Moloco Advertising Services Privacy Notice

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.

1. 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.

2. 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.

3. PERSONAL INFORMATION WE COLLECT

Below are the types of personal information collected by the Advertising Services:

1. Device and Browser Information

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.

2. Personal Information Provided by Others

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.

4. HOW WE USE PERSONAL INFORMATION

1. 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.

2. 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.

3. 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...

4. 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.

5. 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.

1. 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...

2. 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.

3. 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.

6. 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.

7. 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.

8. 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.

9. 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.

10. CHILDREN’S PERSONAL INFORMATION

We do not knowingly collect personal information from children under 18.

12. CONTACT US

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.
privacy@moloco.com

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.