This Privacy Notice applies to the processing of personal information by Moloco, Inc. and its affiliates and subsidiaries (“Moloco,” “we,” “us,” or “our”) through our advertising services including, but not limited to, our Moloco Ads, Moloco Commerce Media, Moloco Streaming Monetization, and the Moloco software development kit (“SDK”) offerings (collectively, the “Advertising Services”).
This Privacy Notice does not apply to the personal information that we process solely as a “processor” or “service provider” on behalf of our customers pursuant to a written agreement we have entered into with them (“Customer Data”). Any questions or requests relating to Customer Data should be directed to our customers.
Disclosure Regarding the California Consumer Privacy Act (Notice at Collection). For information on our processing of personal information that is subject to the California Consumer Privacy Act (“CCPA”), please see Annex A – Supplemental CCPA Privacy Notice.
- UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time at our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and we may also send other communications.
- ABOUT THE ADVERTISING SERVICES
The Advertising Services aim to assist digital publishers and buyers of digital advertising inventory (for example, advertisements displayed on digital services) to achieve their mobile marketing goals through methods like monetization, user acquisition, and targeting.
- PERSONAL INFORMATION WE COLLECT
Below are the types of personal information collected by the Advertising Services:
- Device and Browser Information
If you interact with the Advertising Services (for example, by visiting a digital service that displays ads from Moloco, or by using a digital service which contains the Moloco SDK or pixel or through an API or other similar technologies), we may collect personal information including:
- Identifiers such as iOS IDFA, Android Advertising ID, and Amazon Advertising ID;
- Device properties such as settings, model, operating system, and size;
- Usage information such as installations and sessions from the apps and sites you use;
- Information about the digital service you use to interact with the Advertising Services;
- Location information such as city and/or country level information, imprecise location information inferred from IP address, and time zone;
- Network information such as IP address and connection details;
- Advertising and tracking preferences; and
- Details collected in connection with Moloco’s display of advertisements.
- Personal Information Provided by Others
We may collect personal information from others such as Moloco customers and other third parties, including:
- User and other IDs;
- Email addresses and phone numbers;
- Demographic information such as age range and gender;
- User activity scores and interaction, engagement, and predictive metrics;
- Events and activities, such as browsing behavior (for example, views and searches), records of products purchased or considered (for example, added to cart and checkout), contextual data, or other custom events; and
- Subscription, registration, or installation status.
- HOW WE USE PERSONAL INFORMATION
- Provide Advertising Services
We use personal information to:
- Tailor and serve ads on behalf of customers;
- Combine information we collect with information we derive, through analytical techniques, to provide the Advertising Services; and
- Measure advertising performance and optimize advertising campaigns.
EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful bases may include legitimate interest, consent, and/or compliance with legal obligations.
- Improve our Advertising Services and Develop New Products and Services
We use personal information to improve the Advertising Services and to develop new products and services, such as:
- Developing, training, and fine-tuning models, algorithms, and artificial intelligence technologies;
- Improving, upgrading, or enhancing the Advertising Services; and
- Creating and supplementing advertising profiles.
EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful bases may include legitimate interest, consent, and/or compliance with legal obligations.
- Operate Our Business
We use personal information to operate our business, such as:
- Pursuing our legitimate interests such as direct marketing to potential and existing customers, fraud prevention, frequency capping, research and development (including marketing research), and network and information security;
- Carrying out analytics;
- Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information unless doing so is permitted or required by applicable laws;
- Enforcing, or exercising our rights under, our agreements, policies, and applicable laws; and
- Carrying out activities that are required or appropriate to comply with our legal obligations.
EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful bases may include legitimate interest, consent, and/or compliance with legal obligations.
- With Your Consent or Direction
We may use personal information: (i) for other purposes that are clearly disclosed to you at the time you provide the personal information, (ii) with your consent, or (iii) as otherwise directed by you.
EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful bases may include legitimate interest, consent, and/or compliance with legal obligations.
- HOW WE DISCLOSE PERSONAL INFORMATION
We disclose personal information to third parties for a variety of business purposes, including to provide the Advertising Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
- Disclosures to Provide the Advertising Services
We may disclose any of the personal information we collect to the categories of third parties described below.
- Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Advertising Services. This includes service providers that provide us with hosting, analytics, marketing services, AI or machine learning services, consent management platforms, IT support, and related services.
- Third-Party Services. We may disclose personal information to third-party applications, platforms, services, products, or technologies (each a “Third-Party Service”). For example, Third-Party Services include, but are not limited to, supply-side platforms, demand-side platforms, and ad mediation platforms. Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
- Affiliates. We may disclose your personal information to our corporate affiliates.
- Disclosures to Protect Us or Others
We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with 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 unauthorized or illegal activity.
- Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.
- YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. You may be able to limit Moloco’s processing of your personal information via the Advertising Services by adjusting your preferences as your device or application/browser permits or by contacting us as set forth in “Contact Us” section below.
You may limit ad tracking on some mobile applications by following the instructions for Android, iOS and others.
For details about how to manage your preferences on some Internet connected TVs, read the instructions found here.
For the most effective and up-to-date “limit ad tracking” methods, you should consult instructions provided by your device manufacturer or application/browser provider.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from organizations that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out on each device and in each application/browser.
Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
- Request Access to or Portability of Your Personal Information;
- Request Correction of Your Personal Information;
- Request Deletion of Your Personal Information;
- Request Restriction of or Object to our Processing of Your Personal Information;
- Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws); and
- Withdraw Your Consent to our Processing of Your Personal Information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.
Please note that due to technical limitations inherent in the ad tech ecosystem, we are unable to authenticate the identity of many individuals whose device level data we process. As a result, we are unable to fulfill some requests that we receive from individuals (for example, access requests). In such circumstances, our customers (which may be the platform where you saw the advertisement, the company that is the subject of the advertisement, etc.) may be able to authenticate your identity and pass your authenticated request to us.
If you would like to exercise any of your other rights listed above, please click here and follow the instructions provided.
Alternatively, you can email us at [email protected] and provide us with the identifier you believe we may process about you (for example, IDFA, IP address, or another identifier). You may also contact us as set forth in “Contact Us” below.
We will process such requests in accordance with applicable laws.
Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.
To protect your privacy, we will take steps to verify your identity before fulfilling certain requests submitted under applicable privacy laws. These steps may involve asking 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. Examples of our verification process may include asking you to provide the device ID or IP address that your request relates to.
Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.
If your personal information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.
- INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
All personal information processed by us may be transferred, processed, and stored anywhere in the world, including the United States or other countries, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country.
If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
- RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Notice for as long as necessary to fulfill the purpose(s) for which it was collected by Moloco, or as long as necessary to pursue Moloco’s business purposes.
To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
- SUPPLEMENTAL NOTICE FOR EU/UK GDPR
This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.
In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.
IAB Europe Transparency & Consent Framework. Moloco participates in the IAB Europe Transparency & Consent Framework. Moloco’s identification number within the framework is 807.
- CHILDREN’S PERSONAL INFORMATION
We do not knowingly collect personal information from children under 18.
If you are a parent or guardian and believe your child has uploaded personal information to the Advertising Services in violation of applicable law, you may contact us as described in “Contact Us” below.
- THIRD-PARTY SERVICES
The Advertising Services may contain links or other references to other third-party services including, without limitation, websites/applications and other third-party services may reference or link to the Advertising Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each service with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such third-party services. Providing personal information to third-party services is at your own risk.
- CONTACT US
Depending on where you are located, one or more of the following Moloco entities may be the controller of the personal information processed under this Privacy Notice:
- Moloco, Inc.
- Moloco (Beijing) Information Technology Co., Ltd
- Moloco Singapore Pte. Ltd.
- Moloco Co., Ltd.
- Moloco Technology Services Ltd.
- Moloco GK
- Moloco UK Limited
- Moloco Germany GmbH
- Moloco Technology India Private Limited
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:
Attn: Privacy Group
Moloco, Inc.
135 Commonwealth Dr., Menlo Park, CA 94025.
[email protected]
Toll-Free Phone Number: +1-888-251-8829
EU Representative: Attn: Privacy Group, Moloco Germany GmbH, with registered address Am Zirkus 2, 10117 Berlin
UK Representative: Attn: Privacy Group, Moloco UK Limited, with registered address No.1 London Bridge, London, SE1 9BG
ANNEX A – SUPPLEMENTAL CCPA PRIVACY NOTICE
This Supplemental CCPA Privacy Notice supplements our Privacy Notice and only applies to our processing of personal information that is subject to the CCPA.
NOTICE AT COLLECTION
At or before the time of collection, California residents have a right to receive notice of our privacy practices. California residents can find this information below.
- Personal Information Collected. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, and/or Shared” for a list of personal information which may be collected. If we have previously collected personal information in the past 12 months, we may collect that personal information from you.
- Uses of Personal Information. See the section of this Supplemental CCPA Privacy Notice titled “Uses of Personal Information” for a list of the purposes for which we use personal information.
- Is Personal Information “Shared” for “Cross-Context Behavioral Advertising”? Yes. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, and/or Shared” for more details. If we have previously “shared” personal information for “cross-context behavioral advertising” in the past 12 months, we may “share” that personal information if collected from you. See the section of this Supplemental CCPA Privacy Notice titled “Right to Opt Out of ‘Sharing’ for ‘Cross-Context Behavioral Advertising’” for instructions on how to opt-out of these activities.
- How Long is Personal Information Retained For? To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
- Additional Information. For more information on our privacy practices, please review this Supplemental CCPA Privacy Notice and our Privacy Notice. Importantly, the section of our Privacy Notice titled “Your Privacy Rights” includes important details about how you can exercise some of the rights which you have under the CCPA.
CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED
We collect personal information that our customers provide to us, personal information we collect automatically when operating the Advertising Services, and personal information from third-party sources.
OVERVIEW OF PERSONAL INFORMATION COLLECTED, DISCLOSED, AND/OR SHARED
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, whether Moloco disclosed that personal information to a service provider or a contractor for a business purpose in the preceding 12 months, and whether Moloco “shared” that personal information for “cross-context behavioral advertising” in the preceding 12 months. California residents can find this information below:
USES OF PERSONAL INFORMATION
We may use and disclose the personal information that we collect for the following business and commercial purposes:
- Providing the Advertising Services as further described in our Privacy Notice;
- Processing to improve the Advertising Services and develop new products and services, as further described in our Privacy Notice;
- Processing to operate our business, as further described in our Privacy Notice;
- Processing with your consent or direction as further described in our Privacy Notice;
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- Helping to ensure security and integrity to the extent the use of personal information is reasonably necessary and proportionate for these purposes;
- Debugging to identify and repair errors that impair existing intended functionality;
- Short-term, transient use, including non-personalized advertising shown as part of your current interaction with Moloco;
- Processing or fulfilling transactions, verifying customer information, providing analytic services, providing storage, or providing similar services;
- Providing advertising and marketing services;
- Undertaking internal research for technological development and demonstration;
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Moloco, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Moloco.
RIGHT TO OPT OUT OF “SHARING” FOR “CROSS-CONTEXT BEHAVIORAL ADVERTISING”
We “share” your personal information for “cross-contextual behavioral advertising” to provide the Advertising Services.
California residents have the right to opt out of the “sharing” of personal information for “cross-context behavioral advertising.”
California residents may exercise these rights by Moloco by clicking here and following the instructions provided.
Alternatively, California residents may exercise these rights by emailing us at [email protected] and providing us with the identifier they believe we may process about them (for example, IDFA, IP address, or another identifier).
DISCLOSURE REGARDING INDIVIDUALS UNDER THE AGE OF 16
Moloco does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Moloco does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”
NO RETALIATION FOR THE EXERCISE OF RIGHTS UNDER THE CCPA
California residents have the right not to be retaliated against by us for the exercise of their rights conferred by the CCPA.
