Skydeo values the privacy of its customers and consumers. Skydeo’s customers include clients of Skydeo’s Services (defined below), third parties (e.g., publishers) that provide data to Skydeo, as well as brands, advertising agencies, application developers, media and technology platforms, and others who visit any Skydeo website that links to this policy (“Site”) or otherwise use Skydeo’s Services (collectively “Customers”). “Consumers” include individuals who use Skydeo’s applications or who use applications from which Skydeo receives or collects data (such as applications that are owned and/or operated by Skydeo’s Customers).
- The Consumer Information Skydeo Collects for the Services
- How Skydeo Uses Device Data to Provide the Services
- How Skydeo Discloses Information through the Services
- Consumer Choices and How to Opt Out of Interest-Based Advertising
- Collection and Disclosure of Information from this Site and Skydeo Accounts
- Data Security
- Children’s Privacy
- International Visitors
- Links to other (third party) Websites and Apps
- Additional Information
- California Do Not Track
- Skydeo Contact Information
- THE CONSUMER INFORMATION SKYDEO COLLECTS FOR THE SERVICES
When Consumers use Skydeo applications or engage with our Customers (e.g., by using their mobile applications or viewing an ad provided by our Customers, or by using an app that has integrated our software development kit (“SDK”)), we may collect or receive Device Data that may (but does not necessarily) include the following:
- Precise geolocation data pertaining to Consumers’ devices, which may be expressed by latitude-longitude coordinates obtained through GPS tools, WiFi data, cell tower triangulation or other techniques (collectively, “Device Geolocation Data”) and linked to a device identifier, such as the IDFA for iOS devices or Android ID for Android devices;
- Predicted or actual data about a Consumer such as age, gender, date of birth, street address; predicted or actual characteristics or interests; and any information that Consumers provide to Skydeo or to Skydeo’s Customers;
- Other information about a Consumer’s device, such as: device type (e.g., tablet, smartphone), operating system, IP address, network provider, mobile carrier, mobile browser type (e.g., Firefox, Chrome, Safari), other apps and SDKs installed on the device, timestamp, time zone, information about the speed, bearing, orientation, and altitude of a device, or other device-identifying information;
- Information about the possible relationships among different devices; and/or
- Data about Consumer activities that helps Skydeo determine how a Consumer interacts with advertising or content, such as determining whether a Consumer who viewed a particular advertisement ultimately purchased the advertised product or service.
The Device Data that Skydeo receives from its Customers or from Consumers may be combined with additional information Skydeo collects or receives from third-party sources. For example, Skydeo may have information about consumer products, events held at specific locations, street addresses, and categories of geographic locations. While such information is associated with a specific device, it is treated as Device Data.
Please see Section 5 below for a description of the information that Skydeo collects through its Site and in connection with Skydeo accounts.
- HOW SKYDEO USES DEVICE DATA TO PROVIDE THE SERVICES
Skydeo generally uses the Device Data it collects or receives for the following purposes:
- to operate, maintain, enhance, and provide the Services described below; and
- to improve and market the Services, and to create new features and functionality.
Skydeo’s Services help application developers, publishers, advertisers, marketers, and other companies and organizations learn more about Consumers based on Device Data including Device Geolocation and Application Data. For example, the Services help Customers:
- provide more relevant content or advertising to Consumers over time and across multiple devices;
- identify other Consumers that may be interested in their offerings;
- measure the performance of Customers’ content, services, and advertising (for instance, what effect certain ads, as opposed to other ads, have), or trends or preferences among Consumers (for instance, what types of Consumers generally tend to shop at certain stores); or
- learn about how Customers’ apps can perform better.
Skydeo may also work with third parties, such as brands, advertising agencies, media platforms and publishers (such as app developers), and other advertising platforms to improve their own services. The above list is not exhaustive, but it is intended to provide illustrative examples of how Skydeo uses the Device Data it collects and receives. Skydeo may retain the Device Data:
- for interest-based advertising, ad delivery, and reporting purposes for approximately 24 months;
- for other business purposes (such as technical developments) for such period as Skydeo considers reasonably necessary. After this Skydeo will delete or de-identify the Device Data.
Skydeo may retain Device Data beyond these time periods as required by law.
- HOW SKYDEO DISCLOSES INFORMATION THROUGH THE SERVICES
- Skydeo may disclose Device Data if it believes that such action is necessary to comply with applicable laws or regulatory investigations, or to respond to a court order, judicial or other government subpoena, warrant, or law enforcement request.
- Skydeo may also disclose Device Data if it believes it will help to protect Skydeo, its Customers, or any other person or third party, or to enforce any legal rights.
- In the event that Skydeo is acquired by or merged with a third-party entity or is potentially going to be acquired by or merged with a third-party entity, in any partial or total sale of assets including in the event of bankruptcy, or in any other corporate change, Skydeo may transfer or assign the Device Data as part of that actual or potential merger, acquisition, sale, or other change of control.
- Skydeo may share Device Data with its affiliates and joint venture partners.
- Skydeo may share Device Data with service providers that help it operate the Services.
Please see Section 5 below for a description of how Skydeo may disclose information collected from this Site and/or Skydeo accounts.
- CONSUMER CHOICES AND HOW TO OPT OUT OF INTEREST-BASED ADVERTISING
- Opting Out of Interest-Based Advertising Services by Skydeo
Skydeo, and some of Skydeo’s Customers, provide the ability for Consumers to opt out of the collection and use of mobile app data across apps over time on a device, for interest-based advertising purposes, through the DAA’s AppChoices tool. To opt out of Skydeo’s collection, use, and transfer of such app usage data and of Device Geolocation Data, for interest-based advertising purposes, Consumers can download AppChoices onto the relevant mobile device and exercise choice through the app. When such choice is exercised on a device, Skydeo will also stop using and transferring Device Data from that device for interest-based advertising on other linked devices, and will stop using Device Data from other linked devices for interest-based advertising on the device from which choice was exercised. AppChoices is available at the links below:
Please note that Consumers who use more than one mobile device should renew their opt-out choices on each device. Consumers who opt out from use of their Device Data as part of Skydeo’s Services may continue to receive interest-based advertising from other companies.
This will opt you out of many –but not all- of the interest-based advertising activities in which Skydeo or its third party partners engage. Opting out via AppChoices will opt the User out of all Skydeo Targeting Segments that are created immediately and any subsequent Segment distributions. However, there will be a lag for the User’s ID to be removed from previously distributed Targeting Segments that are already active at the time when the opt-out is exercised.
If a User wants to end all targeting immediately, s/he can turn on “Limit Ad Tracking” in his/her device settings. To limit Ad Track on an Apple device, see instructions at: https://support.apple.com/en-us/HT202074.
To limit Ad Tracking on an Android device, see instructions at: https://support.google.com/ads/answer/2662922.
Please note, however, that opting-out will not block general advertisements that are sent at random, and not tied to the perceived interest of the User of a particular device.
Consumers who have downloaded Skydeo’s applications, but who no longer wish to provide information to Skydeo for interest-based advertising purposes, should opt out through AppChoices as described above.
Opting Out of Interest-Based Advertising by Third Parties on the Skydeo Site
Skydeo may permit third parties to collect information on its Site and combine that information with other information collected on non-affiliated websites or applications over time. These third parties may use technologies, including cookies and web beacons, to collect information about Consumers’ or Customers’ use of the Site in order to analyze, report on, or customize content or advertising on the Skydeo Site or on other sites, or to help us operate and improve the Site. To find out more about interest-based advertising in the web environment, and how to opt-out of information collection for this purpose by companies that participate the Digital Advertising Alliance, DAA’s Consumer Choice Page. EEA and Swiss residents, please refer to www.youronlinechoices.com.
Opting Out of Interest-Based Advertising on Websites by Skydeo Customers
Skydeo sometimes works with web-based Customers, such as to coordinate and integrate information across platforms. To find out more about interest-based advertising in the web environment, and how to opt-out of Web viewing information collection for this purpose by companies that participate in the Digital Advertising Alliance, visit DAA’s Consumer Choice Page. EEA and Swiss residents please refer to www.youronlinechoices.com.
- COLLECTION AND DISCLOSURE OF INFORMATION FROM THIS SITE AND SKYDEO ACCOUNTS
- Information Collected on the Site
For Users who provide Skydeo with an email address, Skydeo may use such email addresses for administrative communications such as marketing, notifying Users of major Site and Services updates, for customer service purposes, to address copyright infringement or defamation issues, or to contact Users regarding any content that they have posted to or downloaded from the Site or Services. If you do not want to receive promotional emails, please follow the unsubscribe instructions within the email.
To review or update your contact or billing information maintained by Skydeo, you can contact us at https://skydeo.com/contact
Skydeo’s server logs also automatically collect User information such as Users’ IP addresses, pages Users access, browser type and language, and the date and time of visits, which helps Skydeo track use of the Site and understand trends.
- Cookies and Similar Technologies
Skydeo may place one or more cookies on a User’s computer if the User visits the Skydeo Site. Skydeo’s cookies may collect information to facilitate access to Skydeo’s website and to personalize the User’s online experience.
Analytics: Skydeo also works with third-party service providers, such as Google Analytics, which collect information about Users’ use of the Site and Skydeo Services (and other unrelated sites over time). Data collected via Google Analytics can be connected to other data that Skydeo has about its Users. These third-party service providers may use tools such as cookies, web beacons, and similar technologies to provide their services. These technologies may be used to assist Skydeo in offering the Site, such as managing the content on the Site and understanding how Users interact with the Site. Skydeo does not control the third-party technologies employed on its Site for this purpose. To learn more about how Google Analytics collects and processes data and the choices Users may have to control these activities, please visit http://www.google.com/intl/en/policies/privacy/partners.
- How Skydeo Discloses Information from the Site
Skydeo may disclose personal information collected on this Site or through other account tools (including contact or billing information):
- with consent;
- to affiliated companies or joint venture partners;
- to other businesses or persons that help Skydeo operate or improve Skydeo’s business;
- if Skydeo believes that such action is necessary to comply with applicable laws or regulatory investigations, or to respond to a court order, judicial or other government subpoena, warrant, or law enforcement request;
- if Skydeo believes that disclosure will help protect Skydeo, its Users, or any other person or third party, or to help enforce any legal rights;
- in the event that Skydeo is acquired by or merged with a third-party entity or is potentially going to be acquired by or merged with a third-party entity, in any partial or total sale of assets including in the event of bankruptcy, or in any other corporate change, Skydeo may transfer or assign the information as part of that actual or potential merger, acquisition, sale, or other change of control.
- Disabling Cookies
- DATA SECURITY
Skydeo uses reasonable physical, managerial, and technical safeguards to preserve the integrity and security of Users’ personal information.
We take commercially reasonable efforts to maintain security protections in accordance with industry practices to protect data we collect from loss, alteration, destruction, misuse and unauthorized access or disclosure.
To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the personal information we collect, we have implemented physical, electronic, and administrative procedures. We utilize hashing, encryption and de-identification techniques to help ensure your privacy is safeguarded.
We have policies to help maintain control and physical security of the facilities used to store data and only allow access to authorized personnel, restrict access to data to those employees, contractors and agents that have a need to know the information in order to provide and support our services. All our employees are bound by confidentiality obligations and may be subject to disciplinary or legal action if they fail to meet these responsibilities.
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
- CHILDREN’S PRIVACY
Skydeo does not knowingly collect personal information from children under 13 years old or from websites or online services directed to children under 13 years old. Users should not create Skydeo accounts unless they are legally old enough to form a binding contract and in any case are 13 years of age or older. In the unlikely event that you are the parent or legal guardian of a child under 13 who has registered with the Site or Services, please contact us at https://skydeo.com/contact to have your child’s personal information deleted.
- INTERNATIONAL VISITORS
For Users visiting the Site or Consumers whose data is collected through the Services from non-U.S. territories, please note that any data entered into the Site or that is collected through the Services will be transferred outside such non-U.S. territory for use by Skydeo and its affiliates for any of the purposes described herein. In addition, because Skydeo operates globally, it may make information it gathers available to worldwide business units and affiliates. By providing and/or using any data on the Site or through Skydeo’s Services, individuals hereby expressly consent to such transfers of data to the United States or other countries.
Skydeo’s Mobile SDK ensures that user’s privacy is being respected and compliance is met with the regulations in place. Skydeo only receives data after user consent is granted.
More Information for Individuals from the European Economic Area (“EEA”) and Switzerland
EU-U.S. Privacy Shield
Skydeo complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from EEA member countries, as that term is defined in the Privacy Shield Framework. Skydeo has certified that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
Residents of the EEA and Switzerland have the right to access the personal data that Skydeo maintains about you, as that term is defined in the Privacy Shield Framework, and you may be able to correct or amend that information if it is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, please email privacy@Skydeo.com. For information on opting out of interest-based advertising enabled by Skydeo, please see Section 4(a) above.
Skydeo is accountable for information that it receives under the Privacy Shield and subsequently transfers to a third party. In particular, Skydeo is responsible under the Privacy Shield Principles if third-party controllers to whom it transfers information or third-party agents it engages to process this information on its behalf do so in a manner inconsistent with the Principles.
In compliance with the Privacy Shield Principles, Skydeo commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Skydeo at:
695 Atlantic Ave Boston MA 02111
Skydeo has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States at 620 8th Ave, 34th Floor, New York, NY 10018. (212) 751-2700. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit www.jamsadr.com for more information or to file a complaint. The services of JAMS are provided at no cost to you. A binding arbitration option may also be made available to you in order to address complaints not resolved by any other means.
Skydeo is subject to the investigatory and enforcement powers of the United States Federal Trade Commission
What is the legal basis on which Skydeo relies to process personal data?
On some occasions, Skydeo may process personal data with the individual’s consent (for example, when a User agrees that Skydeo may place cookies, or process information that the User inputs into the Skydeo website).
On other occasions, Skydeo may process personal data when Skydeo needs to do this to fulfil a contract (for example, for billing purposes) or where Skydeo is required to do this by law.
Skydeo also processes a User’s/Consumer data when it is in Skydeo’s or its Customer’s legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include providing services to enable Skydeo’s Customers to provide more relevant ads and content.
Who is responsible for the data?
For the majority of the services it offers, Skydeo, Inc. is a data processor who processes data on behalf of its Customers.
For certain other services for which Skydeo is a data controller and for processing of personal data derived from the Site, Skydeo, Inc. is the data controller of the data.
If you have any questions or comments please contact Skydeo at the contact details set out at Section 11 below.
You may ask Skydeo for a copy of your information, to correct it, erase it, and to transfer it to other organizations at your request. You also have rights to object to some processing and, where Skydeo has asked for your consent to process your data, to withdraw this consent. Skydeo will only send marketing to you, if you have indicated that you are happy to receive marketing information from us. In addition, you have rights to object to direct marketing at any time. Where Skydeo processes your data because Skydeo has a legitimate interest in doing so (as explained above), you also have a right to object to this. These rights may be limited in some situations – for example, where Skydeo can demonstrate that it has a legal requirement to process your data.
Skydeo hopes to satisfy queries you may have about the way Skydeo processes your data. For details on how to opt-out of Skydeo’s interest-based advertising services, please see Section 4(a) above.
However, if you have unresolved concerns you may also have the right to make a complaint to the relevant data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached.
- LINKS TO OTHER (3rd Party) WEBSITES AND APPLICATIONS
11. ADDITIONAL INFORMATION
Skydeo’s Site may include links to other websites, apps, and services whose privacy practices may differ from Skydeo’s practices. Information collected from by those companies is governed by their privacy policies or statements.
Skydeo’s Site may offer a publicly accessible blog and/or a support forum. Any information provided in any such areas may be read, collected, and used by others including the general public.
- CALIFORNIA DO NOT TRACK POLICY
California law requires that operators of websites and online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a User visits, indicating that the User does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signal. Users may also turn on “Limit Ad Tracking” which will zero their advertising IDs as a means of opting out of tracking.
- SKYDEO CONTACT INFORMATION
Updated: May 14, 2018