Display.io Privacy Policy

 

Display.io Ltd. (together with its subsidiaries, affiliates, employees, officers and directors, as applicable – collectively “Company” “Display.io” or “we” or “us” or “our“) is a global mobile ad-tech company that provides its mobile application developers, advertisers and publishers (“Business Partners”) with an advertising platform for the purpose of delivering targeted and personalized advertising to individuals (“User(s)”) who download, use or otherwise interact with an app developers’ app or our Services, as defined below (hereinafter the “Business Partners” and “User(s)” shall be collectively defined as “you” or “yours”) (collectively, “Service(s)“). Display.io respects your right to privacy all as detailed in this Privacy Policy (“Privacy Policy”). Your ability to make informed choices about our use of your information is important to us. This Privacy Policy details how and what information we collect, process, transfer, and store, when you visit our Site  (available at: www.display.io) and/or use our Services, as well as your ability to control certain uses of the collected information. For more detail regarding the terms and conditions for use of the Site, please read our Terms of Use Agreement (“Agreement”), a current copy of which is available at http://www.display.io/termsofuse/. Words that are capitalized but not defined in this privacy policy have the meaning set forth in the Agreement. Without derogating from the foregoing, “You” or “Your” means any user of the Site or Services, including Users where applicable, using an app which integrated the Services.

You are not required by law to provide us with any information. You can always refuse to supply Personal Information; however, you acknowledge that such refusal may prevent you from engaging in certain activities on the Site or Services.


ACCEPTANCE OF THE TERMS: BY USING AN BUSINESS PARTNER’S APP OR THE DISPLAY.IO SERVICES, AS APPLICABLE, YOU HEREBY AGREE TO THE TERMS OF THIS PRIVACY POLICY AND TO THE COLLECTION AND USE OF CERTAIN INFORMATION, AS DESCRIBED IN THIS POLICY. ANY USE OR CONTINUED USE OF THE BUSINESS PARTNER’S APP OR DISPLAY.IO’S SERVICES CONSTITUTES YOUR AGREEMENT AND CONSENT TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, PLEASE DO NOT ACCESS, DOWNLOAD THE APP OR USE THE SERVICES.


 

Types of Information We Collect

The first type of information is non-identifiable information which may be made available or gathered through your use of the app or the Services, to clarify, we are not aware of your identity (“Non-Personal Information”).

The Non-Personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including: (i) certain software and hardware information (i.e., operating system, type of device, internet service provider, etc.); and (ii) approximate geo-location.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information includes either (i) contact information such as your name, email address and company information which you submitted voluntarily; or (ii) certain identifiers such your IP addresses or Android ID or Advertising ID, IDFA or user agent (“Identifiers”).

Note that the Identifiers are considered “Personal Information” in many jurisdictions (such as the EEA), thus, Display.io treats Identifiers as such and complies with applicable laws.

Please note that we may collect different categories of Personal and Non-Personal information from you depending on the nature of your interaction with the Services, in the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

Information We Collect from Business Partners

If you are a Business Partner, we may collect the following:

  • Registration: In order to use certain aspects of the Site and Services you may be required to register. During the registration flow you may provide us with certain information for the purpose of creating a Display.io account. We require basic contact information such as: full name, email address and company name. Further, during the registration process the Business Partner will be required to create a password, at which time you thereby represent and warrant that you are responsible for maintaining the confidentiality of your details and password. You represent and warrant that you will not provide inaccurate, misleading or false information to Display.io.
  • Newsletter Subscription: If you voluntarily subscribe to our newsletter you will be asked to provide us with your email address, you can unsubscribe at any time using the unsubscribe option within the body of the newsletter.
  • Technical: we also collect certain technical non-Personal Information which relates to your use of the Site, including your account, the amount of time you spent viewing certain portions of the Site etc.

Information we Collect from Users

The Display.io’s software development kit (“SDK”), which is integrated into a Business Partner’s app, is a piece of software that allows our Business Partners to provide Users with personalized content, including advertisements. By downloading and using the app, Users grant the Business Partner with permission to collect the below listed information and share it with Display.io pursuant to the acceptance of the Business Partner’s privacy policy. Display.io collects the information set forth below for the purpose of creating a user profile. This information includes Personal and Non-Personal Information as defined above, all as follows:

  • Type of operating system; Type of browser;
  • Language preference;
  • Access time and date;
  • ISP;
  • Wi-Fi Usage;
  • User’s Click Stream; User’s Action;
  • Search Queries;
  • Precise geo-location;
  • List of installed apps on the user’s device;

We may also collect and store User information stored locally on the User’s device using mechanisms such as local storage identifiers, which in no way damage your system or files.

How We Use Information

General

Display.io may use the information we collect from and about you for any of the following purposes: (1) the legitimate interest of providing, operating, managing, enhancing and improving the Services; (2) to respond to your inquiries or requests, and contact and communicate with you; (3) to provide Users with customized content, targeted offers, and/or advertising and limit the number of advertisements displayed; (4) to contact you with informational newsletters and promotional materials relating to our Site and Services; (5) to review the usage and operations of our Site and Services; (6) to use data in an aggregated, non-specific format for analytical purposes (as detailed below); and (7) to prevent fraud, protect the security of third parties as well as our Site and Services, and address any problems with the Site and/or Services.

Statistical Information

By analyzing all information, we receive, including all information concerning users, we may compile statistical information across a variety of platforms and users (“Statistical Information”). Statistical Information helps us understand trends and customer-needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Information. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion. We may provide certain information that we receive to Google Analytics, or other such Tools (as more fully detailed and defined below) in order to receive an analysis of the use of our Site and Services.

Analytics

We, or our service providers or subcontractors, may use analytics tools (“Tools“), including “Google Analytics” to collect information about the use of the Site and/or Services. Such Tools collect information such as how often users visit the Site, what pages they visit when they do so, and what other sites and applications they used prior to coming to this Site. We use the information we get from the Tools to improve our Site and Services.

To learn more about how Google uses data from our use of Google Analytics Cookies, we recommend you review Google’s policies located at: www.google.com/policies/privacy/partners. We also encourage you to review the Google Analytics’ currently available opt-outs for the web tool available at:  https://tools.google.com/dlpage/gaoptout/

 

How We Collect Information

Depending on the nature of your interaction with the Services, Display.io may collect information from you automatically or when you voluntarily choose to provide it with information such as through the registration process, all as detailed in this Privacy Policy. We may also collect certain types of information automatically, including through the use of Cookies, User Agents, Hooks, Device Fingerprint, Web Beacons and other similar tracking technologies (as detailed below). Display.io primarily collects information from Users when a Business Partner serves an advertisement to a User through Display.io SDK, as detailed above.

 

Disclosure of Information

We may share your information, including Personal Information, as follows:

Authorized Disclosures

We may disclose your Personal Information to third parties when you consent to a particular disclosure of your Personal Information. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices. In addition, we may share Identifiers, for the purpose of operating our business and providing the Services, as well as to calculate payments and detect fraud, security or technical issues in connection with the Services.

Business Partners, Service Providers, Affiliates, and Subcontractors

We may disclose information, including  Personal Information, we collect from and/or about you to our trusted affiliates, personnel, licensors, contractors, service providers, subcontractors and business partners who may use such information to: (1) help us provide you with the Services; (2) aid in their understanding of how users are using our Site and Services; and (3) provide you with customized content, targeted offers, and advertising on both our Site or through an app which uses our Services .
Display.io may also share non-personal information with our clients or other third parties in accordance with this privacy policy.

 

Business Transfers

We may transfer our databases containing your Personal Information if we sell our business or any part of it. In the event of the aforementioned, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.

Law Enforcement related disclosure

We may be required to share information (including Personal Information) collected with law enforcement agencies or court order requesting or directing us to disclose the identity, behavior or digital content of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Information with third parties if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Agreement and our Privacy Policy), or to protect the rights, property or safety of third parties. You can request such personal data as specified herein by emailing us at contact@display.io.

 

Except as expressly set forth herein, we will not share your Personal Information with third parties without your explicit permission, except when required by law, regulation, subpoena or court order.

Data Retention

We retain this collected information as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

How we Protect Information

Display.io is committed to protect your Personal Information. Thus, Display.io has implemented technical, physical and administrative security measures to protect the Personal Information submitted to and collected by us, both during transmission and once we receive it. In addition, Display.io limits access to your information on its servers, and it is password-protected as well as encrypted. The data collected by the Company is stored in the AWS data servers, for more information regarding the data security provided by AWS, please see: https://aws.amazon.com/security/. For additional information regarding Display.io’s security measures please see: www.display.io/security

How to Access and Limit Our Use of Certain Information

We may send you e-mail or other messages about us or our Services. You can remove your Personal Information from our mailing list and stop receiving communications from us by following the unsubscribe link located at the bottom of each communication or by emailing us at contact@display.io.  In addition, Users of our Site and/or Services, including Users, are given the opportunity to “opt out” of having their Personal Information used for purposes not directly related to the provision of the Services. You may “opt out” at any time, even if you have previously elected to receive direct marketing communications from us.  Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account or to your transactions on the Site or Services, without offering you the opportunity to opt out of receiving them unless you cancel your account.

Even after providing your consent to this Privacy Policy, you are entitled to change your mind. If you do, you may easily opt out of the data collection, sharing process and targeted advertising services related to our Service. Please note that even if you opt-out, you will still receive content and advertising from Displa.io. Opting-out simply means that the advertisements you do receive from us will not be targeted in any way.

Options to opt out:

Mobile Opt-out:

Android-https://support.google.com/ads/answer/2662922  or iOS– https://support.apple.com/en-il/HT205223.

Website Opt-out:

You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.

Please refer to the support page of the browser you are using. In this regard, following are some links which you may find useful:

 

Industry Standards

You may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website- NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website- DAA opt-out page.  If you wish to opt out of interest-based advertising, you may click here. Please note you will continue to receive generic ads.

Business opt-out

Our Business Partners may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the privacy policies for the Apps to learn more about the privacy practices of our Business Partners. Please note, however, that we are not responsible for the privacy practices of our Business Partners, and other third parties.

In the event, that you have any additional complaints about your privacy rights, please initially contact the Data Protection Officer. Please note that you have the right at any time to contact your local data protection authority.

You may also Contact Us at: contact@display.io and we will be happy to assist you. Note that once you opt out, part of the Services provided by us might no longer be available and some features may not work if you revoke the data transfer.

User Rights

You have a right to know what information we hold about you and, in some cases, to have such information communicated to you. You may also ask for our confirmation as to whether or not we process your Personal Information.

Subject to the limitations in applicable law, you may also be entitled to obtain from us the Personal Information you provided to us (excluding information that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Information to another party.

Your principal rights under applicable data protection law in relation to your Personal Information are as follows:

  • the right to access any information which is provided by you;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent (to the extent applicable).

We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Information. Depending on your relationship with us, to exercise your rights contact us at: contact@display.io . We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month in accordance with applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

If you wish to exercise any or all of the above rights, please contact us by email at contact@display.io or contact our Data Protection Officer at: dpo@display.io and let us know that you wish to exercise your right of access and specify what Personal Information you would like to receive. Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this.

 

Cookies

A cookie is a small piece of text that is sent to a visitor’s browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. Display.io uses cookies to help personalize your Display.io experience. A “persistent” cookie may be used to help save your settings and customizations across visits. Also, if you log into Display.io, such a cookie will be used to recognize you as a valid user so you will not need to log in each time you use the Services. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please note that some features of the Site or Services may not function properly when cookies are disabled or removed.

Third Party Sites and Services

Portions of the Site or Services (including, without limitation, advertisements) may involve linking to or using web sites or services belonging to third parties. The Site and/or Services may also provide you with links to access the applications of third party vendors or companies. We have no control over third-party sites or services, and all use of third-party sites or services is at your own risk. We cannot accept responsibility for the privacy policies of any such sites. We are not responsible for content available by means of such sites or services. Display.io does not endorse any products or services offered by third parties and we urge our users to exercise caution in using third-party sites or services.

Changes

This policy may change from time to time and we will post the amended terms on the Site and notify you by email of major changes. Amended terms will take effect immediately for new users, and 10 days after they are posted for existing users. You should review the Privacy Policy periodically to remain informed of any changes. You agree to accept posting of a revised Privacy Policy as actual notice to you.

Your continued use of the Site after any changes to this Privacy Policy have been posted as of the “Last Updated” date below (or, if applicable, notified) signifies your acceptance of those changes. If you do not agree to the revised Privacy Policy, please refrain from using our Services and contact us by sending an email to: contact@display.io.

Children’s Privacy

You represent and warrant that, (i) if you are located in the US, you are at least 13 years of age; or if you are located in any other GEO, you are above the age defined as “child” under applicable laws in your jurisdiction (collectively “Child” or “Children”); and (ii) you are of legal competence to enter into this Privacy Policy. If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. The Services are not directed or intended for Children, as defined under applicable law, and we do not knowingly collect or solicit information from children. If we become aware that a Child under that age has provided us with Personal Information, we take steps to remove such information from our servers. If you are aware that your child has provided us with Personal Information, please contact us at contact@display.io.

Comments and Questions

If you have any comments or questions about our privacy policy, please contact us at

Display.io Ltd.

Ehad Haam 9, Tel Aviv, Israel.

You can also contact us via email at: contact@display.io.

Data Protection Officer

If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: dpo@display.io

Please be sure to include your information in any correspondence to us so that we can respond to your inquiry in a timely manner.

 

Last updated: May 15, 2018