Last Updated: 1st July 2022
AdInMo is an in-game advertising platform which serves click-free immersive brand ads without interrupting game flow. (the “AdInMo Service”).
Important information and who we are
We are AdInMo Ltd. We are a company incorporated and registered in Scotland, United Kingdom, with company number SC648449. Our registered office address is 26 Dublin Street, Edinburgh, EH3 6NN, UK. When we refer to “we”, “us” or ”our” in this policy, we are referring to AdInMo Ltd.
What information we collect
When a user visits a developer mobile application that incorporates our technology, AdInMo and our partners use and deploy tracking technologies to automatically collect certain information about users and their devices.
Some of this information (including mobile advertising IDs) may identify a particular device and may be “personal data” in some jurisdictions, including the EU.
The AdInMo Services are designed to process information in such a manner that the information cannot be directly attributed to a specific, identifiable individual without the use of additional information (such as a name, address or email address).
The information we may collect includes:
- Device information, such as the device type and model, manufacturer, operating system type and version (e.g. iOS or Android), user-agent, carrier name, time zone, network connection type (e.g. Wi-Fi or cellular), IP address, general location inferred from IP address, hardware-based identifiers (e.g. MAC address), information about mobile developer apps and versions currently active on a device (but not any other apps), and identifiers assigned to a device, such as its iOS Identifier for Advertisers (IDFA), Android/Google Advertising ID (AAID or GAID), or other unique device identifier (typically an alphanumeric string allocated to a device by the device manufacturer).
- Information about advertisements served, engaged with or interacted with, such as the type of advertisement, where the advertisement was served, the number of times a user has clicked on the advertisement (if applicable), whether the user visited an advertiser website or relevant app store.
How we share your information
Information that we collect may be disclosed with:
- Developers: If you are a user, we may disclose information collected through our AdInMo Services to mobile application developers to allow them to analyse the effectiveness and performance of our AdInMo Services and to offer targeted advertising inventory to buyers.
- Buyers: If you are a user, we may share information we collect in connection with our with buyers for purposes relevant to our business relationships with them, such as for billing purposes, dispute resolution or fraud prevention and to allow them to make decisions regarding buying advertising inventory and to analyse the effectiveness and performance of their advertising campaigns via the AdInMo Services.
- Analytics Partners: If you are a user, we may share your information (such as your mobile device ID, or other unique identifier) with our attribution and analytics partners to validate and measure the success and effectiveness of advertisements.
- Business transfers: We may share your information with a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or sock (including in connection with any bankruptcy or similar proceedings).
- For legal purposes: We may share your information as we believe to be necessary or appropriate under applicable law, including laws outside your country of residence, to respond to requests from government authorities, including government authorities outside your country of residence and to enforce our terms and conditions.
How we store your information
If you are a mobile application user, we may retain information that we collect through the AdInMo Services for up to 90 days from the last date that we received any user information.
If we are required to retain information to comply with a legal or audit obligation, we may store user information for longer periods.
After the applicable retention period, AdInMo may only retain and use personal information: (i) in an aggregated or anonymised format; (ii) to comply with its legal obligations; (iii) to resolve disputes and enforce agreements.
How we use your information
We use information we collect for a variety of AdInMo business purposes.
We use the information we collect for the following purposes:
- Serving Ads: To allow application developers to offer advertising inventory in their mobile applications and third party buyers to bid on and fill that inventory with advertisements.
- Reporting: To provide information and reports to third party buyers about when and how mobile users have been exposed to their advertisements and/or clicked on their advertisements.
- Frequency Capping: To prevent users from seeing the same advertisement too many times.
- Performance Analytics: To analyse advertising performance, such as tracking engagement with advertisements and click-through rates to websites or app stores and/or installs of apps that have been advertised.
- Location-Based Advertising: To deliver location based advertising services through the use of a user device’s physical location (where permitted by law).
- Fraud Detection: To identify invalid advertisement impressions, interactions or installs.
- As we believe to be necessary or appropriate: Under applicable law, including laws outside a user’s country of residence, including responding to requests from government authorities, including and government authorities outside of a user’s country of residence and to enforce our terms and conditions.
If we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- The country has been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- If we use certain service providers based outside of the EEA, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- If we use providers based in the US, we may transfer information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
If you are resident in the EEA, UK or Switzerland, we will protect your personal information when it is transferred outside of your jurisdiction by (i) processing it in a territory that provides an adequate level of protection for personal information based on the receiving country’s data protection laws; and/or (ii) implementing appropriate safeguards to protect your personal information, such as requiring the recipient to comply with the Standard Contractual Clauses or another lawful and approved transfer mechanism.
We use reasonable organisational, technical, administrative and physical safeguards to protect the personal information we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your information is safe and secure.
We may use tracking technologies (such as pixel tags, IDFA, AAID/GAID, UDID, ETags) to collect information automatically from a mobile device of a user. They help us perform functions such as limiting the same Ad from continuously being served and serving an Ad more relevant to the user.
Both our application developers and media buyers may use information that we share with them to establish connections among related devices for targeted advertising, analytics and reporting purposes.
Our application developers and buyers may use other information about a user’s activity across multiple, unaffiliated third-party mobile applications for targeted advertising, analytics and reporting purposes. For example, if a user uses a sports app, these third parties may display sports related ads to a user on other unrelated apps.
Legal basis for processing your personal information
For users located in the EEA, our legal basis for collecting and using personal information will depend on the personal information concerned and the specific context in which we collect or use it.
We rely on our or our application developer client’s legitimate interests to collect and use your personal information, except where such interests are overridden by your data protection interests or fundamental rights and freedoms.
For the purposes of EU data protection legislation, each mobile application developer is deemed to be the “data controller” of your personal information that may be obtained via your usage of the respective developer mobile application installed on your mobile device.
The AdInMo legitimate interests are described in more detail in the sections above with the heading “How We Use Your Information”. In connection with the AdInMo Services, our legitimate interests include the provision of the AdInMo Services to application developers as required by our respective terms and conditions and agreements in place with them.
In the context of our AdInMo Services We may rely on your consent that we obtain directly from you, or, which is obtained on our behalf by application developers that use our technology or use technology that interacts with the AdInMo Services.
AdInMo complies with the requirements under applicable privacy laws such as Children’s Online Privacy Protection Act (COPPA) and California Consumer Privacy Act (CCPA) in the US and GDPR in EEA and does not knowingly collect personal information about users of apps directed to children.
Your opt-out choices and rights
You can adjust the advertising preferences on your mobile device as follows:
- In iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking.
- In Android, visit Settings > Google > Ads > Opt out of interest-based ads.
To opt out of Interest-Based Advertising in Mobile Apps, our advertising partners may display interest-based advertising to you in mobile applications, based on your use of mobile applications over time and across non-affiliated apps.
To learn more about these practices and how to opt out, visit www.aboutads.info/appchoices and download the DAA’s AppChoices mobile app and follow the instructions provided in the AppChoices mobile app.
Right to object and/or withdraw consent
You have the right to object to processing of your personal information, restrict processing of your personal information, or request portability of your personal information. To exercise these rights please email email@example.com
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Data subject access request
We will respond to your request in accordance with our obligations under applicable privacy laws. Please review our Data Subject Rights Notice for further information and instructions on how to exercise your rights.
Please note that because most of the information we collect can only identify a particular mobile device and cannot directly identify you personally and therefore you may need to provide us with some additional information to enable us to identify the personal information we hold about you and ensure that we accurately fulfil your request and do not infringe on the privacy rights of other individuals.
Deleting your personal information
You have the right to request that we change, update, or delete your personal information at any time. To exercise these rights please email firstname.lastname@example.org
Right to complain to a Data Protection Authority
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
- Contact details for the UK Information Commissioner’s Office is here: Contact us | ICO
- Contact details for EEA Member States are here: Our Members | European Data Protection Board (europa.eu)
This version was last updated on 1st July 2022.
if required by applicable data protection laws.