GENERAL

Kochava Inc. (“Kochava”) respects the privacy of its online users and is therefore committed to protecting any information that you may provide to us. The following Kochava Privacy Policy (“Privacy Policy”) relates solely to our Kochava Platform and users of the website www.kochava.com. In particular, we believe it is important for users to know how we treat information that we may receive, gather, or collect in connection with clients utilizing the Kochava Platform and by visiting www.kochava.com. It is also intended to explain the conditions under which Kochava uses and discloses that information, and your rights in relation to that information.


We Self-Certify Compliance With:

Safe Harbor

Kochava complies with the U.S. – E.U. Safe Harbor framework and the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Kochava has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Kochava’s certification, please visit: http://www.export.gov/safeharbor/. The EU Safe Harbor program is due to be superseded by the EU Privacy Shield later this year. Until such time any data collected will be in compliance with Safe Harbor.




Definitions

Advertiser: An Advertiser is any person or company that promotes their product or a component of their product using the Kochava Platform. For example, Advertisers may promote their mobile application, a specific promotion within their app, an app update, event, or a company announcement, and use the Kochava Platform to attribute these events.

Attribution: Attribution is a general term used to describe the process user interactions within apps and around the advertising ecosystem are measured. For example, a user may click on an advertisement, download an app, and make an in-app purchase – each of these actions would be considered an Attribution within the Kochava Platform.

Geographic Location Data: Advertiser clients may collect Geographic Location Data from an IP address through the Platform to give them deeper insight into the performance of their advertising campaigns. Geographic Location data is non precise geographic data that determines location from IP address, GPS coordinates and/or Wi-Fi networks.

Kochava Platform: The Kochava Platform is a back-end technology that provides unique attribution matching using advertising identifiers and/or statistical identifiers to measure the performance of a mobile ad campaign.

Kochava Platform SDK: The Kochava Platform SDK is computer code inserted into a Developer’s mobile app to enable the Developer to collect Unique Advertising Identifiers and Statistical Identifiers from the user for the purpose of measuring performance.

“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person.

Partners: Partners are third parties that Advertiser clients work with to promote applications, networks, offers, and/or advertisements, including but not limited to: ad networks, publishers, advertisers, affiliates, analytics providers, and data providers.

“Personally-Identifying Information,” is information such as a name or email address that, without more, can be directly associated with a specific person.

Postbacks: Postbacks are server-to-server communications that allow parties to share information.

Statistical Identifiers: Statistical Identifiers are used to provide attribution when Unique Advertising Identifiers are unavailable. Statistical Identification involves the collection of publicly-available HTTP headers from the end user’s device. The Kochava Platform uses the HTTP headers to probabilistically determine which device is responsible for the Attribution and collects the following data points: country code, device brand, device model, device carrier, IP address, language preference, operating system name, operating system version, user agent (browser type), and timestamp.

Unique Advertising Identifiers: Unique Advertising Identifiers are user-specific, unique character strings for advertising that can be reset by the user. Examples of Unique Advertising Identifiers include IDFA (developed by Apple for the iPhone), Google Ad ID (developed by Google for Android), and Windows advertising ID (developed by Microsoft for the Windows Phone).




Information Collected From Visitors To Our Website

As a visitor to our site, you can browse our pages without having any personally identifiable information revealed about you. Information we automatically collect via industry standard web log files and other tools includes the URL from which you visited, the page you are visiting, your computer browser information and your IP address. We collect this data on behalf of our customers who hire us to provide services for them. We may share this non-personally identifying information with our customers who hire us to provide services for them. We do not sell raw non-personally identifying information, but we provide it to enable use of the data pursuant to an agreement with our customers. Our customers own and control the data.

Web Cookies A “Web Cookie” is a string of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the site. Kochava uses Web Cookies to track the pages that users visit during each Website session, both to help us improve users’ experiences and to help us understand how the Website is being used. As with other Non-Personally-Identifying Information gathered from users of the Website, Kochava analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Kochava, its partners and others better understand how the Website is being used. Kochava does not attempt to link information gathered using Web Cookies to Personally-Identifying Information. KOCHAVA USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Web Beacons A “Web Beacon” is an object that is embedded in a web page that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page. Kochava may use Web Beacons on the Website to count users who have visited particular pages and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Kochava may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides. As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. There are portions of our web site, www.kochava.com where we may need to collect Personal-Identifying Information from you for a specific purpose, such as to provide you with certain information you request. The information collected from you may include your name, address, telephone, fax number, e-mail address, and other personal information. Users of the Kochava.com are under no obligation to provide Kochava with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features. BY REGISTERING WITH THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “PRIVACY POLICY”.




Links To Other Sites

Kochava’s web site may contain links to other sites such as distributors and sales affiliates. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites. Kochava neither owns nor controls the third-party websites accessible through the Website. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third-party, whether by means of a link on the Website or otherwise, and before providing any Personally-Identifying Information to any third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in those users’ discretion, protect their privacy.


Information Of Minors


This web site is not intended for persons under 13 years of age. We do not knowingly solicit or collect Personally-Identifying Information from or about children, and we do not knowingly market our products or services to children.

USe and Disclosure of Information By Kochava Kochava gathers information on behalf of our customers for the purposes of:

  • providing you and our customers with custom information about our service offerings that support your business needs;
  • matching you and our customers with compatible participants in our partner program in the event that we are unable to support your business needs ourselves; and
  • reviewing your application for employment if you are seeking work.

We recognize that your information is sensitive and restrict our collection of it to the critical data needed to deliver these services. If you use the forms on our Site, you may receive emails from us to facilitate your inquiry. You cannot opt out of emails that are necessary to provide our services. Your use of our forms and acceptance of our Terms and Conditions include agreement that we and our partners may use your Personally-Indentifying Information to contact you and deliver information to you. We may share the Personally-Identifying Information you provide with other companies we have hired to provide services for us, and those who hire us to provide services for them. These companies – our vendors and customers – are contractually bound to use Personally-Identifying Information we share with them only to perform the services we have hired them to provide, or that we are hired to provide, and they are prohibited from disclosing the information to anyone else or using it for any other purpose. We do not sell raw personally identifying information, but we provide it to enable use of the data pursuant to an agreement with our customers. Our customers own and control the data. We may also share the Personally-Identifying Information you provide with compatible participants in our partner program in the event that we are unable to meet your business needs ourselves.


Information Collected By Clients Utilizing The Kochava Platform


Non-Personally-Identifying Information


The Kochava Platform is designed to collect and use data such as Unique Advertising Identifiers, Statistical Identifiers, Geographic Location Data and other data provided by the Advertiser for attribution. When an end user clicks on an advertisement, installs an app, or takes an action inside of an app, The Kochava Platform uses our SDK and redirect links to collect information, such as a Unique Advertising Identifier, to perform attribution. The Platform also enables clients to view and measure information provided by KOCHAVA, Advertisers, and the Advertiser’s other partnerships. Advertiser clients and Partners may also send information to The Kochava Platform via Postback. The Kochava Platform does not collect names, addresses, phone numbers, or financial information (like credit cards or banking information) from end users.


Personally-Identifying-Information


All data collected by The Kochava Platform is anonymous and no personally identifiable information is collected through our platform. We recognize, however, that in some contexts, IP Address may be considered personal data under the EU’s 1995 Data Protection Directive. As a precaution, we have signed onto the US-EU and US-Swiss Safe Harbor Frameworks due to the possibility that the European Data Protection Authority might deem some of the information we collect to be personal data. Advertiser clients own the data that they provide to and collect through The Kochava Platform, including end user data. When clients remove or export their data from The Kochava Platform, their use of data is governed by their own privacy policies and applicable laws, rules, or regulations. As part of The Kochava Platform customers are permitted to extract and submit electronic data and information to Kochava’s servers. In this context, Kochava acts as a data processor and does not determine how its customers’ data is utilized in Kochavas’s servers. Kochava does not choose or determine the types of data that are submitted to Kochava’s servers through The Kochava Platform, and any access to or use of such data by Kochava is incidental to completing the contractual obligations of Kochava, as data processor, to its customers. As part of Kochava’s professional services operations, Kochava processes data and information, potentially including personal data, on behalf of its customers. In this context, Kochava acts as a data processor on behalf of its customers. As part of Kochava’s internal operations, Kochava transfers data of its customers and current and prospective business partners to Kochava’s U.S. data centers for processing and storage.


For What Purposes Can Clients Use Data Collected Through The Kochava Platform?


Advertiser clients use information collected from end users on The Kochava Platform to view reports and data related to their advertising campaigns. The Platform also allows clients to view and utilize the information they collect to optimize their ad campaigns. Advertiser clients may also use The Kochava Platform to share their data with Partners—including measurement partners, ad networks, and publishers—via Postback, data exports, and/or API calls. Advertiser clients may use the information they collect on The Kochava Platform for the following purposes. Including but not limited to:


  • Measuring the performance of ad campaigns (for example, by comparing the lifetime value of a user against the expenses required to obtain that user).
  • Measuring the value of particular end users.
  • Measuring the performance of various Partners, including ad networks and publishers.
  • Creating customized performance reports (for example, how well a particular advertisement is performing in a particular geographic region).
  • Determining when end users respond to ads.

Device attribution. For more details on how The Kochava Platform measures device attribution, click here.


What Data Does Kochava Collect From Clients?


Signing up for the Kochava Platform as a client requires the submission of your full name, mailing and/or billing address, email address, company name, and website URL. This information is not collected from end users except in rare circumstances when an Advertiser asks The Kochava Platform to collect email addresses on their behalf. We use this information to service your accounts and respond to inquiries. We hold all such information in strict confidence.


Security Of Information Collected By Clients & Kochava


We maintain strict physical, electronic, and administrative safeguards to protect your Personally-Identifying Information from unauthorized or inappropriate access. We restrict access to information about you to those Kochava workers and our customers who need to know the information to respond to your inquiry or request. Workers who misuse Personally-Identifying Information are subject to disciplinary action.


Access To Collected Information & Opt Out Provisions


You may review and update the information that you provide to us through this web site by contacting us as described below. Any information collected by clients utilizing The Kochava Platform is owned and controlled by the individual client. Opting out of The Kochava Platform will not stop end users from receiving interest-based advertisements from our clients or other publishers or ad networks. Users who want to opt out of a particular ad network, publisher, or advertiser’s ads must contact those companies directly to opt out. Kochava’s system, The Kochava Platform, allow its customers an option allow you to choose not to enter any personally-identifying information into Kochava’s systems. You can inquire from these customers as to this option, and your rights and obligations in this regard flow from your relationships with those customers.


Length Of Time Information Is Stored


KOCHAVA allows advertiser clients to choose how long data is stored in The Kochava Platform. Clients are able to create and manage custom data-retention policies that dictate when data is removed from The Kochava Platform (e.g. after 180 days). When the client does not select a custom data-retention policy, KOCHAVA uses industry standard data-retention policies.

Third Party Disclosure
Except as stated above, we do not share, sell, or lease Personally-Identifying Information about you to any third-parties. Kochava contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing Personally-Identifying Information received from Kochava, other than in accordance with this Privacy Policy. Third parties are under no obligation to comply with this Privacy Policy, with respect to Personally-Identifying Information that users provide directly to those third parties or that those third parties collect for themselves. KOCHAVA may share aggregated data derived from The Kochava Platform, including, for example, statistics about Platform activity. It is possible that our business may be merged with or sold to another business entity. During such a transaction, business information is typically one of the assets shared in the combined entity. In the event that this occurs, your Personally-Identifying Information will be protected by the Kochava privacy policy in effect at the time. As a good corporate citizen, Kochava is interested in protecting the community at large. We will release Personally-Identifying Information to legal authorities when we believe it is appropriate to comply with the law. In addition, Kochava may choose to release information about you to relevant parties in relation to investigations of fraud, piracy or other unlawful activity.


Dispute Resolution


In case of a dispute that we cannot resolve PrivacyTrust, an independent third party dispute resolution service, will work with us to ensure that your query is resolved.


Contacting Us


If you have any questions about this privacy policy, please use the Contact Us page. We welcome your questions and suggestions about our privacy policy. You may send us a message at privacy@Kochava.com Kochava 414 Church Street Suite 306 Sandpoint, Idaho 83864


Changes To This Policy


Please check this privacy policy periodically to inform yourself of any changes. We reserve the right to modify or supplement this privacy policy at any time. The current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the end of this document) and review any changes since the last time you used the site.

This policy is effective as of and was last updated on April 15, 2015.




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