Privacy Policy 

EFFECTIVE FROM MAY 2021 

Last updated April 2021 

1. Introduction   

This privacy policy (“Policy”) governs your use and access of the content displayed in the OEM webpage (the “webpage”). This webpage and its content are hosted by InMobi Pte. Ltd, (referred to as “we”, “us” or “our”) on behalf of the device manufacturer/carrier service provider (hereinafter referred to as “OEM”). We respect your privacy, and we are committed to protecting it. Please read this policy carefully to understand our practices regarding your personal data.  

This Policy describes (i) the types of data we may collect or that you may provide when you visit, access, and/or use the content of the webpage including when any advertisement or survey is displayed and/or as part of your interaction with such advertisement; (ii) how we use that data, and the purposes for which we collect it; and (iii) and how we disclose such data to third parties.  

Your OEM may also collect, process, store your data, and we urge you to refer the privacy policy of such OEMs. Please note that such OEMs may levy charges towards internet usage during browsing of the webpage, for which you will be solely responsible. 

1. Description  

The webpage provides you with interesting content and targeted advertisement subject to this Policy. 

1.  What data does the webpage collect and how is it used?  

User Provided Data – The webpage obtains the data you provide when you visit/access/interact with the webpage. We may ask that you provide:  

1. Location information, where permitted/enabled by the user, including Geo-location or precise location of your device is used to provide Weather information at user’s location and will not be shared with partners. 

 Automatically Collected Data - the webpage may in its operation collect certain information, such as:  

(a) Universal Unique identifiers – Unique identifiers are alphanumeric strings that are unique to your device. Typically an identifier UUID (Universal Unique identifiers) that we use with our partners so we can communicate for opt in/ opt out. 

(b) Network information, including  

• Carrier  
• Network type (e.g., WiFi or cellular)  
• IP address  

(c) Advertisement data. Our Ad partners collect data about the ads presented on your device, including:  

• The content type of the ad (the advertiser and category, e.g., mobile app utility, internet and telecom, network connectivity apps, telephony, sports, entertainment) 

• The ad type (e.g., whether the ad is a text, image, video or other format based)  
• Whether you viewed, clicked or otherwise interacted with the ad  

We use Cookies or pixels (or mobile cookies/pixels)/ web beacons for automatic information collection. These are a small file(s) placed on your smart device. These permit the webpage, for example, to count users who have visited those pages or for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). It may be possible to exercise the choice to accept cookies by activating the appropriate setting on your smart device. However, if you select this setting you may be unable to access certain features of the webpage. Please see Section 7 “What are my privacy rights?” below. 

Types of cookie	What they do	Opt-out mechanism
Essential website	Show new users the privacy policy on their first page visit  Opt-out mechanism with 3rd parties so we do not show target ads	https://lenovo-content.com/unregister    https://wap.boostmobile.com/unregister    https://yes-swish.com/unregister
	Content
	Ad Personalization
Analytics web beacons and customisation cookies	Analyze how page is used by users	https://tools.google.com/dlpage/gaoptout/
	A/B testing

  

Some of these data sets, including cookies may be considered to be personal data, in which case, we ensure compliance with the privacy laws (in force) in our collection, processing or use of the same, to the extent applicable in such jurisdictions including certain data subject rights that you may enjoy under such applicable laws. We do not collect sensitive information such as biometric data, sexual preference, physical or mental health information, political opinions, religious beliefs, credit card and other banking related information, etc. Personal data does not include aggregate, de-identified or anonymous information. 

The personal data we collect helps us to improve our services, conduct attribution, fraud detection and to deliver a better personalized experience which may include content and advertising customized to individuals’ interests, preferences and locations and to perform analysis aimed at improving your user experience. We may use the information to:  

• Provide you with the webpage features and its contents and suggestions;  
• Provide advertisements, surveys and/or promotional content that may be of interest to you;  

• Conduct analytics such as estimate our audience size and usage patterns. 

 

1. Does the webpage collect precise real time location information of the device?  

No, we infer the region basis your IP Address to be able to show appropriate privacy notice/ consent. The IP Address is stored on your browser and we do collect/ process/ store it in our database. We may infer the city level information from the IP Address to be able to show you the weather updates. We collect real time location only if you have provided us your consent to do so. 

You may at any time change your settings to prevent the webpage from accessing your location data. Please see Section 8 “What are my privacy rights?” below and scroll down to find tools to withdraw consent from the collection of this data. 

1. Do third parties see and/or have access to data obtained by the webpage?  

Yes, we may share your data with third parties in the ways that are described in this Policy:  

• Disclosures to protect us or others. We may access, preserve, and disclose any data we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and 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 illegal activity;  
• Advertising networks and Analytics companies. We may share your information with brands, advertisers and analytics companies to allow them to understand the performance of their campaigns; and to help them better target their campaigns, products or offerings;  
• Service Providers. The categories of service providers (processors) to whom we entrust personal information include: IT and related services; fraud detection, information and services; customer service provider; in relation to any contracts including with respect to billing, collection, disputes;  

• Affiliates. We may share personal information with our affiliates for their business purposes including data analytics, data management, audiences, insights, content management and targeted advertising (subject to adherence to any legal or regulatory directives); and  
• Disclosure in the Event of Merger, Sale, or Other Asset Transfers.If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.  

We may disclose aggregated or de-identified personal information about our users, and information that does not identify any individual or device, without restriction.  

1. International Transfers 

We may share your information with clients, affiliates and other third parties described above who are based in countries outside of your country of residence (for example, if you are an EU resident, we may share your information with our non-EU clients or affiliates), subject to any contractual or legal requirements. This means that their processing of your personal information will involve a transfer of data outside of the EEA. 

Whenever we transfer your personal information outside of the EEA, 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 USA; 

If you wish to learn more about the specific circumstances when each of these protection measures are used, you can contact us at privacy@inmobi.com for the details as to how we protect specific transfer of your data. 

1. Automatic Data Collection, Cross Device Tracking and Advertising  

This webpage is intended to comply with the Self-Regulatory Program for Online Behavioral Advertising found at http://www.aboutads.info/principles/. We work with online advertising companies to provide you with relevant and useful advertising. Some of the ads you receive are customized based on predictions about your interests generated from your visits over time and across different applications and websites. For example, our partners may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.  

Our partners may use tools or third-party analytical software to collect and use certain user data, as listed in section 3 above. These data sets help us in improving their services to ensure they are more tailored to your interests.  

We and our partners reserve the right to use and disclose the collected data in a de-identified, anonymized and/or aggregated manner for the business purposes stated herewith. We and our partners do not collect/ share any information such as your name, phone number or email address to other ad networks or advertisers.  

We may work with attribution partners and analytics companies to help us understand how the webpage is being used, such as the frequency and duration of usage. We also work with advertisers and third-party advertising companies, advertisers, ad networks, ad servers that collect information about how you interact with advertising and content provided in the webpage. Advertisers and advertising companies use some of the data collected by the webpage, including the advertising identifier assigned to your device to serve advertisements that are targeted to your interests in the webpage.  

Our customers, partners or vendors (including without limitation advertising companies, advertisers, ad networks, OEMs, other application developers, data enrichment partners, etc.) may disclose to us certain personal or non-personal data they have separately collected about you so that we can effectively provide our services. They do this in accordance with their own specific privacy policies and subject to their own applicable legal requirements. 

1. What are my privacy rights?  

To learn how to opt out of the use of data collected from this webpage including third party use, for targeted advertising purposes, please use the links provided in Section 3 What data does the webpage collect and how is it used. If you have questions or concerns about this, please write to us at apps-dsr@inmobi.com. 

Additional rights for users based out of State of California (in the United States): You have a right to exercise certain data subject rights such as request to access/ correct/ delete/ anonymize your data, collected by us in the last 12 months. We would like to inform you that we do not share/ sell any of your personal data with any third party. 

To the extent the privacy laws applicable to our processing of your personal data, provides certain data subject rights to you, please reach out to apps-dsr@inmobi.com   

The webpage assumes no responsibility for any third-party landing pages you access or your direct interaction with any third-party advertisers even if you engage with any specific advertisement or survey campaign displayed through the webpage; we recommend that you review the privacy policies of such third parties that you elect to interact with. 

1. Privacy of Children  

The webpage is meant for general audience and is not targeted to children. If a parent or guardian becomes aware that his or her child has provided us with data without their consent, he or she should contact us at apps-dsr@inmobi.com.  

1. Security  

We use reasonable technical and organizational measures to protect the information we collect about you in compliance with its legal and privacy requirements and contractual obligations. We also seek appropriate contractual protection from our partners and service providers regarding their collection, use or treatment of user data. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.  

1. Data Retention Policy  

We store the data we receive as described in this Policy for as long as you use our webpage or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. 

1. Change to this Privacy Policy  

This Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new < URL to where we store this Policy> with a notice on the site prior to the change becoming effective. 

1. Do Not Track  

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.  

1. Contact Us 

If you have any questions regarding privacy while using the Application, or have questions about our practices, please submit a thorough description at apps-dsr@inmobi.com.