Publication Date: June 3, 2022
1. TYPE OF INFORMATION PLAYWIRE AND THIRD PARTIES COLLECT.
By use of the Services, Platforms and Networks, Playwire may collect two (2) types of information about Users: Personal and Non-Personal. In addition, Playwire works with advertisers, ad agencies, third-party traffic measurement services and other service providers (collectively “Third Parties”) to serve advertisements on publishers using the Playwire Services, Platforms and Networks. Third Parties may set and access their own tracking technologies on your device including but not limited to cookies, web beacons, device identifiers and other information as described below.
- “Personal Information.” Personal Information refers to information that lets Playwire know the specifics of who you are and which may be used to identify, contact or locate you or a business interested in the Playwire Sites, Software, the Services, Platforms and Networks (e.g., name, mailing address, telephone number and e-mail address). Playwire may collect Personal Information when you use the Playwire Sites including, without limitation, setting up account information, filling out surveys, corresponding with Playwire, or otherwise volunteering information about yourself. Playwire does not sell, trade or rent Personal Information collected through the Playwire Sites to any third-party. Notwithstanding the foregoing, Playwire shall: (1) fully cooperate with law enforcement agencies; and (2) may be required to disclose Personal Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation.
- “Non-Personal Information.” Non-Personal Information refers to information that, by itself, does not identify you as a specific individual (e.g., demographic information or website visitations). Playwire and/or advertisers, advertising agencies, third-party traffic measurement services and other service providers may collect and/or process Non-Personal Information through a variety of methods and industry standard technologies described further below.
- Information about your browser including: the type of browser you use, browser language, browser settings, cookie information and other locally stored objects. This may include data about you related to bid requests and ad impressions, collected when we decide to show you an ad on a Digital Property and when we deliver an advertisement.
- Information about your device including device operating system version, connection type, device make, device model, device Identifiers such as your IDFA or AAID, and the IP address from which the device accesses our Services, Platforms and Networks.
- Unique anonymous IDs assigned to your browser or device, which allows the Platform to automatically recognize your browser or device the next time it visits another Digital Property that has integrated our technology. This allows our clients and partners to sync their own unique identifiers against this ID so that they can use their own data on the Services, Platforms and Networks that they may have associated with you (collectively “Digital Identifiers”).
- General geolocation information, as well as precise geolocation information when location services have been enabled for an app on your device that has integrated our technology or that sends that information to our Services, Platforms and Networks.
- Information about your online activity such as website visited, general browsing history, viewing history, referral source, search history and information regarding an individual’s interaction with an internet website, app, or advertisement, including the time web pages or apps were visited or used, including in-game or online viewing activity (e.g., videos viewed, pages viewed).
- Inferences or audience segmentation derived from our Services, Platforms and Networks, such as individual profiles, preferences, characteristics, and behaviors.
- Information about ads served, viewed or clicked on, including the type of ad, where the ad was served, whether you clicked on it and whether you visited the advertiser’s website or downloaded the advertiser’s app.
- Information about the specific content viewed on websites
- Email addresses in hashed form
- Information about your internet service including information about which internet service provider is used by you.
- To receive more information about these practices and/or opt-out of these types of data collection you may visit the following links:
- To opt-out of interest based advertising using cookies:
- To opt-out of email based identifiers go here:
- To turn off personalized ads in Chrome go here:
- To opt-out of Google Analytics go here:
Mobile device system software such as Apple iOS or Google Play Services provide mechanisms that allow users to opt out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device. For more information, or to opt out using these mechanisms, consult your device settings (“Opt out of Personalized Ads” on Android devices and “Limit Ad Tracking” on iOS devices). When Playwire’s technology encounters “Limit Ad Tracking” signals they are respected. Devices vary in where they include the setting to adjust.
2. HOW PLAYWIRE AND THIRD PARTIES USES THE INFORMATION WE COLLECT.
We use, and allow third parties as set forth herein to use, the information we collect for the following purposes:
- System Administration. Playwire may use Non-Personal Information for the purposes of system administration, assisting in diagnosing problems with Playwire servers, monitoring Playwire’s Services, Platforms and Networks performance and traffic on the Playwire Sites and to gather broad demographic information about Playwire customers.
- For our legitimate business interests to provide services to advertisers, including providing and operating our services which includes:
- Compiling statistics about the advertising transactions occurring through our Platform and conducting research and development for our own internal business purposes, such as analyzing campaign forecasts and conducting machine learning to help our clients improve their sales of ad space and delivery of ads to you
- Analyzing and reporting on campaign and ad performance, such as reporting to advertisers about when and how you have been exposed to ads or clicked on ads, and reporting to Digital Properties information about when and how ads were shown on their Digital Properties and whether they were clicked on
- Investigating, protecting against and deterring malicious activity, fake traffic or fraudulent, unauthorized or illegal activity on the Platform and on the internet.
- For our legitimate business interests to provide services to our customers and publishers, including providing and operating our services.
- Notices to Registered Users. If you have registered for an Account, Playwire may use your Personal Information to send emails regarding your registration, including confirmation to verify the accuracy of any information you have provided. Playwire may also send you emails to verify your identity or to notify you if Playwire believes your use of Playwire Sites violates any applicable agreement for the use of the Playwire Sites.
- Advertising-related purposes:
- Interest-Based Advertising: Using Platform Data to infer what you may be interested in and to serve ads to you based on these inferred interests.
- Frequency Capping: Limiting the number of times you see an ad so you don’t see the same ad or type of ad too many times
- Showing Ads in Sequence: Showing you ads in a particular order to provide a better user experience
- Geo-Targeting: Customizing ads shown to you based on your current or prior location
- Contextual Ads: Showing ads to you based on the content you are viewing
- Ad Measurement: Understanding how users respond to ads (e.g., clicking on the ad)
- Aggregated Statistics: Reporting aggregated statistics regarding, for example, the effectiveness of online advertising campaigns
- Cross-Device Mapping: Enabling Cross-Device Mapping (grouping the devices that are owned by an individual or household) in order to serve or measure advertising on related devices on behalf of our clients.
- For ad campaigns that are intended for child-directed sites, we take measures (including activating all available child-directed tags and settings) to ensure that our service providers have disabled any and all forms of behaviorally-targeted advertising and sensitive ad-content categories, and that the child’s anonymous browsing information is only used for permissible internal support operations in accordance with COPPA (e.g., contextual advertising, ad capping, etc.).
- Promotional Emails. Playwire may use your Personal Information to send you emails periodically listing promotions or events relating to the Playwire Sites or from Playwire’s marketing partners or sponsors. You have the choice to opt-out of receiving such promotional emails by sending an e-mail to firstname.lastname@example.org and/or following the instructions in such correspondence. Once Playwire has processed your opt-out request, Playwire will not send you promotional emails unless you opt back in to receiving such communications.
- Legal Rights and Compliance with Law: We may also disclose Platform Data in the event that we reasonably suspect malicious activity or fake traffic or when we reasonably believe it is required by law, subpoena or other legal process, including to meet security or law enforcement requirements.
- Contact Information. If you contact Playwire by telephone, e-mail or letter, Playwire may keep a record of your contact information and correspondence. If you report a problem with the Playwire Sites, Playwire may collect this information in a file specific to you. You may contact Playwire at email@example.com to request the removal of this information from Playwire’s database.
3. HOW TO ACCESS AND CHANGE YOUR PERSONAL INFORMATION
Upon request, Playwire shall allow Users to update or correct Personal Information previously submitted, but only to the extent such activities will not compromise privacy or security interests. Additionally, upon request, Playwire shall delete Personal Information from the database where such information is stored; however, it may be impossible to entirely delete a User’s entry without some residual information being retained due to the manner in which data backups are maintained. Requests to delete Personal Information shall be submitted to firstname.lastname@example.org.
4. SAFEGUARDING YOUR PERSONAL INFORMATION
- Security Measures. Playwire takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of Personal Information. These include, but are not limited to, internal reviews of: (i) Playwire’s data collection; (ii) storage and processing practices; (ii) electronic security measures; and (iv) physical security measures to guard against unauthorized access to systems where Playwire stores Personal Information. All Playwire employees, contractors and agents who access Personal Information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of Personal Information.
- Third-Party Links. The Playwire Sites may contain links to third parties who may collect Personal Information and Non-Personal Information directly from you. Additionally, Playwire may use third parties to provide components of the Playwire Sites. In either case, such third parties may have separate privacy policies and data collection practices, independent of Playwire. Playwire: (i) has no responsibility or liability for these independent policies or actions; (ii) is not responsible for the privacy practices or the content of such websites; and (iii) does not make any warranties or representations about the contents, products or services offered on such websites or the security of any information you provide to them.
5. Your Choices and Rights
If you reside or are located in certain jurisdictions, you may have rights and protections regarding the collection, processing, sharing, and use of your data under a particular jurisdiction’s law. This may mean that you may have the right to:
- Request access and obtain a copy of your data;
- To request rectification of your data;
- In certain circumstances, and subject to some specific legal reasons where we may need to retain data, to request that your data be deleted or erased
- To opt out of the sale of your data to third parties;
- If applicable, to enforce your right to data portability;
- To object to the processing of your data in certain circumstances;
- Not be discriminated against for exercising your rights with respect to your data.
6. CALIFORNIA CONSUMER PRIVACY ACT (CCPA)
The California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.) applies to the collection, use, and disclosure of “personal information” collected from California residents (as those terms are defined by the CCPA). CCPA Personal Information (CCPA PI) is defined by California law as information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households. The CCPA requires us to disclose to California consumers the categories of personal information (as defined in the CCPA) we collect, our business and commercial purposes for collecting, using, or selling such personal information, the categories of sources from which we collect personal information, the categories of personal information we have disclosed or sold for a business or commercial purpose in the preceding 12 months, and the categories third parties with whom we share personal information. We have provided these disclosures below.
If you are a California consumer as defined by the CCPA, you may have the right to: (i) request access to your personal information and request additional details about our information practices, (ii) request deletion of your personal information, (iii) opt out of the “sale” of your personal information (as that term is defined by the CCPA), and (iv) to not be discriminated against for exercising any of your rights under the CCPA. Your options regarding the personal information we collect or receive about you are described below.
Please note that if you wish to exercise any of your rights with any of Playwire’s clients, you must make your request directly to those Playwire clients, based on information and procedures that they supply. Playwire clients own the Platform Data that they maintain in the Platform. Playwire does not control how those clients use Platform Data.
7. SPECIAL NOTE REGARDING CHILDREN UNDER 13 YEARS OF AGE
- Use of the Playwire Sites is not intended for minors under the age of 18 (“Minors”). Minors are not authorized by Playwire to use playwire.com, even if Minors set up an Account or accept the terms of any agreement for Playwire Sites. Parents or guardians may authorize Minors between the ages of 13 and 17 to use the Playwire Sites, provided they assume all responsibility and legal liability for the conduct of such Minor including, without limitation, monitoring the Minor’s access and use of the Playwire Sites. Note that Playwire does work with Publishers who have their own sites that are intended for Minors and have their own separate privacy policies.
- Playwire does not intentionally collect nor maintain any personally identifiable information from Minors. If you discover your Minor child has submitted his/her information to Playwire, you may request to have such information deleted from Playwire’s database by sending an email request to email@example.com together with the e-mail address that was submitted by the Minor. Upon receiving the request, Playwire shall delete such information within twenty (20) business days. If Playwire learns that a Minor is using the Playwire Sites, Playwire will require verified parental or guardian consent, in accordance with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). To learn more about COPPA, consult this simple one-page informational guide from the kidSAFE Seal Program: //www.kidsafeseal.com/knowaboutcoppa.html
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