This Privacy Notice applies to personal information processed by Moloco Inc. (“Moloco,” “we,” “us,” and “our”) through our demand-side platform services that we offer to advertiser clients (“Advertising Services”).
Moloco provides a demand-side platform that allows buyers of digital advertising inventory (i.e., advertisements displayed in mobile applications) to achieve their mobile marketing goals through user acquisition and retargeting.
When a mobile application wants to provide in-app advertisements, it can work with ad exchanges and/or supply side platforms to reach potential advertisers. To do this, the mobile application will share certain device level data with the ad exchanges and/or supply side platforms when someone is using its mobile application and it wants to show them an advertisement. The ad exchanges and/or supply side platforms then make this device level information available to demand-side platforms in the form of “bid requests” (i.e., a request to bid on displaying an advertisement to the mobile app user).
Once a demand-side platform (e.g., Moloco) receives a bid request, it will help its advertiser clients decide how much to bid on displaying an advertisement based on a variety of factors.
Moloco determines this using various machine learning techniques. For example, we may use the event data provided to us by our advertiser clients (described below) to build lookalike targeting models that help our advertiser clients show advertisements to other mobile app users who are similar to their existing user base.
Using these insights allows us to help advertiser clients decide which mobile app users to target and how much to spend on advertisements. Whenever our advertiser client has the highest bid to display an advertisement, it will win the bid request and the mobile app user will see its advertisement.
A Quick Note:
Before we describe the types of information collected by the Advertising Services, it is important to understand that all information processed by the Advertising Services is solely at the device level and cannot, by itself, be used to identify a natural person in the real world. However, certain privacy and data protection laws still consider this device level data to be “personal information” which is why we use this terminology in our Privacy Notice.
Below are the types of information collected by the Advertising Services:
Moloco’s advertiser clients often provide us with device level data that they have collected about users of their mobile applications. This information provides insight into the activities that the users have engaged in on the advertiser client’s mobile application. Moloco uses this information to create models that help the advertiser client determine what sort of users it should target with advertisements online and how much it should spend on advertisements. Moloco is a “processor” or “service provider” of event data and may only use this data in accordance with our advertiser client’s written instructions.
Bid request data.
When Moloco receives a bid-request from an ad exchange or a supply side platform, we collect device level data contained in the bid-request which may include:
When an advertiser client wins a bid and has its advertisement displayed to the mobile app user, Moloco collects information related to this transaction including the Advertising ID (IDFA/GAID) which was shown the ad.
We use personal information for a variety of business purposes, including:
We may share personal information with the following categories of third parties:
We may share any personal information we collect about you with our third-party service providers that help us provide the Advertising Services.
We may share personal information with Moloco’s affiliated entities.
Disclosures to protect us or others
We may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.
Disclosure in the event of merger, sale, or other asset transfer.
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.
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, Belgium, Taiwan, the United States, or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
Personalized Advertisements. You may limit ad tracking in mobile application environments by following the instructions for Android, iOS and others. For the most effective and up-to-date limit ad tracking methods, you should consult instructions provided by your device manufacturer.
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
Please note that because we are unable to authenticate any individuals whose device level data we receive from ad exchanges and/or supply side platforms, we are unable to fulfill such requests. In addition, we are not able to fulfill requests we receive where we act as a “processor” or “service provider” of personal information as our advertiser clients are the “controller” or “business” of this information and responsible for managing these requests.
We store the personal information we receive as described in this Privacy Notice for as long as necessary to fulfill the purpose(s) for which it was collected, provide our Advertising Services, resolve disputes, establish legal defenses, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Moloco, in its capacity as a business, has collected about them and whether Moloco disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
Category of Personal Information Collected by Moloco
Categories of Third Parties Personal Information is Disclosed to for a Business Purpose
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.
“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Moloco does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
The Advertising Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
CHANGES TO OUR PRIVACY NOTICE
We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you by posting an updating notice online.
If you have any questions about our privacy practices or this Privacy Notice, please contact us at:
Attn: Privacy Group
601 Marshall St., 5th Floor
Redwood City, CA 94063