4INFO Respects Consumer Privacy

TRUSTe
4INFO Inc. is committed to establishing and maintaining privacy best practices and to giving users control over their mobile advertising experience. Users’ privacy rights are maintained while advertisers are presented with audience segments to target.

How to Opt-Out

To opt-out of 4INFO’s interest-based advertising, please use your mobile device to go to our Ad Preferences mobile opt-out page. Please note that if you change your mobile device, you will need to renew your opt-out choice, and if you use more than one device, you must opt-out on each device by visiting this site from the browser on that device. You can opt-in again at any time by visiting the Ad Preferences page. Please note, due to technology limitations YOU CANNOT opt-out of mobile advertising from your computer. You must visit the preferences page from your mobile device(s) to opt-out.
 

4INFO Privacy Policy

Effective Date: January 20, 2017 
 
1.     Introduction
We (“4INFO,” “us,” “our” or “we”) have designed this 4INFO Privacy Policy (“Privacy Policy”) to help you understand how our ad-serving technology platform (our “Ad Platform”) collects, secures and uses information to help us provide advertising services to our clients, and to target ads through mobile products and networks. It also explains your choices regarding use, access or correction of your information, as well as your opt-out rights, if you do not wish to receive targeted advertising. “Users” (or “you”) includes anyone who interacts with the services we offer, whether through a website, app, messaging product or other platform, which contains an ad sent by or through a service that we provide, including the Ad Platform.

We may partner with third parties to display advertising on 4INFO.com (“Website”) or to manage our advertising on other sites. Our third party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here. Please note you will continue to receive generic ads.

You may also provide us information via our Website, such as your name or email address when signing up for a newsletter or content download.  If you would like to discontinue receiving such communications, you may manage your preferences by using the “Unsubscribe” link found in emails we send to you, or update your personal information by contacting us as described below.

If you have questions or complaints regarding our privacy policies or practices, please contact us as indicated in this Privacy Policy. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
 
2.     Overview of our Ad Platform
Through our Ad Platform, we help advertising clients deliver ads and content to mobile devices by serving ads to you while you are on mobile websites, mobile games and applications (“apps”). We also work with web-based platforms that employ browser-based technology, to facilitate ads while you are online. We help our mobile and web-based advertising clients tailor ads and content to you that we think are more likely to be relevant to you. We also sometimes help them analyze their “audience” – how users appear to be responding to their ads or products.

To do this, we collect and use the information that we’ve described in this Privacy Policy. We also provide an easy opt-out, as we’ve described below under “How to Opt-Out” in Section 5.
 
3.     Information We Collect In Order to Serve Ads and Content
We gather several types of information from you that help us and our data partners serve ads that are interest-based and provide analytics services related to ads, like inferring which ads performed better or worse based on user behavior on or off of our Ad Platform.

We receive information from apps, games and similar mobile products that we work with, and the platforms that host and work with them. This information may include geo-location data (including precise geo-location data), as well as demographic data, connection data associated with your mobile device (such as your browser or device type), your zip+4 postal code, and the wireless carrier to which you subscribe. It may also include what actions you have taken on advertising we have served you. For instance, if you respond favorably to ads about sports, we may target your preferences based on that. In addition, if you click on an advertisement we have delivered to you, we may receive information about that interaction, which may include from what app or website you clicked an advertisement or that you subsequently downloaded an app. For purposes of this Privacy Policy, “precise geo-location” data is a record of your location sufficient to identify an accurate address, or a functionally equivalent identifier. For instance, “Corner of Elm and Maple, Anywhere, USA” is “precise geo-location” data, as is “One Main Street, Rivertown, Alaska.”

We also may automatically collect and use information about how you access our Website or Ad Platform, including: the IP address used to access the mobile Internet, the type of phone or other mobile device used, the Internet service provider (“ISP”), the clickstream data, the unique device advertising-identifier, the date and time a mobile ad was delivered and, if applicable, clicked on.

We also use geo-location data as a way to target users through de-identified and/or anonymous data segments that we create or receive, including through geographic, demographic or interest-based data provided by our data partners, which may be derived from household level data (“Data Segments”). These segments might suggest, for instance, that you might be interested in receiving an ad for a convertible rather than an SUV, or a trip to Las Vegas instead of to Disneyland. We may also collect and retain other information that you willingly provide to us, through various online and mobile communication methods.

As described in Section 4, in order to help us better predict which ads may interest you, we may make certain inferences based on data we collect (including geo-location data), and enhance that data with other de-identified or anonymized segments provided by third party sources.
 
4.     How We Use and Share the Information We Collect
We use the information we collect to help advertising clients better target ads and content to you, and analyze trends about how users react to advertising.  Where the information could reasonably identify who you are, we create anonymous, unique identifiers to de-identify, anonymize or otherwise process the data in a way that is intended to prevent our clients (or other third parties) from associating precise geo-location data with information such as name, address, telephone number, or email address.

We may link anonymous identifiers to Data Segments, including by making inferences based on geo-location data sets. This combination of information may allow us to infer whether multiple devices are associated to the same general location, such as to a household. We may also work with web-based ad exchanges and other networks who use similar technology, identifiers and information (like IP addresses) to tailor (or help us to tailor) ads and offers across mobile and/or web-based channels: for instance, this may involve correlating a User’s interactions on one device (such as a browser on a computer) with her interactions with another device (such as an app on a phone).  In either case, we may tailor ads based on inferences we or our partners have drawn from such geo-location data, Data Segments correlated to such geo-location data (such as demographic data), or both.

We may work with or on behalf of our clients to communicate with you regarding certain products and services. When we do so, we may share the information you have provided us with them, in order to fulfill those requests. We also may aggregate this information and share it with other companies, partners and providers we work with. 

We also may provide the information we collect to companies that perform services for us, such as technical or operational services, or that store the data. These companies are authorized to use your personal information only as necessary to provide these services to us to assist us in our business activities.  

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet law enforcement requirements.  We also may share the information with third parties if we believe in good faith it is necessary to comply with applicable law; enforce or apply our Terms of Use and other agreements; protect the rights, property, or safety of 4INFO, our employees, our users, or others; or for fraud prevention purposes.  We may also disclose your personal information to any other third party with your prior consent.  

In addition, if 4INFO or all or substantially all of its assets were acquired, or in the unlikely event that 4INFO goes out of business or enters bankruptcy, your information may be transferred or acquired by a third party, subject to the conditions of this Privacy Policy.  If so, you will be notified via a prominent notice on our website of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.
 
5.     How to Opt-Out of our Ad Platform Targeting
You can opt-out of receiving targeted advertising from us. Please keep in mind that even after you opt-out, you will continue to receive ads, but we will no longer tailor those ads based on your interests or activity. To opt-out of interest-based advertising, use your mobile device to go to our mobile Ad Preferences opt-out page. Please note that if you change your mobile device, you must renew your opt-out choice, and if you use more than one device, you must opt-out of each device by visiting this site from the browser on that device. Also keep in mind that you can opt-in again at any time by updating your preferences by visiting the Ad Preferences Management page from your mobile device. Please note, due to technology limitations YOU CANNOT opt-out of mobile advertising from your computer. You must visit the preferences page from your mobile device(s) to opt-out.

Mobile device system software such as Apple iOS or Google Play Services provide an opt-out choice that will be communicated to companies providing interest-based, in-app advertisements. For more information, or to opt-out using these mechanisms, consult your device settings. If you prefer to not have your precise geo-location data collected, you can also make this selection within your mobile device settings.

Some opt-out mechanisms will use the HTML5 local storage of your device in order to save your choice preference. We may view the local storage of your device in order to determine what choices, if any, you may have made previously. If we recognize a choice preference within the local storage of your device, we will honor that request. 
 
4INFO and our partners also use cookies or similar technologies to analyze trends, administer our Website, track users’ movements around the Website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.  To manage Flash cookies, please click http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
 
As described above, we sometimes work with web-based platforms to help tailor online and mobile ads. If you wish to learn more about or opt-out of those platforms, please go to http://www.aboutads.info/choices or http://www.networkadvertising.org/choices/.
 
6.     Information Relating to Children
Our Ad Platform, Website and services are designed for those 13 years of age and older.  If we are made aware that we have received personal information from someone under 13, we will use reasonable efforts to remove that information from our records immediately.
 
7.     Information Relating to Health Conditions
We do not create Data Segments based on health or medical conditions. We may, however, work with partners that create those types of Data Segments and we may serve advertising based on these Data Segments. To learn about some of the health-based Data Segments we or our partners may work with, please go to http://www.datalogix.com/health-related-segments/ (“Oracle Datalogix Segments”). If you would like to opt-out of having ads tailored based on those Oracle Datalogix Segments, or review this data partner’s privacy policies, please go to https://www.datalogix.com/privacy/.
 
8.     Security
We have implemented security measures to protect the information in our care, both during transmission and once we receive it. This includes, but is not limited to, the use of firewalls and encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

We retain the information we collect for up to 25 months, after which it is one way (i.e., irreversibly) hashed and/or anonymized, aggregated, and archived for business purposes.
 
9.     Changes to This Privacy Policy
From time to time, we may revise this Privacy Policy to reflect changes to the services or for other reasons. Therefore, it is important to check this Privacy Policy periodically. If we make any material revisions to this Privacy Policy, we will provide advance notice on our Website. It is the obligation of users visiting this Website to learn of changes to the Privacy Policy since their last visit. Any change to this Privacy Policy shall be effective as to all visitors once instituted (or as otherwise stated by us).

10.     Industry Memberships
4INFO supports industry self-regulation, and endorses best practices and self-regulatory requirements that apply to the Ad Platform. 4INFO participates in the Digital Advertising Alliance (DAA) Self-Regulatory Program. 4INFO licenses the “AdChoices” advertising icon within ads that it serves through mobile and online channels. Learn more at http://www.aboutads.info.

We are a member of the Interactive Advertising Bureau (the IAB) and the Mobile Marketing Association (the MMA).

11.     Contact Us

If you have any questions or concerns regarding privacy at 4INFO, please send us a detailed message to privacy@4info.com. Alternatively, you may contact us via postal mail at:

Privacy Officer

4INFO, Inc.
155 Bovet Road, Suite 200
San Mateo, CA 94402