PRODUCT PRIVACY POLICY

With this privacy policy we, Verve Group Europe GmbH, Karl-Liebknecht-Str. 32, 10178 Berlin Germany (hereinafter „PubNative“ or “we”) would like to inform you about the processing of personal data when using our mobile advertising optimization technology (“PubNative`s Technology”). PubNative’s Technology is integrated into mobile apps to provide personalized ad experiences. The providers of the respective apps (“Publishers”) are responsible for the integration in the first place. Please therefore also note their individual privacy policies.

To access the privacy policy governing our Website, please click here.

  1. Provider of PubNative’s Technology

PubNative’s Technology is provided by

Verve Group Europe GmbH

Karl-Liebknecht-Str. 32

10178 Berlin Germany

Should you have any questions or suggestions regarding data protection, please do not hesitate to contact us. You are welcome to direct your data protection concerns to our data protection officer by sending an e-mail to [email protected]. Our full contact details are available here.

 

Our Data Protection Officer:

Fieldfisher Tech Rechtsanwaltsgesellschaft mbH

Am Sandtorkai 68

20457 Hamburg, Germany

  1. Personal Data processing in connection with PubNative’s Technology

2.1 Data we receive.

First of all, we do not know who you (as a user) are. PubNative neither processes the names nor the addresses or e-mail addresses or similar information of users. That said, we only process data provided by the Publishers, including user information about the interaction with apps, which is recorded, stored and evaluated using temporary identifiers, which PubNative is unable to decode (so-called pseudonyms). The Publishers determine the purposes and means on how we process users’ data. We have established several technical and legal measures to safeguard that the Publisher’s users have given their consent for our processing.

Data we receive from Publishers differ. We typically receive:

  • mobile identifiers such as the ID for Advertising for iOS (IDFA), Google Advertising ID
  • device information (device model, platform, operating system version, browser details).

However, from time to time the Publishers may also provide data to us, which typically relates to the behavior of users inside the Publisher’s apps and may include:

  • user interactions within an app (e.g. in-app purchases, registration)
  • user information such as age, gender, interests.

2.2  Purposes of data processing.

We process the data received from Publishers on behalf of the Publishers so that they can market ad space for targeted in-app advertising and targeting campaigns. When serving personalized mobile advertising, this gives advertisers the opportunity to target users who are actually interested in their products, offers and content.

Our processing activities include the following:

  • Serving ads to the users
  • Serving ads to the users taking into account their approximate location when permitted by the user’s device
  • Serving ads to the users taking into account their age, gender, keywords or interests when provided by the user in the host mobile app on the user’s device. Race, religion, politics, sex life, or health are unavailable targeting criterions in PubNative’s Technology
  • Aggregating reports for publishers, advertisers and internal systems on how many ad requests PubNative received, how many ads were displayed and clicked
  • Limiting and control number of ads same users see
  • Limiting and control number of ads of particular campaign users see
  • Detecting fraud by running models to identify invalid events (requests, impressions, clicks)
  • Analyzing internally aggregated reports in order to improve PubNative product offerings.

We are unable to combine the data we receive in a way that would enable us to personally identify users and we do not combine the data with any third-party data that would enable us to do so.

2.3  Data recipients.

PubNative only discloses data to other parties if this is necessary for the implementation of campaigns or other purposes listed in this privacy notice, or if another legal basis for the disclosure of data exists. The collection and processing of usage data by the mobile app Publishers are controlled by and the exclusive responsibility of the respective Publishers. PubNative processes these data for and on behalf of the Publishers in the first place.

In the context of the serving of ads, data are exchanged between PubNative and partner advertisers on the bid request level (to get an ad) or in aggregated form for reporting and fraud analysis. This might include the following information on the bid request level:

  • device information (device model, platform, operating system version, browser details)
  • targeting information (county, city, hyperlocation when allowed to be collected)
  • user information (such as device ID, hashed device ID, age, gender and interests, when allowed to be collected).

If PubNative uses its own external service providers (e.g. data centers), the service providers may only use the data to fulfill their task. All service providers have been carefully selected and commissioned. They are bound by the instructions of PubNative and are regularly checked. In cases where data is processed in countries outside the European Union, appropriate safeguards are always in place to protect data subjects.

2.4  Retention period.

The collected data are stored for as long as the usage data and data about interactions with ads and installations of new apps are required for the described purposes. After that, the data are deleted or completely anonymized. We will further delete personal data immediately when the Publisher informs us that the user has withdrawn consent. We will, however, retain and use information as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

2.5  Basis for the processing.

The data processing described in this privacy policy serves to market ad space for targeted in-app advertising and targeting campaigns and implement ad campaigns for the customers of PubNative. As such, data are only processed on the basis of users’ consent as part of customer instructions. Insofar as data from PubNative are processed for purposes of billing, abuse monitoring or fraud prevention, error correction and for optimizing PubNative’s Technology, this is done on the basis of PubNative’s legitimate interests. The legal basis in this respect is Art. 6 (1) (f) GDPR. The interests of users are protected by the exclusively pseudonymous processing and the opt-out option described below.

  1. Users’ rights

Users have the right to access information about the processing of their personal data by PubNative. In this regard, PubNative will explain the data processing to you as the user and provide you with an overview of the data stored about you. However, since PubNative processes data on behalf of customers (Publishers), users should contact the relevant Publisher directly. Whenever needed and upon request, we will assist the Publisher. If data stored by PubNative is incorrect or no longer up to date, you have the right to have this data corrected. You may also demand that your data be erased. Should the erasure not be possible in exceptional cases due to other legal regulations, the data will be blocked so that it is only available for that legal purpose. You may also have the processing of your personal data restricted, if for example, you have doubts as to the accuracy of the data. You also have the right to data portability, which means that on request PubNative will send you a digital copy of the personal data you have provided. You also have the right to object to data processing, insofar as this is based on legitimate interests pursuant to Art. 6 (1) (f) GDPR. In particular, you can object to the processing of your data for advertising purposes at any time. The opt-out function described below can be used for this purpose at any time. You also have the right to complain to the data protection supervisory authority responsible for PubNative (Berlin Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219, 10969 Berlin) or to your competent authority. You are also free to contact your local data protection authority, which will then forward your request to the competent authority.

4. Opt-out

If you no longer wish to receive targeted in-app advertising that is deployed based on PubNative’s Technology, you may do so through the device-level advertising preference setting available in the settings menus of your iOS and/or Android devices.

Android Users (version 2.3 and above)

To use the “opt-out of interest-based advertising” option, follow the instructions provided by Google here: Google Play Help.

iOS users (version 6 and above)

To use the “Limit Ad-Tracking” option, follow the instructions provided by Apple here: Apple Support Center

Please note that these are device settings and will disable interest-based ads from all providers, and not just for us. We have decided to offer this way of opting-out, as we estimate users will either want to receive interest-based advertising or no interest-based advertising at all. The above-described way is most efficient to achieve that goal.

You may also request deleting your data or opt-out of targeted in-app advertising via e-mail to [email protected].

  1. Changes to this Privacy Policy

We reserve the right to change or update this Privacy Policy at any time in accordance with the currently applicable data protection regulations. This website always contains the latest version of the Technology Privacy Policy

Updated: July 2018