Last Updated:  October 16, 2017

This Privacy Policy explains how inMarket Media LLC (“inMarket”) collects, uses, and shares information about you that we receive when you download or use a mobile application or visit a website that uses our services, including our software development kit, our mobile advertising platform, our technology, and our related services (collectively, “our Service”).

Third Party Partners are companies who use our Service, such as publishers who integrate our software development kit (“SDK”) into their mobile applications.  We advise our Third Party Partners to maintain appropriate privacy policies per local requirements and accepted industry standards.

inMarket is a proud member of the Network Advertising Initiative (NAI).  inMarket follows the code of conduct and recommended practices of the NAI.

How does inMarket collect data?

We collect data through our Service.  Our Service uses technology such as our SDK that is integrated into our mobile applications and our Third Party Partners’ mobile applications.  Our Service may also use technology such as cookies, ad tags, and pixels.  Cookies are small files sent to your device when you visit a website that allow the site to remember your device and your preferences.  Ad tags and pixels are pieces of software code used for tracking.  We may use cookies, ad tags, pixels, and similar technology provided by us or our Third Party Partners to collect data when you use applications or websites that integrate such technology.

What information does inMarket collect?

Usage Information

When you download or use a mobile application or website that uses our Service, we may automatically collect certain usage information from your device on a regular basis.  Here are some examples of the types of usage information we may collect:

  • Internet protocol address‚ device operating system, browser type‚ referring website, the pages viewed on the website or mobile application, and the name and version of the mobile application running on the device.
  • Device location from GPS data. If your device settings allow the device to share location information with a mobile application that uses our Service, then we may collect GPS data from the application on your device.  If you disable location in your device settings or disable location permissions to that application, that application will not send GPS location data to us.
  • Device Bluetooth-related location and surroundings data. If your device settings have Bluetooth enabled, then we may be able to detect the Bluetooth devices such as beacons around your device and their signal strength.  Many retailers and other public locations have installed such Bluetooth devices.  If you disable Bluetooth and any Bluetooth scanning option in location settings in your device settings, your device will not send Bluetooth data to us.
  • Device wifi-related location and surroundings data. If your device settings have wifi enabled, then we may be able to detect the wifi networks around your device and their signal strength.  If you disable wifi and any wifi scanning option in location settings in your device settings, your device will not send wifi data to us.
  • Device advertising ID, which can be called the IDFA on Apple devices and the Advertising ID on Android devices. You can reset or opt out of sharing device advertising ID in your device’s settings.  For information on how to do this on Apple devices, visit Apple.com or https://support.apple.com/en-us/HT202074.  For information on how to do this on Android devices, consult your owner manual or visit Google.com.
  • Data stemming from cookies, pixels, embedded tags, and any similar technologies that we place on a browser when it interacts with our website or a mobile application that integrates our SDK. Browsers generally allow you to select settings that limit or decline cookies on your device.

Personal Information

We also collect personal information about you when you interact with inMarket through our websites, mobile applications that integrate our Service, or our Third Party Partners.  We define Personal information as information that directly and specifically identifies a particular individual.  The personal information we may collect includes your name‚ email address‚ mailing address‚ loyalty program number, and phone number.  Here are some examples of ways in which you may share personal information with us:

  • Creating or updating an account on a website or mobile application that integrates our Service;
  • Requesting customer service or otherwise contacting us;
  • Sharing financial transactions or receipts;
  • Downloading a mobile application that integrates our Service and opting to share phone number or other personal information with the application;
  • Participating in a contest‚ sweepstake‚ coupon, rebate, promotion‚ or survey; or
  • Otherwise submitting personal information to us.

Information from Third Party Sources

We may also collect information about you or your device from third party sources. The information we collect from third party sources may include things like demographic information and purchase information. The third party sources may include public databases‚ social media platforms‚ data append services‚ data sharing cooperatives‚ and others.  We may use this third party data to supplement the usage information and the personal information we have collected about you.

How does inMarket use the information it collects about you?

We may use the information we collect about you for marketing, for research, and for any other purpose allowed by law.  For example, we may use the information we collect to generate a profile such as “Fast Food Eater” or “Pet Owner”.  We may make inferences about your home address, your office address, and other locations you visit based on the location information we collect.  We may use the information we collect to deliver better targeted advertising to you in the application, on websites, or across other devices.  We may augment the information we collect with 3rd party data sets to augment attributes like age and gender. We may use non-personally identifiable information we collect about you and combine it with other non-personally identifiable  information we collect about others to create aggregated analytics data or market reports.   If your device, platform, and Bluetooth settings permit us to do so, we may also broadcast Bluetooth Low Energy signals from your device.

Your opt-out choices

You can opt out of our email mailing lists by visiting the opt-out link included on the bottom of each such email.  If you would like our mobile application and/or any third party mobile application that integrates our SDK to stop collecting information about you, you can: 1- disable your Ad ID (select Limit Ad Tracking) and we will not collect your information for any advertising purposes or 2- follow the instructions from your device’s operating system or device manufacturer to uninstall the application in question.  You can also make the following choices:

  • disable location sharing in your device settings to stop sending GPS location data to us;
  • disable Bluetooth in your device settings to stop sending Bluetooth-related data to us;
  • disable wifi in your device settings to stop sending wifi-related data to us;
  • reset your device’s advertising ID or disable it on your device via the device settings [for Apple devices, visit apple.com for more information; for Android devices, visit google.com for more information];
  • modify the cookie settings in your browser;

We may target users with data collected from your mobile device across devices other than your mobile device.  If you want to opt your other devices out of receiving targeted ads, you can do the following:

  • To opt out of interest-based advertising on our websites or on other websites that are part of NAI industry group, click- http://optout.networkadvertising.org/#!/ and/or:
  • To opt out of interest-based advertising on our websites or on other websites that are part of DAA industry group, click- http://optout.aboutads.info/#!/.

Please note that your choices must be made on each device, application, and/or on each browser you use. If you disable or remove these technologies from your device, websites and mobile applications that integrate our Service may not work or may not work in an optimal manner.

Please also note that there are many different signals or other mechanisms for consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third party websites or online services, such as browser do-not-track signals. Currently, we do not monitor or take any actions with respect to such signals or other mechanisms.

How and when does inMarket disclose the information it collects about you to third parties?

We may disclose the personal and usage information we collect about you to third parties unless applicable law prohibits us from doing so.  For example, we may share the usage and personal information we collect about you with the following entities:

  • third party application developers who have integrated the inMarket SDK into their application;
  • advertisers who participate in our mobile advertising business;
  • market research, financial research, or investment companies;
  • third party marketing companies;
  • third parties who provide services to us; and/or
  • our subsidiaries and other corporate affiliates.

We may sell the information we collect about you to third parties.  We may also disclose, sell or otherwise transfer personal information and/or usage information about you in connection with a potential or actual corporate merger, consolidation, restructuring, sale of our business or assets, or any other corporate change.

We may also access, use, preserve, transfer, and disclose information about you:  (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Terms of Use for our websites, our mobile applications, or any third party mobile applications that integrate the inMarket SDK, including investigation of potential violations thereof; (iii) to protect the safety, rights, property (including intellectual property), or security of inMarket or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues.  Such disclosures may occur without notice to you.

Children under 13 years of age

Our Service, our websites, our mobile applications, and third party mobile applications that integrate the inMarket SDK are intended for general audiences and do not knowingly collect or store information regarding children who are under 13 years of age.  If you are the parent/guardian of a child under 13 years of age and believe the child has disclosed personal information to us, please contact us at legal@inmarket.com.

Data Security

We incorporate commercially reasonable and appropriate physical, electronic, and administrative safeguards to protect the information we collect.  However, no physical, electronic, or administrative safeguards system is impenetrable, and we cannot guarantee the security of any information collected by us or submitted to us.  We do not retain device specific information after 5 years unless we have an active account for a user.

Modifications

We reserve the right to change this Privacy Policy at any time without notice to you other than posting the revised policy on our website and/or via our mobile applications.   Any changes will be effective immediately upon the posting of the revised Privacy Policy and your subsequent use of our website, our mobile application, or the third party mobile application that integrates the inMarket SDK indicates your consent to the privacy policy posted at the time of use.

Contact Us

If you’d like more information or have questions about this Privacy Policy, please contact us at legal@inmarket.com.

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