Aarki Advertising Privacy Policy

1. ABOUT AS AND OUR SERVICES

Aarki LLC ("Aarki", "we", "our" or "us") works with mobile application developers, brands, and advertising agencies (our "Customers") to deliver advertising to users of mobile apps. We do this through a media buying and optimisation platform and service that we make available to our Customers (our "Service").

2. WHAT THIS POLICY COVERS

2.1
We are committed to protecting and respecting the privacy of mobile app users that receive Customers' targeted advertising through our Service ("End Users" or "you"). This Advertising Privacy Policy sets out how we collect, store, transfer, share and use data that identifies or is associated with End Users (their "personal information").
2.2
When we collect information about End Users we do so both on the instructions of the relevant Customer, in order to provide them with the Service, and for our own purposes. For instance, we use information about End Users to test, optimise and improve our Service.
2.3
This Advertising Privacy Policy sets out how we use End Users' personal information for our own purposes.
2.4
Please note that the Customer and the mobile app provider that supplied your data to us will also use your personal information in ways that are not described in this Advertising Privacy Policy. You should ensure that you also read the Customer's and mobile app provider's privacy notice or policy to understand how your personal information may be used by the relevant Customer or mobile app provider.
2.5
If you have any general questions about this Advertising Privacy Policy or how we use your personal information, please contact us at privacy@aarki.com.
2.6
This Advertising Privacy Policy was last modified on April 10, 2022.

3. WHO IS RESPONSIBLE FOR THE USE OF YOUR PERSONAL INFORMATION

3.1
When we use your personal information for our own purposes, as described in this Advertising Privacy Policy, Aarki determines and is responsible for those uses of your personal information. This means that, if you are in the EEA or UK, we will be the controller of your personal information when we use it in these instances.
3.2
Our Customer will determine and is responsible for how we use your personal information when we do so on their instructions when providing them with the Service, meaning that they will be the controller of your personal information in those instances.

4. OPTING OUT OF ADVERTISING

4.1
The information we receive about End Users is generally collected through third party SDKs and similar technologies embedded in mobile applications. If you would like to opt out of the collection of this information, you can do so as follows:
(a)
For iOS devices, you can enable the "Limit Ad Tracking" setting. For iOS 7.0 or higher this setting is located in Settings -> Privacy -> Advertising menu.
(b)
For Android devices, you can "Opt out of Ads Personalization". To opt out or to find your advertising identifier, please go to Settings -> Accounts -> Ads.
4.2
If you would like to opt out of targeted advertising from Aarki, please enter your device advertising identifier below and click "opt out". Please note that you may still be served general, non-targeted advertising from Aarki, but we will not process your personal information to do so.
4.3
You can also opt-out of receiving some interest-based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices. You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
4.4
Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or through our Service. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s principles.
4.5
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/.

5. INFORMATION WE COLLECT ABOUT END USERS

Bidstream information

5.1
We collect the following information about End Users:
(a)
Advertising identifiers associated with the End User's device, such as Android GAID and iOS IDFA
(b)
Unique agent string used to identify the End User's browser and device type
(c)
Information about the End User's device, including IP address, location, time zone, language of the End User's system, device type (such as brand, model and operating system);
(d)
Interaction with adverts served through the Service, such as views and clicks; and
(e)
Demographic data, such as approximate age, income, household size and family status.
5.2
We receive this information from the advertising service provider responsible for identifying and providing the advert to the End User, together with any other information relating to the category of user and audience segment the End User fits into.
5.3
We use most of the personal information we collect about End Users to provide the Service to the Customer, specifically to identify End Users' interests and activity in mobile applications to determine what advertising we think may be most relevant to them and serve them the most relevant advertising on behalf of our Customers.
5.4
We do also, however, use this information to improve our Service by training our predictive modelling, and to verify the effectiveness of the advertising campaigns managed through our Service. If you are in the EEA or UK, the lawful basis we rely on for processing this personal information is that you have given us, through the relevant mobile app provider, your consent to do so.

Downloads and purchases

5.5
In addition, if an End User downloads and uses one of our Customers' applications in connection with an advert provided to them through our Service, we collect the following information about that End User:
(a)
Advertising identifiers associated with the End User's device, such as Android GAID and iOS IDFA
(b)
Information about how the End User uses our Customer's application, such as when they download the application and any purchases they make through the application.
5.6
We primarily collect this information on behalf of the relevant Customer to enable them to assess and track the effectiveness of their mobile advertising campaigns.
5.7
We do also, however, use this information to measure and improve the effectiveness of our Service. If you are in the EEA or UK, the lawful basis we rely on for processing this personal information is that you have given us, through the relevant mobile app provider, your consent to do so.

6. RECIPIENTS OF YOUR PERSONAL INFORMATION

6.1
We may share the personal information we collect and use for our own purposes with the following:
(a)
Companies owned by or under common ownership with Aarki, including our subsidiaries (i.e., any organisation we own or control) and our ultimate holding company (i.e., any organisation that owns or controls us) and any subsidiaries it owns. These companies may use your personal information in the same way as described under this Advertising Privacy Policy.
(b)
Service providers and advisors. We may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.
(c)
Purchasers and third parties in connection with a business transaction. Your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
(d)
Law enforcement, regulators and other parties for legal reasons. We may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Aarki, its users or others.
6.2
We may also share your personal information with other recipients on the instructions of our Customers. Please refer to the relevant Customer's privacy notice for further information about how the Customer may share (or may instruct us to share) your personal information.

7. HOW LONG WE STORE YOUR PERSONAL INFORMATION

We retain personal information about you for as long as necessary for the purposes set out in this Advertising Privacy Policy and in any event no longer than thirty-six (36) months, unless we are required to retain the personal information for longer under applicable law, to resolve disputes or to protect our legal rights.

8. TRANSFERS OF YOUR PERSONAL INFORMATION

8.1
We may transfer personal information to our service providers and partners as described above in section 6. This may mean that your personal information may be transferred to and stored in countries outside the UK or EEA where we and our third-party service providers have operations, including the United States.
8.2
These international transfers of your personal information will be made pursuant to appropriate safeguards, including:
(a)
ensuring that recipients or the country in which they are located are deemed by the European Commission or under law applicable in the UK to provide adequate protection for personal information.
(b)
ensuring that transfers are subject to standard contractual clauses approved by the European Commission or the UK Information Commissioner for the transfer of personal information.
8.3
We will take appropriate steps to ensure that your personal information is treated securely and in accordance with applicable law and this Advertising Privacy Policy regardless of where it is processed.
8.4
If you wish to enquire further about the safeguards we use, please contact us using the details set out at the top of this Advertising Privacy Policy.

9. CALIFORNIA PRIVACY RIGHTS

9.1
For the purposes of the California Consumer Privacy Act ("CCPA"), we act as a "service provider" in relation to the personal information we process on behalf of our Customers in the performance of the Service. We process, retain, use, and disclose personal information only as necessary to provide the Service. In other words, we use your personal information strictly for business purposes (as defined by the CCPA).
9.2
We enter into data processing agreements with our Customers which set out our obligations under the CCPA, which includes forwarding our Customers any End User individual rights requests and providing reasonable and timely assistance to our Customers in complying with our Customer’s obligations with respect to consumer access and deletion requests under the CCPA.
9.3
If we are able to identify your personal information we will forward any request from you to exercise your rights under the CCPA to the relevant Customer, and the decision about how to respond to it will ultimately be made by that Customer and actioned by us on their instructions.

10. EEA AND UK PRIVACY RIGHTS

10.1
In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
(a)
Right of access. You have the right to obtain:
(i)
confirmation of whether, and where, we are processing your personal information.
(ii)
information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods.
(iii)
information about the categories of recipients with whom we may share your personal information.
(iv)
a copy of the personal information we hold about you.
(b)
Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
(c)
Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
(d)
Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
(e)
Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
10.2
You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case.
10.3
If you wish to exercise one of these rights, please contact us using at privacy@aarki.com.
10.4
Please note that, in order to exercise your rights with respect to any personal information that we hold about you, in order to verify such a request, you will need to provide your Mobile Advertising Identifier.
10.5
If you reside in the UK, you have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK regulator for data protection issues. You can make a complaint via the ICO's website (https://ico.org.uk/make-a-complaint/). This website also provides additional contact details for the ICO.
10.6
If you are resident in the EEA, you have the right to make a complaint at any time to the regulator in your jurisdiction. To find out how to contact your local regulator, please visit https://edpb.europa.eu/about-edpb/about-edpb/members_en.

11. NEVADA RIGHTS

11.1
If you are resident in the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@aarki.com.
11.2
Please note that, in order to exercise the above rights, in order to verify such a request, you will need to provide your Mobile Advertising Identifier.

12. SECURITY

We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. Unfortunately, however, no security measures will always be completely effective. We will notify you in accordance with applicable laws if we become aware that your personal information has been compromised.

13. OUR POLICY TOWARDS CHILDREN

Our Service is not directed at persons under 16 and we do not knowingly collect personal information from or about children. If you become aware that we have collected information about your child without your consent, then please contact us using the details below so that we can take steps to remove such information.

14. CHANGES TO THIS POLICY

We may update this Advertising Privacy Policy from time to time and so you should review this page periodically. When we change this Advertising Privacy Policy in a material way, we will update the "last modified" date in section 2 of this Advertising Privacy Policy. Changes to this Advertising Privacy Policy are effective when they are posted on this page.