Last Updated: 4/4/14
Moasis Global LLC (“Moasis”) provides a geo-centric delivery platform and related services that allow advertisers utilizing such platform (“Advertisers”) to display advertisements (“Ads”) on publisher mobile applications and mobile websites (“Publishers”). Moasis seeks to (i) enable Advertisers to better reach their target audience, (ii) enable Publishers to maximize their advertising revenue, and (iii) expose consumers to Ads relevant to their interests and location.
Moasis Customer Information: Collection and Use
This section applies to information we may collect from our Moasis Customers when they access and use our advertising platform and related Moasis technology and services (including, without limitation, the Moasis Website) (collectively, the “Services”). Moasis collects information to provide and improve the Services and to administer your Moasis account (“Account”). We may collect information from our Moasis Customers in the following instances:
When you register with us through the Moasis Website (whether as a Publisher or an Advertiser), we will ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you. Personally identifiable information includes, but is not limited to:
- For Publishers: name, phone number, Account password, bank or on-line account information, Federal Tax ID number, email address, postal address, and device IDs;
- For Advertisers: name, phone number, Account password, bank or on-line account information, Federal Tax ID number, email address, postal address, and click-through URLs;
- For all Moasis Customers: any other personal information listed in the Account registration form.
We also collect non-identifying information that you provide through registration and the administration and personalization of your Account (e.g., without limitation, zip code (on its own) and individual preferences).
We use your personally identifiable information (in some cases, in conjunction with your non-identifying information) mainly to provide the Services, complete your transactions, administer your inquiries, and contact other Moasis Customers regarding Account activities or communications relevant to the Services.
Certain non-identifying information would be considered a part of your personally identifiable information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-identifying information when they are considered alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your personally identifiable information with non-identifying information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Services and to analyze and understand how our Site and Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
In addition, if you are a Publisher, we may collect information related to interactions of Consumers with your mobile applications and/or mobile websites, including demographic data associated with a device ID (not personally identifiable), as described in more detail below.
Moasis Customer Information: Sharing and Disclosure
We may share and/or disclose information that we collect from our Moasis Customers in the following instances:
Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include personally identifiable information with third parties, and we may otherwise disclose non-identifying information (including, without limitation, any device IDs and associated demographic data) and log data to third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your personally identifiable information.
Service Providers. We may employ third party companies and individuals to (i) operate the Moasis Website and facilitate the Services, (ii) provide the Services on our behalf, (iii) perform Moasis Website-related services (e.g., maintenance services, database management, web analytics and improvement of the Site’s features) and (iv) assist us in analyzing how our Site and Services are used. These third parties have access to your personally identifiable information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Business Transfers. Moasis may sell, transfer or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganization, sale of assets or equity, or in the event of bankruptcy.
Compliance with Laws and Law Enforcement. Moasis cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to (i) respond to claims and legal process (including but not limited to, subpoenas), (ii) protect the property and rights of Moasis or a third party, (iii) protect the safety of the public or any person, or (iv) prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.
Changing or Deleting Customer Information
All Moasis Customers may review, update, correct or delete the personally identifiable information in their registration profile by contacting us. If you completely delete all such information, your Account may be deactivated. If you would like us to delete your record in our system, please contact us at firstname.lastname@example.org and request that we delete your personally identifiable information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
CONSUMERS WHO VIEW ADS
This section of the Policy applies to information that Moasis may collect, access and/or obtain about Consumers who view Ads while using or accessing a Publisher’s mobile application or mobile website (“Mobile Media”).
Consumer Information: Collection, Use, and Sharing
We only collect personal information when you knowingly and voluntarily provide it to us, such as when you provide us feedback or request information from us. You do not have to provide personal information to use our Services and we do not collect personal information through our Services. Moasis does not collect the phone number or the unique device IDs for mobile devices. However, Moasis may deliver Ads that are targeted based on location or other user-entered information. Moasis does not store or connect this information to the unique device ID. The Ads delivered by Moasis may include forms or other prompts that allow users to opt-in to share data, including personal information, but you may choose not to provide that data. Moasis tracks unique users through an anonymous code that cannot be tracked back to a device or any personal information. Moasis does not collect or store the unique device ID of a mobile device.
If you use a particular Publisher application or mobile website, that application or mobile website may independently collect information from you. Notably, this Policy does not cover such information collected by a Publisher through its application or mobile website. When using a particular application or mobile website, you should familiarize yourself with the given Publisher’s terms and conditions and privacy practices. Moasis is not responsible for, and cannot control, a given Publisher’s privacy practices. Publishers may use Moasis technology to request personal information from you.
When you opt-in to provide personal information to Moasis Customers, Moasis restricts access to such personal information to employees, contractors and agents who need to know the information in order to operate, develop or improve rhe Services and to service the Moasis Customers. We take all reasonable steps to ensure that these parties comply with confidentiality obligations and do not use such information for any purpose other than providing the Services to Moasis Customers.
Our Publishers allow us to serve Ads on their Mobile Media. We use technology to send, directly to your browser or mobile application, the Ads and links that appear on the Mobile Media. If you are a Consumer, we automatically receive your IP address when this happens, and we use other technologies (such as cookies and Pixel Tags, as described below) to measure the effectiveness of the Ads and to personalize the advertising content that you see on the Mobile Media. We also collect, access or obtain other non-identifying information in conjunction with your IP address; these non-identifying details include, but are not limited to, the website you are logged onto or the application you are using, the geographic location of the IP address you are using to access the Internet, the type of browser used, which and how many web pages have been viewed by you, which applications you have used, search terms used, referring/exit pages, platform type and date/time information. We may also conduct surveys by serving interactive advertisements that ask Consumers to provide information such as their gender and age range (e.g., 30-40, 40-50), which information will be associated with a device ID (not personally identifiable). If you are a Consumer and decide to respond, your demographic information will be associated with an anonymous device ID and used only for the purposes described in this section. We do not collect, access or obtain personally identifiable information (such as name, username, address, phone number or email address) from you when you view or interact with Ads.
The information we collect, access or obtain about you is usually anonymous and does not personally identify you except as noted above when Publishers share a limited amount of your personally identifiable information with their third-party service providers like Moasis. This information is used by Moasis for the purpose of delivering Ads and measuring their effectiveness with Consumers. If we ask a Publisher to enable us to serve an Ad to a certain audience, or a Publisher requests an advertising campaign for a certain audience (for example, men ages 18-34) or audience segment (for example, women ages 25-40 who have viewed certain content) and you respond to or interact with that Ad, we may conclude that you fit the description of the audience we are trying to reach. We aggregate this information and use it to analyze trends, identify the audience most likely to respond to an Ad and to tailor Ad placement for members of our advertising network accordingly. This aggregated information may be shared with our affiliates, employees, and Moasis Customers. In addition, we may share with such individuals and entities any device IDs and associated demographic data. Any information shared in this context will not contain your personally identifiable information. We reserve the right to track IP addresses for the purposes of fraud prevention, and we reserve the right to release IP addresses to legal authorities.
We may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (individually or collectively, “Pixel Tags”) to analyze usage patterns of Consumers and to serve Ads to you that are tailored based on our analysis. A Pixel Tag is an electronic image, often a single pixel, which is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a webpage or in a mobile application and may be associated with cookies on your hard drive. Pixel Tags allow us to count users who have used certain mobile applications or visited certain websites and pages within websites, to personalize the Ads, and to help determine the effectiveness of promotional or advertising campaigns.
Moasis markets the Ads that invite the Actions on behalf of the Advertisers, but the Advertiser is the issuer of the content appearing in the Ads. As issuer of an Ad, the Advertiser is fully responsible for any and all injuries, illnesses, damages, claims, liabilities and costs suffered by or in respect to you, caused in whole or in part by the Advertiser or its products and services, or the Actions, as well as any claims arising from unredeemed or partially redeemed Ad-featuring offers, promotions and/or coupons. By redeeming an offer, participating in a promotion, or using a coupon, you acquire only the specific rights thereby granted.
We may change this Policy at any time, at our sole discretion. Use of information we collect now is subject to the Policy in effect at the time such information is used. If we make changes to the Policy, we will notify you by posting an announcement on the Moasis Website so that you are always aware of the information we collect, how we use it, and under what circumstances, if any, it is disclosed. If we make any changes to this Policy, we will change the “Last Updated” date above.