39. RhythmOne Privacy Policy

  40. Rubicon Project Consumer Online Profile and Opt Out

  41. Sharethrough Privacy Policy

  42. Smaato, Inc. Privacy Policy

  43. Smart AdServer Policy

  44. Sovrn Holdings, Inc. Privacy Policy

  45. Switch Concepts Privacy Policy

  46. Triple Lift, Inc. Privacy Policy

  47. WO Programmatic Digital Policies

 

You should also know that Mobinner may disclose your data to the following types of recipients:

  • Third-party service providers who offer data processing services that support Mobinner and act on our behalf. Including IT service providers, analytics providers, etc.

  • Mobinner partners and clients who use data such as location context and general statistics to provide interest-based ads.

  • Competent law enforcement entities, regulatory agencies, government agencies, courts, and other third parties whenever we believe disclosure is a must either under applicable law or in response to requests from aforementioned agencies and authorities.

 

XII. Additional Notice for End-Users Located in California

 

If you are located in California, United States, there are special additional provisions that apply to you, under the California Consumer Privacy Act effective from January 1, 2020 ("CCPA"). The remaining provisions described in this End-User Privacy Policy apply in matters that are not included in this section.

If you have any questions, doubts, or concerns regarding the contents of this section or the scope of application, please contact us at legal@Mobinner.com.

 

California End-User Rights

The CCPA offers additional privacy protections to California end-users. That means you have the right to:

  • Ask for access to your personal data and request additional details about Mobinner's practices regarding the way we process personal data.

  • Ask for the deletion of personal data.

  • Opt-out of the "sale" of your personal data.

  • Not be discriminated against exercising any of your CCPA rights.

 

You can make personal information access or deletion requests and non-discrimination requests by contacting us at legal@mobinner.com or through our contact form, click here. You can opt-out by visiting the page Do Not Sell My Personal Information.

When you make your request, please provide all the information we need to reasonably verify your identity. Describe your request in detail so we can understand, evaluate, and provide a proper response.

Keep in mind that if you want to exercise any of these rights with any Mobinner client, you must make the request to them because they supply individual procedures and have their own policies in place, which are separate from Mobinner policies.

 

Disclosure

Personal Data Categories. Mobinner may gather the following kinds of personal data about you or your devices: IP Address, User Agent, HTTP Request Header, HTTP Request Parameters, Device ID, Request Time, Unique Identifier (UID). If you wish to read a more detailed description of these, refer back to section "IV. What Kind of Data Does Mobinner Collect and What For?" for more information. We don't collect any data that may identify individuals, such as names, addresses, email addresses, and phone numbers.

Mobinner may have collected all of the types of personal information mentioned above during the last year before the last update of the End-User Privacy Policy.

Purposes of Personal Data Use. Mobinner collects and stores data intending to increase advertisement relevance and adjust advertisement displays so they can match the evolving needs of visitors. More specifically, we may use the personal information for Cross-Device Matching, Fraud Detection, Frequency Mapping, Reporting, Analysis and Optimization, Retargeting. If you wish to read a detailed description of these purposes, please refer to section "VI. Why Does Mobinner Use End-User Data?"

Additionally, we may use the collected and processed personal data for business purposes under the CCPA. The following table describes the specific business purposes:

Personal Data Category

Business Purposes of Personal Data Use

IP Address, User Agent, HTTP Request Header, HTTP Request Parameters, Device ID, Request Time, Unique Identifier (UID)

Audits related to current interactions with end-users and transactions, including, but not limited to: tracking ad impressions of individual visitors, verifying positioning and advertisement impressions quality, and auditing compliance.

IP Address, User Agent, HTTP Request Header, HTTP Request Parameters, Device ID, Request Time, Unique Identifier (UID)

Discover security events, providing protection against activity that's malicious, fraudulent, deceptive, or illegal, and the prosecution of the responsible parties of said activity.

IP Address, User Agent, HTTP Request Header, HTTP Request Parameters, Device ID, Request Time, Unique Identifier (UID)

Debugging to discover and fix errors that cripple the intended functionality of our platform.

IP Address, User Agent, HTTP Request Header, HTTP Request Parameters, Device ID, Request Time, Unique Identifier (UID)

Transient use in the short-term, including, but not limited to contextual personalization of advertisements displayed in an interaction.

IP Address, User Agent, HTTP Request Header, HTTP Request Parameters, Device ID, Request Time, Unique Identifier (UID)

The performance of services such as account maintenance or servicing, customer service, processing or fulfillment of orders and transactions, verification of customer information, payment processing, offering of advertising and marketing services, analytics services, and other similar services.

IP Address, User Agent, HTTP Request Header, HTTP Request Parameters, Device ID, Request Time, Unique Identifier (UID)

Conducting internal research for the purposes of technological development and exhibition.

IP Address, User Agent, HTTP Request Header, HTTP Request Parameters, Device ID, Request Time, Unique Identifier (UID)

The performance of activities that help us verify or maintain the quality and safety of services or devices that are owned, manufactured, manufactured for, or controlled by Mobinner, as well as the improvement, upgrade, or enhancement of such services or devices.

 

Your personal data may have been used by Mobinner for these purposes during the year before the last update of the End-User Privacy Policy.

 

Sale of Personal Data

Due to the specific nature of the services we provide at Mobinner through our Mobinner DSP platform, we may sell your personal data (as defined by the CCPA) to advertising networks, clients, or partners. We provided a full list of the third-party advertising networks we collaborate with, please refer to the section "XI. Information Transferred from Third-Party Services (Mobinner DSP)" to check it out.

Additionally, our customers may use the Mobinner DSP platform to sell or purchase personal data (as defined by the CCPA) to demonstrate interest-based ads in apps or websites. The CCPA provides a broad definition of what it means to "sale" personal data, so that's something to keep in mind. For instance, the definition includes swapping a variety of data available for "valuable consideration".

The year before the last update of the End-User Privacy Policy, we or our clients may have sold the following types of personal data through our services: IP Address, User Agent, HTTP Request Header, HTTP Request Parameters, Device ID, Request Time, Unique Identifier (UID).

Section "XV. Children" explains that we don't sell personal data regarding minors under the age of 16.

We are dedicated to protecting our clients' privacy and supporting them so they can provide solutions for end-users such as the opt-out option. Being a California end-user means you can instruct us not to sell your personal data by opting out. For more detailed information and instructions on the opt-out option, visit our "Do Not Sell My Personal Information" page or send us an email at legal@mobinner.com.

 

Sharing Personal Data for Business Purposes

If we need to share your personal data for business purposes in any way, it's not considered a sale under CCPA. For instance, third parties such as service providers who operate on our behalf agreed to our contractual limitations regarding the retention, use, and disclosure of personal data.

In the year before the last updated version of the End-User Privacy Policy, we may have shared the following kinds of personal data: IP Address, User Agent, HTTP Request Header, HTTP Request Parameters, Device ID, Request Time, Unique Identifier (UID).

If you wish to know more about the third parties we share this information with, refer to the section "XI. Information Transferred from Third-Party Services (Mobinner DSP)" in the present End-User Privacy Policy.

 

XIII. Personal Data Transfer Outside EEA

 

Mobinner works exclusively with clients and partners located in the United States of America (USA). To guarantee that your personal information is protected when sent outside of the EEA, we rely on the decision made by the European Commission, which states that a third country may provide the adequate level of data protection or standard contractual clauses assimilated by the European Commission (the EU Commission Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses personal information transfer to third countries following the Regulation (EU) 2016/679 of the European Parliament and the Council).

If you need a copy of the safeguards Mobinner has adopted to protect your personal information when it's sent outside of the EEA and privacy rights, please contact us. If you wish to know more about the EU Commission Decision on standard contractual clauses when it comes to the transfer of personal information to entities in a third country, click here for further reading.

 

XIV. Security

Mobinner makes use of a variety of security technologies and methodologies to protect your personal data from unauthorized use, access, alteration, destruction, or disclosure. Here's what we do to guarantee security:

 

Personnel: We only provide access to personal data to authorized and qualified personnel. Additionally, they may only access this information for allowed business purposes.

 

Security Measures: Mobinner features encryption in all transmissions of personal data between the end user's system and ours. We also have firewalls in place to keep unauthorized parties from accessing personal data.

 

Payments: All the payment information users provide is sent through a Secure Socket Layer (SSL) and it's encrypted into the database of Mobinner's gateway providers. It will only be accessible by authorized people who need special access rights to these systems. Additionally, they are required to maintain confidentiality. Once the transaction is done, the information won't be stored on Mobinner servers. That includes credit card numbers, social security numbers, etc.

 

Additional Safeguards: Mobinner provides physical, electronic, and procedural safeguards. The security procedures protect every aspect of data collection, storage, and disclosure. For this reason, we may require proof of identity whenever you need to access the personal data stored in Mobinner.

 

Trusted Vendors: We only work with vendors who provide the appropriate level of security as it relates to personal information. Mobinner only uses secure cloud servers, such as AWS Cloud, a cloud platform that's both secure and private. AWS Amazon cloud provides a variety of security technologies and methodologies to keep personal information safe and they comply with third-party assurance structures, including ISO 27017 for security on the cloud, ISO 27018 for privacy on the cloud, PCI DSS Level 1, and SOC 1, SOC 2, and SOC 3. If you need further information, check out AWS Amazon's policies.

 

XV. Children

 

Mobinner protects children's privacy at all costs. The platform we provide is not meant to be used by children and it's not targeted to them according to the Applicable Laws. We don't allow clients or partners to provide us with children's personal information of any kind.

 

XVI. Contact Mobinner

 

If you have any questions at all about the End-Use Privacy Policy as described in this document, you can contact us by using the following information:

Mobinner LLC is a Delaware company EIN #37-1951556, having a principal address at 1330 Avenue of the Americas, Suite 23A, New York City, NY 10019.

General contact form: https://mobinner.com/get-in-touch.html

Privacy contact: legal@Mobinner.com