LAST UPDATED: APRIL 2021
EFFECTIVE: MAY 2021
InMobi runs a marketing platform solution which provides advertising and monetization services/products (whether owned or through its partners) to marketers and supply partners including through digital media, sites, surveys, owned or operated application(s)/widgets, exchange(s) for demand/supply, marketing automation solutions and other services, such as, fraud detection, reporting, audiences, attribution, analytics, modelling, segments, measurement (“Marketing Platform”).
To the extent that foregoing Consumer Offering promotes any interest-based advertising using the Marketing Platform Services, the terms of this policy would apply to the data processing practices for such Marketing Platform Services.
Marketing Platform Services and Consumer Offering are collectively referred to as “Services”.
3. INMOBI MARKETING PLATFORM SERVICES
InMobi engages with third party site/app publishers and app developers to serve ads on their digital properties on behalf of its demand side advertising partners through various channels of advertising solutions including exchanges, network, off-network etc. InMobi may also serve ads on Consumer Offerings. InMobi also engages in campaign planning, measurement (e.g. whether an advertisement was viewed, its timestamp etc.) and attribution of advertisements, whether by itself or through third party measurement partners.
InMobi provides Marketing Platform Services, including optimization of advertising campaigns, data analytics/enrichment, segment creation, user acquisition or re-engagement through various digital advertising channels. InMobi receives data into its Marketing Platform from various sources, including end user information collected by our systems, applications/offerings, partners, data/cookie vendors or customers (“Sources”), which may include third party apps, sites and services that you use. Please refer to the privacy policies of the apps, sites, and services you use to understand how those apps, sites and services collect, use, and share data from your interactions with them. InMobi is not responsible for how those third-party apps, sites and services collect and use data.
4. WHAT PERSONAL INFORMATION DO WE COLLECT?
When you view an advertisement distributed through InMobi on a site, app or other digital media, we may collect information on your device and your interaction with the advertisement. This information enables us to serve advertisements to you, improve our Services including to recognize your device when you use other sites and applications that have partnered with us. InMobi may also collect information about you when you elect to interact with our surveys or opinion-based applications. Information we may collect includes:
- (a) Device identifiers. Device identifiers are alphanumeric strings that are unique to your device. These include:
- iOS devices’ Identifier for Advertising (IDFA) and iOS Identifier for Vendors (IDFV)
- Google Advertising ID (GAID), or Android ID for Android devices
- Identifier for Advertising on OTT and CTV platforms
- International mobile equipment identity (IMEI), in certain jurisdiction as permitted by applicable law
- Cookie IDs
- (b) Location information, including:
- Geo-location or precise location of your device if you have given the app or site permission to collect your location information
- Location information we infer based on data collected through a WiFi identifier that your device is connected to, in accordance with applicable law and provided location access is permitted
- Location information we infer from your device’s IP address, provided that we will not infer location from an IP address to a more precise than city-level of accuracy unless you have given the app or site permission to collect your location information
- (c) Network information, including:
- Mobile carrier
- Network provider or ISP
- Network type (e.g., WiFi or cellular)
- IP address
- IDs of WiFi access points to which your device is connected
- Date and time of connection
- (d) Information about apps or sites and our Software Development Kit (SDK), including:
- App or site name or version
- App identifier
- SDK version
- API key identifier
- Other information about/on your device, including:
- Device type (e.g., make and model)
- Device startup time and update time
- Device name
- Screen size
- Memory and hard drive capacity
- Operating system and version (e.g., iOS 14, Android, Windows, Blackberry)
- Mobile browser used (e.g., Chrome, Safari, Firefox)
- Language settings (including country code) and time zone
- App usage
- Advertisement information. We collect information about the ad presented on your device, including:
- The content type of the ad (the advertiser and category, e.g. games, finance, entertainment, news)
- The ad type (e.g. whether the ad is a text, image, video or other format based)
- Where the ad is being served (e.g. the site, digital media or app on which the ad appears)
- Whether you viewed, clicked or otherwise interacted with the ad
- Survey information. We may ask users to voluntarily participate in online surveys. These surveys help brands improve their products and services offered to you. If you fill out a survey, we may collect your device information described above and information you provide, including your:
- Email address
- Phone number
- Occupation and income range
- Family size and other demographic information
- Preference for brands, modes of travel, and other consumer choices.
- Other marketing information:
In the context of our Marketing Platform Services, our customers, partners or vendors may also disclose to us certain personal or non-personal information they have separately collected about you during your interaction with their apps, sites or services so that we can effectively provide our Services. This may in the context of websites, including mobile websites, include cookies, other technologies, or other aggregated characteristics or other identifiers related to your device to understand your interaction with such site and to serve certain types of ads relevant to your interests.
These parties serve you cookies in accordance with their own specific privacy/cookie policies and subject to their own applicable legal requirements. We do not use the information they provide to us for any purpose other than as permitted by such third parties or for providing or improving our Services.
We do not collect any sensitive data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric data, data concerning health. We may show targeted advertisements to fitness enthusiasts.
5. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the information that we collect about your device to:
- Display advertisements on your device, which may include interest-based advertising customized to your interests, preferences, locations
- For bidding to serve advertisements and to determine which ads are most effective
- Analyze and provide our demand partners or advertisers reports on the effectiveness of advertisements and campaigns, including across different types of devices based on our determination of devices that are related to the same person. We, or third parties whom we engage to provide this service, may use cross-device data to provide interest-based advertising services and to deliver tailored ads to users across multiple mobile devices including over the top applications and smart televisions
- Avoid showing you the same ads too many times
- Build custom audience segments to enable our customers and partners better target their advertisements and offers
- Improve our Services and assist our customers and partners in improving their products and services
- Detect, deter and prevent fraud, fraudulent traffic or to protect the security of our systems
- We may process your survey responses and share the response data with the brands who are our customers/marketers
6. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
InMobi may share the information we collect or receive about you as described in this Policy as follows:
- Publishers and Supply Partners. We may share your information with publishers (the app or site publishers) to help them understand how users interact with their apps and sites and advertisements on their apps and sites
- Demand Partners and Advertisers. We may share your information with demand partners, brands and advertisers who use our Marketing Platform, to allow them to understand the performance of their campaigns; and to help them better target their campaigns, products or offerings
- Marketing Partners. We may share your information with data partners who help us with better understanding your preferences by providing data enrichment, analytics and identification services and measurement companies who help us with attribution and tracking of advertisements distributed through us (“Marketing Partners”)
- Service Providers. We may share personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include: IT and related services; fraud detection, information and services; payment processors; customer service providers; and vendors to support the provision of the Services
- Affiliates. We may share personal information with our affiliates so that the Services of InMobi and/or its affiliates may be improved and otherwise to serve you and/or our customers better with all our offerings including effective content management
- Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity
- Disclosures in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract
- International Data Transfers. Where applicable, we will protect information through other legally valid methods, including international data transfer agreements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
7. HOW DO WE KEEP PERSONAL INFORMATION SECURE?
InMobi uses reasonable technical and organizational measures to protect the information it collects about you in compliance with its legal and privacy requirements and contractual obligations. We also seek appropriate contractual protection from our partners regarding their collection, use or treatment of user data. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
InMobi retains information collected in the context of our Marketing Platform for a period of up to thirteen (13) months, unless otherwise required by law or applicable contract.
InMobi may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations. In case any information is provided by you in participation of a survey or opinion-based application by InMobi, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
After the applicable retention period, InMobi will only retain and may only use your data: (i) in an aggregated or anonymized format; (ii) to comply with its legal obligations; and (iii) to resolve disputes and enforce agreements. Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.
9. OPTING OUT OF INTEREST BASED ADS
Opting out of interest-based advertising: If you prefer not to receive interest-based advertising from InMobi, you can opt out at any time by going to the InMobi Opt Out page and submitting your device ID or any other listed identifier. If you opt-out of interest-based advertising, you will still receive "generic" ads from InMobi. To opt-out of our cross-device ad targeting, you must opt-out on every device browser and device using the appropriate opt-out methods.
Opting out of surveys: Each survey that you participate in will provide opt-out instructions, including an option to skip questions, which if elected will ensure that we do not include your device for that survey. Please note that if you opt-out of a survey you may still receive other survey requests. If we reach out to you through marketing communication modes such as emails, you will have the option to unsubscribe from such marketing communications through links provided in such emails.
Opting out of Connected TV: If you opt-out of interest-based ads on your connected TV device, your advertising ID will not be used to build profiles or target you with interest-based ads and it is likely that you will get irrelevant ads which are not tailored to your interest. To disable interest-based ads, please use the Opt-Out on your Connected TV device as shown below.
You may also opt out of interest-based advertising via NAI. Please visit Mobile Choices | NAI: Network Advertising Initiative for opting out of interest-based ad on mobile devices and Internet Connected TV Choices | NAI: Network Advertising Initiative on TV.
10. PRIVACY RIGHTS
InMobi provides consumers with data subject or consumer rights as and when and to the extent required under such applicable laws.
California: The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with the right to know what categories of personal information InMobi has collected about them and whether InMobi disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “4. WHAT INFORMATION DO WE COLLECT?” and “5. HOW DO WE USE YOUR INFORMATION?” above, respectively. The categories of third parties with whom we may share your information are listed in “6. WHO DO WE SHARE YOUR INFORMATION WITH?” above.
California residents have the right to opt out of the “sale” of their personal information. Under the CCPA, “sale” is defined broadly and includes the transfer of personal information by a business to a third party for valuable consideration (even if there is no exchange of money). InMobi may be deemed to be “selling” personal information. The categories of personal information we have “sold” and the categories of third parties we have “sold” personal information to in the preceding twelve months are listed in “6. WHO DO WE SHARE YOUR INFORMATION WITH?” above.
Residents of the State of California (in the United States) have the following additional privacy rights:
- You have a right to exercise certain consumer rights such as request to know/ disclose/ access/ delete your data, collected in the last 12 months, by writing to us at firstname.lastname@example.org.
- You have the right to opt out of selling of your data by clicking on the following link: Do not sell my data.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “17. CONTACT US” below and provide written authorization signed by you and your designated agent.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include information about your device.
Nevada. If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by writing to us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.
The privacy laws of your country may grant you the following additional privacy rights relating to their personal information: right to access, request correction, request deletion/anonymization/blocking, restrict/object to processing, withdraw your consent, request data portability, be informed about third parties with whom your data has been shared, and request review of decisions taken exclusively based on automated processing. To exercise these rights, please write to us at firstname.lastname@example.org.
11. INTERNATIONAL TRANSFERS
InMobi may share your information with clients, customers, partners, affiliates and other third parties described above who are based in countries outside of your country of residence (for example, if you are an EEA resident, we may share your information with our non-EEA clients or affiliates), subject to any contractual or legal requirements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world.
12. LEAD GENERATION CAMPAIGNS
InMobi may offer form-based advertising solutions to marketers that include the collection of voluntary information from you as part of an advertisement that contains a questionnaire. Such information may consist of personal data, non-personal information or data, or both. All the information that you voluntarily provide in response to such form or questionnaire is typically forwarded directly to the relevant marketer’s servers or their landing page and in such cases will be governed by such marketer's privacy policies in place at the time of transfer.
In the event any personal data is directly processed by InMobi, you acknowledge that InMobi may be required to store such information for the period during which it continues to manage the applicable lead-generation campaign for its marketer on whose behalf the information is collected. This information may be temporarily stored by InMobi solely for running such form-based campaigns and will be used only for the purpose of optimization of such campaigns, subject to applicable legal/privacy and contractual requirements. InMobi has implemented internal safeguards to protect the temporary storage of this information and uses reasonable technical and organizational measures to protect the same. InMobi has mechanisms to delete or anonymize any personal data after the said campaign is concluded or within a period thirty (30) days from the same. Pursuant to the conclusion of the applicable campaign, InMobi may retain and use your Information only to the extent necessary for it to create reports for its client, comply with its legal obligations, resolve disputes and enforce agreements and no other purpose. Any non-personal information or data submitted by you may be used for improving our Services.
If you have any questions about InMobi lead generation campaigns, please contact us at: email@example.com. InMobi will refer any enquiries or complaints to the relevant marketer responsible for the processing of data provided as part of lead generation campaigns.
14. PRIVACY OF CHILDREN
InMobi complies with the age-gating requirements under applicable privacy laws such as Children's Online Privacy Protection Act (COPPA) and California Consumer Privacy Act (CCPA) in the U.S., Lei Geral de Proteção de Dados Pessoais (LGPD), General law of personal data protection in Brazil and GDPR in the EEA and does not knowingly collect personal data about users of sites or apps directed to children. Please also visit our COPPA Policy.