SilverMob Privacy Policy


This Privacy Policy is an integral part of the Contractual General Terms accepted by SilverMob’s Clients. Capitalized terms used in this Privacy Policy, shall have the meaning given to them in the Contractual General Terms unless otherwise defined.

This Privacy Policy  explains how SilverMob collects, process, use and share your information, in order to provide its Services, as defined in our General Conditions, including information we collect when you visit and/or log-in in our website, located at silvermob.com (Web).

 

Situations


SilverMob collects information when:

1. Surfing our Web: we will collect information like your IP Address, your browser and analytic info through our cookies.. SilverMob informs you that our website uses cookies.

2. Joining our Platform by accepting our Contractual General Terms and this Privacy Policy.

Information shared by you in the register process would be used to the following purposes:

  • manage the relationships between SilverMob and you;
  • to access and use our Services;
  • manage administrative, billing aspects
  • fraud control,
  • share updates and news related to SilverMob’s activities and Services.

When SilverMob sending you newsletters you will have the option to unsubscribe at any time.

You may exercise the rights of access, rectification, cancellation and opposition to the processing of your personal data by sending a written communication to contact@silvermob.com, attaching a copy of his ID or document proving his / her identity.

Third party service providers could access to these data on behalf of SilverMob for the provision of the contracted services. SilverMob has signed the corresponding service provision agreement with these providers stating that they can only handle the data according to SilverMob’s instructions and applying the legally established security measures

In order to accomplish the treatment purposes described above, personal data may be transferred to SilverMob business partners within or outside the EU. If any of the recipients is located in a country without the adequate legal protection for personal data, SilverMob will make reasonable efforts so the recipient adopts the principles described in this Privacy Policy.

 

3. Provided by End Users giving the prescriptive consent.

SilverMob’ s Services consist in connecting Publishers inventory with Advertisers or agents buying this inventory on their behalf with the final aim of placing digital advertisements (“SilverMob Services”).

 

For the purpose of performing SilverMob Services, SilverMob needs to collect minimum data from End Users. In the normal course of business, SilverMob shall not receive any directly identifiable Personal Data. “Personal Data” means any information that can help to identify a natural person, or relating to an identified or identifiable natural person.

 

In order to perform its Services, SilverMob will use its tracking and tagging technology on the Inventory. This technology allows SilverMob to collect End User basic information, like:

What information SilverMob will collect

  • Device and app information– this category includes your device's type and model, system language, the device's operating system (such as Android or iOS), SDK version, mobile carrier name, mobile browsers installed on the device (such as Chrome or Safari, your device's IP address, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or other types of unique device identifiers (a number uniquely allocated to your device by your device manufacturer).
  • Ad information– this category includes information about the online ads and personalized content we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, whether you viewed, clicked on or otherwise interacted with the ad, ad engagement history and whether you visited the Advertiser’s website, downloaded an app or purchased the product or service advertised.
  • Location information– SilverMob collects information about your general location (such as country). For example, we may use the IP address to identify your general location. This information does not tell us where your device is precisely located. This information is sent as a normal part of internet traffic. In addition, we also collect implicit location information, which allows us to infer that you are either interested in a place or that you might be at the place – this information does not actually tell us where your device is precisely located.

In addition, SilverMob may collect the precise location of your device (using GPS signals, device sensors, Wi-Fi access points, Bluetooth signals, Beacons signals and cell tower ids that can be used to derive or estimate precise location, or other geo-location data), when location services have been enabled by the end user for the mobile app or website that uses our SDK (you typically have to choose to turn on device-based location services).

  • Log information– this category includes the app or website visited, time zone, and network connection type (e.g., WiFi, cellular).
  • Information from advertising partners ("Advertisers") and other third parties– this category includes information we receive from our Publishers, Advertisers and other Partners that we work with to help us deliver ads and personalized content to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some Advertisers or other third party ad platforms choose to share with us. This information is also used to enhance data points about a particular unique browser or device.
  • Demographic Information – this category includes information like gender, age, marital status, year of birth.

 

Referred Collectively “Ad Data”

 

SilverMob Role when processing Ad Data

Depending on the way SilverMob will collect Ad Data SilverMob will operate as a Independent Data Controller or just a pure Processor following Publisher’s instructions and directions, not having in any case direct relationship with the End Users whose information SilverMob will process. “Data Controller" means an entity that determines the purposes and means of the processing of Personal Data.  Processor" means an entity that processes Personal Data on behalf of a Data Controller.

In any case, SilverMob will process Personal Data only on the legal grounds allowed under EU Data Protection Laws including General Data Protection Regulation (Contractual Necessity, Legitimate Interest and Consent).

 

Permitted uses of Ad Data

  • Serving ads and promoting apps– allowing Publishers to promote advertising, apps and content in their mobile apps or web display, and to allow Advertisers to bid on Publishers’ inventory.
  • Serve interest-based advertising and personalized content– enable our partners to infer interests and serve ads and personalized content to users based on their behavior, app activity and inferred interests. We will not serve interest-based ads or personalized content based on information that we consider sensitive, such as race, religion or health. An End User is not under any obligation to provide us with any Personal Data. In cases, where an End User is from EEA, we serve them interest-based advertisements, only when they have given us their express consent to use their Personal Data to enable us to serve interest based ads directed to them. Even if you opt-out of interest-based advertising or have not given your express consent to interest-based advertising, you will still receive ‘generic’ ads from SilverMob which are context based or better known as ‘contextual advertising’. EEA means, the European Economic Area, United Kingdom and Switzerland
  • Ad reporting and conversions– measure ad performance, report to Advertisers or Demand Partners when and how users have viewed or clicked on their ads, or visited their website, and to report to Publishers when and how ads were shown on their properties and were clicked on.
  • Analytics and frequency capping– allow our Publishers to analyze their applications (for this purpose, we use aggregated and anonymous benchmark data) and prevent users from seeing the same ad too many times. We also use usage information to analyze our web traffic, to figure out how often customers use parts of the site, to improve the site and generally to make it appealing to as many users as possible.
  • Fraud detection and prevention– identify invalid or incentivized clicks (or ad queries) and protect SilverMob and our partners from fraudulent behavior.
  • Enforce our policies, resolve disputes and communicate with you.
  • Providing and improving our services– audit, research and analyze information in order to maintain, protect, and improve our services and develop new services, and to ensure that our technologies function properly.

 

Collectively, “Permitted Purposes

 

Information Sharing

We share information about you with:

 

  • A Publisher whose app you have accessed to– we share information about how you have interacted with that Publisher's app and its ads and personalized content, if any tailored ad.
  • An Advertiser or Demand Partners whose site or app you have visited– we share information about how you have interacted with that Advertiser’s site, app or its ads.
  • With our service providers– we contract with companies who help with parts of our business operations (for example, storage of information, fraud control and monitoring). We require that our service providers only use your information in connection with the services they perform for us.
  • In connection with legal proceedings– when we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of SilverMob, our Partners or any other third party.
  • In connection with a sale of our business– if a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale.
  • In addition, we may disclose aggregated, anonymized information with other third parties. This information cannot be used to identify you.
  •  

    Ways to Collect Information

     

    SilverMob have developed different technological tracking tools to collect information from End User device, such as:

     

    • Our SDK – the SDK is a bit of computer code that app developers (such as our Publishers) can include in their apps to enable ads and personalized content to be shown, data to be collected, and related services to be implemented.
    • Along with our Partners, we may use tracking technologies such as cookies, JavaScript, beacons and Local Storage such as HTML5. Our Partners may also use Local Storage Objects (LSOs) such as Flash. Local Storage (LS) such as HTML5 and Local Storage Objects (LSOs) such as Flash are used to store content information and preferences. Various browsers may offer their own management tools for removing HTML5 LS’s. Beacons are clear graphic image(s) of 1×1 pixel that is delivered through a web browser usually as part of a webpage request. Web beacons operate as a tag that records an End Users visit to a particular webpage.
    • Our Publisher may use cookies to track your behavior on their apps or websites. A cookie is a small piece of text that is sent to a browser. The browser provides this piece of text to the originating server when the visitor returns. Most web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please note that some features of SilverMob may not function properly when cookies are disabled or removed.
    • JavaScript is a dynamic object oriented computer programming language. JavaScript is used to understand the End User's behavior on an app or website.
    • Directly from the Publisher through Server to Server (S2S) or Video Vast Tags etc.

     

    Consent Control

    Access to Ad Data through SilverMob SDK. SilverMob implemented a Consent Management Platform in our own SDK that allow to read and transmit information about which vendors and which purposes an end user has consented to with vendors.

    SilverMob will follow IAB standards and Consent Management Platform compliant with IAB requirements, in our own SDK in order to allow SilverMob to read and transmit information about which purposes the end user has consented.

    Online Behavioral Advertising:

    We use third parties who collect data about their apps' and sites' visitors through their own cookies, web beacons, and other technologies regarding your online activities, in an effort to understand your interests and deliver you advertisements that are tailored to your interests.

    These third parties include Publishers, Advertisers and ad networks that may collect information about when you view or interact with one of their advertisements and may collect information regarding your online activities over time and across different apps and websites.

    Like most Advertisers, we place advertisements where we think they will be most relevant to the recipient. When an End User visits a third-party website or app on which that network advertising company has purchased ad space, the advertising company can then recognize the individual's interest and deliver one of our advertisements.

     

    End User choice and Opt-Out.

    Ads delivered through SilverMob SDK will allow End Users to out-put with a mechanism that permits End Users to set their preferences.

    End Users from EEA can withdraw their consent given to SilverMob to collect and process data to optimize interest-based ads, by writing tocontact@silvermob.com. If you do not consent, the ads you see will be less tailored to your interests.

     

    Information Retention and Access to Information

     

    We may retain personally identifiable information we process on behalf of our Clients for  a period of up to twelve (12) months unless otherwise required by law or applicable contract. After the period, SilverMob may retain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes and enforce agreements. We may adopt shorter retention periods if so directed by our Clients.

    Please note that in most of the cases we have no direct relationship with the End Users. An End User who seeks access, or who seeks to correct, amend, or delete inaccurate information should direct his query to the relevant Publisher. If an End User requests us to remove any personally identifiable information relating to him or her, we will respond to their request within a reasonable timeframe.

    Security

    SilverMob has implemented reasonable security measures in order to protect your information from loss, misuse and unauthorized access, disclosure, alteration or destruction. While we cannot guarantee that loss, misuse or alteration to information will not occur; we make good faith efforts to prevent such occurrences. We do not warrant or represent that your account or any of your information will be protected against, loss, misuse, or alteration by third parties.

     

    International transfers

    SilverMob may transfer the information we collect about you to countries other than the country where we originally collected it for the purposes of storage and processing of information and operating our services. Those countries may not have the same information protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Policy and take steps, where necessary, to ensure that international transfers comply with applicable laws. We ensure it is protected by making sure at least one of the following safeguards is in place:

    • by transferring your personal information to a country that has been deemed to provide an adequate level of protection by the European Commission;
    • by using specific contracts approved by the European Commission which give your personal information the same protection it has within the EEA including to US;

    where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.


    Children Information

    SilverMob does not knowingly collect any personally identifiable information (including persistent device identifiers) relating to children under the age of 13. In addition, we require our Publishers to certify to us that their services (such as their mobile apps) are not primarily directed to appeal to children under the age of 13, and to avoid sharing with us any personally identifiable information relating to children under the age of 13.

    Please note that while we strive hard to ensure that our policies are respected, we cannot be held responsible for the practices of our Publishers. Our publishers are responsible to ensure that their privacy practices comply with applicable privacy laws and requirements.

    If you have knowledge of any incident in which we may be collecting personally identifiable information relating to children under the age of 13, or that our SDK is included in any service (such as a mobile app) that is directed to or aimed to appeal to audience under the age of 13, please let us know immediately by contacting us at: contact@silvermob.com, and we will remove their personally identifiable information from our servers without delay.

    The following section will only apply, if You are a Data Subject as defined under General Data Protection Regulation (“GDPR”) and also to the extent that SilverMob is in receipt of any Personal Data, as defined in Article 9 of the GDPR, originating in the European Economic Area (EEA), the United Kingdom, and Switzerland.

    The Rights of Data Subjects under GDPR:

    i. Right of access: Where SilverMob hold personal information about you, you can ask us for access to this personal information, to correct or update any inaccurate personal information we hold, to stop sending you ads or to stop using your personal information altogether;

    ii. Right to rectification: You have the right to require SilverMob to rectify any inaccurate personal information we hold about you. You also have the right to have incomplete personal information we hold about you completed, by providing a supplementary statement to us;

    iii. Right to restriction: You can restrict SilverMob’s processing of your personal information where:

    • you think we hold inaccurate personal information about you;
    • our handling of your personal information breaks the law, but you do not want us to delete it;
    • SilverMob no longer needs to process your personal information, but you want us to keep it for legal reasons; or
    • where we are handling your personal information because we have a legitimate interest, as described above, and are in the process of objecting to this use of your personal information.

    Where you exercise your right to restrict SilverMob from using your personal information, we will then only process your personal information when you agree, except for storage/archival purposes and to handle billing and legal claims.

    Right to data portability: You have the right to receive your personal information in a structured, standard machine-readable format and to send this to another organization controlling your personal information. This right only applies to your personal information we are handling because you consented to us using it or because there is a contract in place between us.

     

    iv. Right to erasure: You have the right to require SilverMob to erase your personal information which we are handling in the following circumstances (anonymization would satisfy erasure):

    • where we no longer need to use your personal information for the reasons we told you we collected it for;
    • where we needed your consent to use your personal information, you have withdrawn your consent and there is no other lawful way we can continue to use your personal information;
    • when you object to our use of your personal information and we have no compelling reason to carry on handling it;
    • if our handling of your personal information is in violation of applicable law; and
    • when we must erase your personal information to comply with a law we are subject to.

    v. Right to complain: You have the right to lodge a complaint with the Supervisory Authority.

     

    Changes to Our Privacy Practices

     

    We may update this privacy policy to reflect changes to our privacy practices, from time to time. If we make any material changes we will post such amendment on our website, prior to the change becoming effective; material changes will become effective seven (7) days as of the date we posted the notice on our website. We encourage you to periodically review this page for the latest information on our privacy practices (the last change will be reflected in the "last updated" date above).

     

     Have Any Questions or Comments?

    If you have any questions, concerns or feedback about our privacy policy, please don't hesitate to contact us at contact@silvermob.com. We will make our best efforts to respond to you in a timely manner.

     

    SilverMob uses Google Analytics cookies, which configuration is predetermined by the service offered by Google. We suggest you to consult the Google Analytics privacy pagehttps://support.google.com/analytics/answer/6004245 for more information about the cookies you use and how to disable them (we understand that SilverMob is not responsible for the content or veracity of third-party websites).

     

    Deactivating cookies

    The user can freely decide on the implantation or not in his hard disk of our cookies as well as his elimination, following the procedure established in the help section of his navigator. The user can also configure their browser to accept or reject by default all cookies or to receive an on-screen warning of the reception of each cookie and decide at that time whether to implement or not on its hard drive.

     

    Links to device manufacturers and browsers for the management or deactivation of cookies in your browser:

     

    For Internet Explorer:

    http://windows.microsoft.com/en-us/windows7/how-to-manage-cookies-in-internet-explorer-9

    For Chrome:

    https://support.google.com/chrome/answer/95647?hl=en

    For Safari:

    http://support.apple.com/kb/HT1677?viewlocale=en_US

    For Firefox:

    https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

    For Opera:

    http://help.opera.com/Linux/10.60/en/cookies.html

    For Android:

    http://support.google.com/android/?hl=en

    For Blackberry:

    https://help.blackberry.com/en/blackberry-classic/10.3.2/help/mwa1334238823957.html

    For Windows Phone:

    http://www.windowsphone.com/en-US/how-to/wp7/web/changing-privacy-and-other-browser-settings

     

    In the event that the user sets his browser to reject all cookies or expressly our cookies, that may suppose the unavailability to access to some of the services provided in this website and that the experience in it may be less satisfactory.