Privacy policy

Last updated: 18.10.2021

At SilverMob we are committed to safeguarding the privacy of our website visitors and service users. This Privacy Policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. We recommend you to read this Privacy Policy carefully and ensure that you understand it. If you do not agree to the Privacy Policy you should immediately stop using our website and services.

By using our website and agreeing to this Privacy Policy, you consent to our use of cookies in accordance with the terms of this Privacy Policy. Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

In this policy, “SilverMob”, “we”, “us” and “our” refer to ArtChaos s.r.o. Further details about the company are available in “Our Company Details” section below.

What does this policy cover?

This Privacy Policy applies only to your use of our website and services. Our website and services may contain links to third party websites. Please note that we have no control over how your data is collected, stored, or used by these third party websites and we recommend you to check the privacy policies of any such websites before providing any data to them.

Definitions

In this Privacy Policy the following expressions have the following meanings:

Personal data	Any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
Non-personal data	Any information that does not directly or indirectly identify an individual. It also includes aggregated and anonymized data.
Data controller	An entity that determines the purposes and means of the processing of personal data.
Data processor	An entity that processes personal data on behalf of a data controller.
Data subject	A natural person about whom a controller holds personal data and who can be identified, directly or indirectly, by reference to that personal data.
European Economic Area, or EEA	European Union countries together with Iceland, Liechtenstein, and Norway.

How we collect your personal data?

Depending on your use of our website and services, we may collect and hold certain personal information about you. This information may involve personal and non-personal data. We may collect your information either when you provide us with your personal information or through your use of our website and services. We may collect your information in the following situations:

1. When you are surfing our Web: We receive information like your IP Address, your browser through requests made by your browser, but we do not store it and do not use it for any tracking purposes. We may use this information in order to protect our services, detect fraud or prevent any harmful actions (for example attacks). Also, we collect analytics information through our cookies. SilverMob informs you that our website uses cookies and lets you consent to or reject the use of cookies.

2. When you are joining our Platform: We may ask you to provide certain information, including name and email address, before joining our Platform. You also accept our Contractual General Terms and this Privacy Policy in order to join our Platform. Information shared by you in the registration process would be used to the following purposes:

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

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

Third party service providers could access this data on behalf of SilverMob for the provision of the contracted services. SilverMob has signed the corresponding service provision agreement with these providers which set forth provisions requiring them to handle the data according to SilverMob’s instructions and applying the legally established security measures.

3. When you are using SilverMob Services: 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.

• 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) or Android Advertising ID.
• 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 and city). 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, 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) and having received a consent from the user.

• 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 such as IP address, user location, user agent, device 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.

All of the above-mentioned data is collectively referred to as “Ad Data”.

4. When you contact us using our web form: You have the possibility of getting in touch with us through the web form on our website. When you contact us using this form, we require you to provide certain information such as your name and email. This information will be used to get back to you with responses to your inquiries. 

5. When you send us an email: You may send us an email using our email address on our website. We may see certain information about you such as your name, email address, and any other information you choose to share with us. 

6. When you contact us through social media: We operate social media pages where you can get in touch with us either by directly messaging us or mentioning us in your posts. In such a case, we would see the data (including any personal data) you have decided to share with us. Depending on the medium, the personal information we might get about you could include your name, email address, where you work, job title or anything else.

Legal Basis of Processing

The General Data Protection Regulation (“GDPR”) requires us to have a valid and lawful legal basis for processing personal data. We rely on the following legal basis:

Consent: We may rely on your consent for us to use your personal information. When we rely on your consent as a legal basis for processing, we require you to consent to the collection and use of your personal data by us. This may, especially, be the case when you are joining our Platform or accept the use of cookies (GDPR Article 6.1(a)). 

Contractual Necessity: We may rely on the performance of a contract as a legal basis to use your information. This legal basis may apply as you have to agree to our Contractual General Terms which is a legally binding agreement between you and us (GDPR Article 6.1(b)).

Legal obligations: We may rely on the legal obligations to process your personal data. This could include a court order, or to exercise or defend legal claims (GDPR Article 6.1(c)). 

Legitimate interests: We may also rely on our legitimate interests to process your personal data. When we rely on this legal basis we ensure that your rights and freedoms are not violated. Our legitimate interests would include to run, grow, develop and deliver our website and services, enhance the security of information systems, and enhance, modify, or otherwise improve our services and communications (GDPR Article 6.1(f)).

Our role in processing Ad Data

Depending on the way we collect Ad Data, SilverMob will operate as an independent data controller or a data processor following Publisher’s instructions and directions, not having in any case direct relationship with the End Users whose information SilverMob will process.

How we use Ad Data

We may use Ad Data for the following purposes: 

• 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’.
• 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.
• Ad retargeting – we carry out ad retargeting campaigns in order to remind our website visitors of our services after they leave. We use Google and Facebook for the ad retargeting purposes. 
• Fraud detection and prevention – identify invalid or incentivized clicks (or ad queries) and protect SilverMob and our partners from fraudulent behavior. SilverMob may collect location, IP, user agent, browser details, system details only to detect fraud but not for building a profile or identification.
• 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.

All of the purposes mentioned in this section may collectively be referred to as “Permitted Purposes”.

How we share your information

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

• 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 – we share information about how you have interacted with 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 and not for any secondary purposes.
• 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 we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party.
• Aggregated and anonymized data -  we may disclose aggregated, anonymized information with other third parties. This information cannot be used to identify you.

Ways to Collect Information

SilverMob has 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 JavaScript and beacons. 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.
• 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

SilverMob relies on SDKs of our partners and our own for consent management. We have implemented a Consent Management Platform in our own SDK that allows us to read and transmit information about the category or list of vendors and for which purposes an end user has consented to share personal data.

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

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.

If you wish to opt-out from SilverMob, you can contact us by writing to our email contact@silvermob.com

Data 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 this 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.

When we get requests of ads from advertising partners including user information we store it for a period of 3 months for the sole purpose of being able to resolve any claims with publishers or advertisers.

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

We 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:

• Adequacy decision: We may transfer your personal information to a country that has been deemed to provide an adequate level of protection by the European Commission. The current list of the countries providing an adequate level of protection can be found here;
• Standard Contractual Clauses: If the event there is no adequacy decision of the EU Commission with the country where to transfer your data to, we will use specific contractual clauses approved by the European Commission which give your personal information the same protection it has within the EEA;

Children’s Personal 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.

Rights of Data Subjects

Under the General Data Protection Regulation (GDPR), you have the following rights, which we will always work to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the contact details provided in this Privacy Policy.
2. The right to access the personal data we hold about you. This Privacy Policy will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the contact details specified in this Privacy Policy to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. You have the right to require SilverMob to erase your personal information which we are handling in the following circumstances (anonymization would satisfy erasure): (i) where we no longer need to use your personal information for the reasons we told you we collected it for; (ii) 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; (iii) when you object to our use of your personal information and we have no compelling reason to carry on handling it; (iv) if our handling of your personal information is in violation of applicable law; and (v) when we must erase your personal information to comply with a law we are subject to. 
5. The right to restrict (i.e. prevent) the processing of your personal data. You can restrict SilverMob’s processing of your personal information where: (i) you think we hold inaccurate personal information about you; (ii) our handling of your personal information breaks the law, but you do not want us to delete it; (iii) SilverMob no longer needs to process your personal information, but you want us to keep it for legal reasons; or (iv) 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.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
9. Rights not to be subject to automated decision-making and profiling. 

For more information about your rights and how you can exercise them, please contact us using the contact details provided in this Privacy Policy.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the appropriate supervisory authority. We would, however, welcome the opportunity to resolve your concerns ourselves. That is why we encourage you to contact us first, using the contact details indicated in this Privacy Policy.

Data Subject Access Requests

GDPR allows data subjects to request an access to their personal information held by data controllers. If you want to know what personal data we have about you, you can ask us for details of that personal data and request a copy of it. This is known as a “data subject access request”, or DSAR.

You can exercise your right to access your personal data by contacting us through any means. Nevertheless, we would welcome any data subject access requests in writing and sent to us via email address set out in this Privacy Policy. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 15 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

Changes to Our Privacy Practices

We may update this Privacy Policy to reflect changes to our privacy practices, from time to time, at our sole discretion. 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).

Questions and 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.

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.

If you wish to reset your advertising IDs, please follow the instructions relevant to your device:

 View instructions here
 View instructions here

Our Company Details

This website is owned and operated by ArtChaos s.r.o.
Registration number 04626427
Registered office is at Vlkova 532/8, Praha 3, 13000, Czech Republic
Our principal place of business is at Vlkova 532/8, Praha 3, 13000, Czech Republic