Tapdaq - Mediation Platform

Privacy Policy

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1. Who are we and what is this Privacy and Cookies Policy about?

Tapdaq Limited ("Tapdaq, us, we, our") is a monetisation platform which connects mobile app publishers ("Publishers") with advertising networks (“Ad Networks”). We also help app Publishers to grow their user base using in- house cross promotion campaigns.

We are a company registered in England, our registered office address is at Third Floor, 29 – 30 Ely Place, London, EC1N 6TD. Our Company Number is 08309095.

We are committed to safeguarding the privacy of our website visitors and service users. Our Privacy Policy tells you how we look after, use and share the Personal Information that we collect from you. Whilst we do not apply a different standard of data protection to our users based on location, some of the rights set out below won’t apply to you if you’re not located in the EU.

We collect different types of Personal Information from Ad Networks, Publishers and users of Apps which have the Tapdaq SDK installed ("User"). Our Privacy Policy may apply in different ways to each type of Personal Information. Please read this policy carefully. In addition, our website uses essential cookies. You can read more about cookies below.

When you use any of our Services or visit our website you are agreeing to our Privacy and Cookies Policy.

2. How do we protect your Personal Information?

We take your privacy seriously and use secure servers to store your Personal Information. We use industry standard organisational and technical security measures to protect your data against unauthorised disclosure, loss, misuse, alteration or processing. However, like everyone else, we cannot guarantee complete security, especially when data is sent over the internet.

Where you are required to choose a password for your account, you are responsible for keeping this password confidential. You must ensure that your password cannot be guessed, either by a person or a computer programme. Limit access to your computer or device and sign off after you have finished accessing your account. If you think that someone has access to your password or unauthorised access to your account, please inform us immediately.

We are not responsible for the misuse of your account or information where you have not kept your password confidential or not reported a breach of security.

3. What information do we collect about you?

We collect Personal Information about you when you visit our website, when you register with us, use our Services, download our Tapdaq SDK, answer our questions or provide feedback. We may also record our communications with you.

If you are a Publisher:

We collect Personal Information that you provide to us when you register and open an account: This includes your full name, email address, company name, company website, username, password, Network account keys, business address, App name and App details and any other information that you supply to us.

The legal basis for our processing is in order to fulfil our contract with you, manage our business relationship, to provide the Services and to assist you in getting the most out of our Services (in other words, our legitimate business interests).

You may choose whether or not to give some information to us. However, if you have not given us some information, you may not be able to enjoy all or parts of the Services offered.

If you are a Publisher, Tapdaq may collect data (some of which may be anonymous personal information) about your Apps including, but not limited to, downloads, performance, user engagement and behaviour, and other performance metrics / data in order to analyse, catalogue, aggregate or otherwise interpret or evaluate such data for the purposes of: (i) displaying the results on our Services to other potential Advertisers, Networks and Publishers; (ii) using the data to ensure that the Tapdaq market functions at optimum market efficiency; ii) producing Advanced Analytics Reports or other services; and (iv) using, in anonymised and aggregate form, such data for quality assurance, training or other purposes.

This legal basis for this processing is for the performance of a contract; or it is in our legitimate business interests.

If you are a User:

Whenever you interact with Apps that use our Services, we automatically record information from your device. This includes your device information (such as UDID, IDFA, device type and settings), IP address, OS and OS version, country, and your in- App user activity ("Device Information"). The user activity information we collect includes the number of times you open an app in a given period and the length of time the app is used at each boot up. We collect this information so that we are able to provide Ad Networks and Publishers with aggregated, anonymous usage reports so they can monitor the effectiveness of our Services.

We also record your device advertising consent flag and we pass this information to Ad Networks so they can respect your wishes in relation to targeted advertising.

We never map any of your device information to other personally identifiable information. So, this means we only ever have anonymised information about you and we have no ability to connect your anonymised information to any other data that could identify who you are. However, Publishers and Ad Networks may collect more Personal Information than we do. You should check the App Publisher’s own privacy policy to get more details.

The legal bases for our processing is either in order to fulfil the contract for our Services that we have with Ad Networks or Publishers or because we have legitimate business interests in monitoring your Service usage so we can make informed, targeted improvements to the Services we offer.

4. How will we use the information about you?

We use the information you give to us to make our Services the best possible experience for you. For instance, we may use your information to:

  • improve our Services;

  • manage our business risks by obtaining insurance or professional advice;

  • meet our legal and regulatory obligations; and

  • carry out research and analysis, training and quality assurance.

The legal basis for this processing is our legitimate business interests.

In addition, for Publishers, we may use your information to:

  • facilitate and optimise the buying and selling of advertisements between Ad Networks and Publishers;

  • customise the Services you choose to receive;

  • manage your account and your queries;

  • contact you with important service and functionality announcements and updates;

  • if you agree, contact you about other Services and products from Tapdaq that we think may be of interest to you

  • if you agree, contact you with advertising from other businesses

Our legal bases for such use is either the performance of a contract we have with you, our legitimate interests in improving our business management and the Services or your consent.

5. In addition, for Users:

Ad Networks and Publishers may also use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one, because Tapdaq does not use any of these methods itself.

Opting Out

If you do not want to receive interest-based ads, you can opt out from having your device data processed by changing your privacy settings. As tracking mechanisms operate at the device level, to fully opt-out across devices, you will need to do so on each device and browser individually.

On iOS, navigate to ‘Settings’, then ‘Privacy’, then ‘Advertising’. On this screen, enable ‘Limit Ad Tracking’.

On Android, navigate to ‘Google Settings’, then ‘Ads’. On this screen, enable ‘Opt-Out of Interest-Based Ads’.

In some cases, the Publisher will ask for your consent in order to show you personalised ads. In these cases, please refer to the Publisher’s privacy policy.

  • If you **do not** opt out: Ad Networks may use your Personal Information to give you a more personalised advertising experience. Please refer to the privacy policy of the App you are viewing for more details.

  • If you **do** opt out: Tapdaq will pass this opt- out on to the Ad Networks so that they will no longer serve you with personalised content recommendations, but you will receive the same number of advertisements.

6. Who will we disclose your Personal Information to?

Tapdaq will not share your Personal Information for marketing purposes with companies outside the Tapdaq group of companies or sell your personal data to anyone.

  • We work with trusted third-party partners to perform tasks on our behalf and we may need to disclose your Personal Information to them to provide services to you. However, these companies are bound by data sharing and confidentiality agreements with us and do not have any independent right to use your Personal Information beyond what is necessary to assist us;

  • We may share aggregated, anonymous usage information in the form of Service reports with our Ad Network partners and Publishers.

  • We may share your aggregated, anonymous usage information with other Service users. For example, we may provide other Publishers with information about what Advertisements may appear on their Apps or vice versa.

  • When the law or regulations to which we are subject require us to disclose your information, we will comply;

  • When we need to enforce our Terms of Service, investigate fraud, reduce credit risk, exercise our legal rights or defend against legal claims;

  • When it is necessary for the protection of your vital interests or the vital interests of another person;

  • If there is a change in the ownership of Tapdaq or any of its assets, we may disclose Personal Information to the new or prospective owner.

7. International Transfers of your Personal Information

We have offices in the United Kingdom, which is subject to the EU’s high standards of data protection and the hosting facilities for our website are situated with the EU.

Some of our service providers are situated in the United States of America. Transfers to the USA will be protected by appropriate safeguards, either: Standard data protection clauses adopted by the European Commission; or

Self-certification of compliance with the Privacy Shield programme designed by the EU and US government to demonstrate a company’s compliance with EU data protection standards.

8. Will I receive marketing information from you?

We do not send direct marketing messages to Users by email, text or telephone.

For Ad Networks and Publishers, we would like to send you marketing information about our Services which may be of interest to you. If you’d rather not receive such messages, you may unsubscribe at any time. Just click on the "unsubscribe" link in our marketing emails.

Please note that this does not apply to non-marketing communications which you cannot unsubscribe from, such as service or functionality announcements. This is because we need to communicate with Advertisers and Publishers in whatever way is necessary to ensure the effective operation of our Services. However, if you really don’t want to receive these emails (and miss out on the benefits of our Services) you can unsubscribe at any time via the footer in each email.

8. What rights do I have to access, change or delete my Personal Information?

Publishers with a Tapdaq account may view or change your Personal Information by going to your "My Profile" tab and viewing the profile information that you have provided.

If you wish to delete your Tapdaq account you may do so by sending an email to us ( www.tapdaq.com/contact ). When you do this, in most cases your account will be deactivated and your Personal Information will be deleted from our database within 90 days. This delay is necessary to discourage users from engaging in unlawful activities.

After your account is deleted, we may retain certain information in order to comply with our legal, financial or regulatory obligations. Other Personal Information will be anonymised (which means you cannot be identified by any of the information). We may use the anonymised data to continually improve our Services, such as innovation through product development, improved navigation and enhanced security systems.

This is a summary of your rights under European Union data protection law. Some of these rights are very complex. You may obtain guidance from your local Data Protection regulator (such as the ICO in the United Kingdom) for a more detailed explanation.

Your RightsWhat are they?What will we do?
AccessTo know whether or not we process your Personal Information and have access to that data.Providing the rights of others are not affected, we will supply you a copy of your Personal Information free of charge. Additional copies may be subject to a reasonable fee.
RectificationYou have the right to have any inaccurate Personal Information about you rectified and have any incomplete Personal Information about you completed.When you communicate with us, we will check the data we have stored and rectify any errors when proof is provided.
ErasureYou have the right to erasure of your personal data when: Personal Information is no longer necessary in relation to the purpose for which it was originally collected. You withdraw consent to consent-based processing. You object to the processing under applicable law. The processing is for direct marketing purposes. The Personal Information has been unlawfully processed.We will erase the Personal Information as requested on validation of the claims, however data cannot be erased if processing is necessary for compliance; for compliance with legal or regulatory obligations or to establish, exercise or defence against legal claims.
Restrict ProcessingYou have the right to restrict processing of your Personal Information in the same circumstances as described under ‘right to erasure’ where you oppose erasure or have objected to processing and the decision is pending.Where processing is restricted, we will continue to store your Personal Information, but will only process it for legal claims, for the protection of another person’s rights or for reasons of public interest.
Object to Processing1. You have the right to object to processing of your Personal Information for direct marketing purposes. 2.You can also object if the processing of your Personal Information is for reason of public interest, or for the legitimate interests pursued by us or a third party, or if we exercise any official authority vested in us.1. If you make an objection we will cease to process your data. 2.If you object, we will cease to process your Personal Information unless we can demonstrate compelling reasons for that processing, which would include establishing, exercising or defending legal claims.
Data PortabilityYou have the right to receive your Personal Information if we have processed it with your consent or as part of performing the contract with you (if carried out by automated means).We will provide your Personal Information to you in a commonly used and machine-readable format. This right does not apply if it adversely affects the right of others.
ComplainYou have the legal right to lodge a complaint to a supervisory authority responsible for your data protection.We will be bound by the decision of the supervisory authority.
Withdraw ConsentYou can withdraw consent at any time from processing for which your consent is our legal ground for processing.Contact us via [email protected] to exercise any of your rights in relation to personal data. Please note that we will always attempt to reply within 14 days but during busy periods, it may take longer.

9. How long do you keep my Personal Information for?

We store your Personal Information for as long as is required for business, legal and regulatory purposes or to protect your vital interests or the vital interests of another natural person. We do not keep personal data for any longer than is necessary.

10. What are cookies? Do you use cookies?

Cookies are small text files that are placed on your device to allow the tracking of advertising, to retarget advertising, to customise content, and to collect standard user behaviour information.

Tapdaq only uses essential cookies on its website.

(So you know, Ad Networks and Publishers may place cookies on a User’s device. Users should check the relevant App Publisher’s privacy policy for more details.)

If you want to use sites without cookies or would like to know more, visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies (we’ve given instructions on how to do this at section 5 above) and the above websites tell you how to remove cookies from your browser. However, in a few cases, some of the features of our Services may not function as a result.

11. Does this Privacy Policy apply to services, apps or websites provided by other companies?

Our Website may contain links to other Apps or websites. This Privacy Policy applies only to how Tapdaq uses your Personal Information. If you disclose your Personal Information to other companies, they are responsible for their use of your information in accordance with their own privacy policies.

12. What about Personal Information of children?

You must be 18 years or over to use the Tapdaq Services. Should we discover that any Personal Information has been collected from an individual under the age of 18, we will promptly delete it.

Our Acceptable Use Policy (as set out in the Terms and Conditions) requires that Publishers and Ad Networks using the Services will not target any advertisements at children under 13 years of age (or otherwise applicable local minimum age if greater) and will not transfer any Personal Information about or relating to an individual under the age of 13 (or otherwise applicable local minimum age if greater) to Tapdaq. If however, you believe that a child under 13 years of age (or otherwise applicable local minimum age if greater) has registered with us or that you have transferred a child’s Personal Information to us, please contact us and we will use our reasonable endeavours to delete such data from our records.

13. Changes to our privacy policy

We review our Privacy Policy regularly and we will update this page. The last date that changes were made is notified below. When we make changes to our Privacy Policy, we may notify you by posting an announcement on our Service or sending you an email. You are bound by any changes to our Privacy Policy when you use our Service after you are notified of these changes.

14. How do I contact you?

Please contact us if you have any questions about information we hold about you or about our Privacy Policy by using the email address: [email protected]

We are registered with the Information Commissioner’s Office with registration number: ZA215530.

15. What do the Capitalised words mean?

"Ad Network" means the following (and more may follow): AdMob; Adcolony, Applovin, Chartboost, Facebook Audience Network, InMobi, ironSource, Tapjoy, Unity Ads, Vungle and YouAppi.

"Advertisement" means advertising content that an Advertiser buys via an Ad Network, who then submits the Advertisement to our Service, which may include text ads, text links, banners, videos and graphics.

"Advertiser" a third-party advertiser who buys advertising inventory via an Ad Network on Publisher App(s) in our network in order to display Advertisements.

"App" or "Apps" means mobile applications which you can download and run on your phone, tablet or other electronic device.

"Personal Information" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Publisher" means a mobile App developer / owner who buys our Services to allow the incorporation of Tapdaq’s SDK into their App to display Advertisements on its App from Ad Networks.

"Service" or "Services" means the products and services provided by Tapdaq, including our Tapdaq SDKs, our ad server, mediation and optimisation services, mobile applications, websites and any other online, offline and/or mobile products and services on or via any platform or technology.

"Tapdaq SDK" means the Tapdaq Software Development Kits that are available for download from our website www.tapdaq.com for use in relation to our Services.

"User" means the user of any App with the Tapdaq SDK installed.

Any words following the terms "including", "include", "in particular", “for example” or any similar expression shall be construed as illustrative and shall not limit the sense of the words, description, definition, phrase or term preceding those terms.

This Privacy Policy was last updated on 22nd November 2018.