4INFO Respects Consumer Privacy
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.
Effective Date: December 30, 2019
. 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 “eMail Preferences" link found in emails we send to you, or you can opt-out by clicking here,
or by updating your personal information by contacting us as described below.
2. Overview of our Platform
Through our Platform, we help our 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. Through our Platform, we also help our clients to reach consumers with greater efficiency and relevance across various digital channels, including online, television and mobile. These services include data onboarding, data linking, and distribution.
3. Information We Collect
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 Platform.
We also may automatically collect and use information about how you access our Website or 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 pseudonymous 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 data that was originally connected to household addresses, or email addresses (which we may receive from partners or customers) (“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 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 may create proprietary unique identifiers to de-identify, anonymize or otherwise process or restrict the use of the data in a way that is intended to prevent our clients (or other third parties) from associating precise geo-location data with information we regard as “personal information” such as name, street address (e.g., 4 Maple Street, Apartment 410, Anywhere, USA, 12345”), telephone number, or email address.
We may link proprietary 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, 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.
Personal information we collect, use, and share.
Sharing for Legal Purposes:
Sharing In Event of a Corporate Transaction
: We may also share any information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
Sharing With Service Providers:
We may share any information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.
Sharing of Aggregate Information:
We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information
”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.
5. Your Rights as a California Resident and How to Access, Update, and Manage Your Personal Information
This Section 5 applies solely if you are a “resident” of California (as that term is defined in the California Consumer Privacy act (the “CCPA”). You should not rely on the information provided in this Section if you are not a resident of California.
Accessing and deleting data held by 4INFO
As described below, you may request a description of the following information collected during the past 12 months: the categories of personal information we have collected about you, categories of sources from which the personal information is collected, the purpose for collecting or selling personal information, and categories of third parties with whom we share personal information. You may also request specific pieces of data about you.
You may make any of these requests by submitting this request form
. You may also submit a verifiable request to us at firstname.lastname@example.org
or by calling (800) 206-8818. We may request additional information for purposes of verification.
You may request that we delete personal information we have collected from you by contacting us at email@example.com
Opt-out of sale of personal information
We do not sell your name, email address, physical address, precise location data or phone number. California law (the CCPA) broadly defines “sale” in a way that may include using services such as those provided by 4INFO to deliver interest-based advertising or marketing analytics.
Thus, under the CCPA, our products include selling the following categories of information to customers or partners for advertising purposes: identifiers such as Internet Protocol address, device IDs, cookie IDs, and advertising IDs; pseudonymized identifiers; demographic information such as household income, age bracket, and homeownership; commercial information such as the types of products or services you’re interested in purchasing; lifestyle interests such as whether you’re a car enthusiast and inferences drawn therefrom. (Some of the above may be inferenced from the various data we collect or receive.)
You have the right to direct us not to “sell” your personal information by submitting a request form
Verifying requests for access to categories of information, access to specific pieces of information and deletion Opt-out of sale of personal information.
To protect the privacy of your information and account, we are required to verify your request. The verifiable request must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request.
We reserve the right to require additional proof of your identity and California residency. We may withhold any information where we believe verification cannot be or has not been achieved to a sufficient degree of reliability, or where release of the information may pose too great a release to a person to whom the data may pertain.
You may also designate an agent (registered with the California Secretary of State) to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.
How to Opt-Out of our Ad Platform Targeting
You can opt-out of receiving targeted advertising from us. This will also opt you out from any sharing of your personal information with third parties for commercial purposes. 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 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 offers an “opt-out cookie” for those that wish to opt-out of 4INFO interest-based advertising (IBA) on the web. This cookie will honor your IBA preferences for a period of five (5) years. We may increase this period, which means your opt-out choice will continue for a longer period. If you have multiple Internet browsers or users on the same computer, you will need to perform the opt-out operation for each browser and/or user. If you or your anti-virus or other software deletes the opt-out cookies from your computer, if you re-install your browser, or if you delete your cookies (which can happen if you clear or delete your browser history), then you will need to repeat the process. 4INFO may be unable to provide you with an opt-out cookie if your browser is set to block third-party cookies.
You may also opt-out of web IBA conducted by 4INFO and other member companies of the Digital Advertising Alliance (DAA) by visiting the DAA website here
. Please note that the above opt-out link is applicable to 4INFO activities conducted on the web through “adhaven.com.”
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
6. Information Relating to Children
Our Platform, Website and services are designed for those 16 years of age and older. If we are made aware that we have received personal information from someone under 16, 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 https://www.oracle.com/us/assets/health-wellness-data-segments-2537888.pdf
(“Oracle Health and Wellness Segments”). If you would like to opt-out of having ads tailored based on those Oracle Health and Wellness Segments, or review this data partner’s privacy policies, please go to https://www.oracle.com/legal/privacy/marketing-cloud-data-cloud-privacy-policy.html
We have implemented security measures intended 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 use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
We retain the information we collect for up to 23 months, after which it is one way (i.e., irreversibly) hashed and/or anonymized, aggregated, and archived for business purposes.
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
11. Contact Us
If you have any questions or concerns regarding privacy at 4INFO, please send us a detailed message to firstname.lastname@example.org
. Alternatively, you may contact us via postal mail at:
4 North 2nd Street, Suite 1150
San Jose, CA 95113