Ubimo and its affiliates (“Ubimo“, “we“ or “us“) is a location intelligence technology company in the digital mobile data and marketing space. Our clients are brands, advertisers, advertising agencies, mobile application publishers, website publishers, and other types of mobile marketing and data providers. Ubimo’s online data and advertising campaign systems technologies (“Platform” or “Platforms”) are designed to provide our clients with the ability to leverage real world context to make more informed data driven decisions.
Ubimo supports industry self-regulations and adheres to applicable industry guidelines. Ubimo is a proud member of the Mobile Marketing Association (“MMA”), Digital Advertising Alliance (“DAA”) AdChoices Program, and the Interactive Advertising Bureau (“IAB”).
This Policy will set forth how Ubimo collects and processes data from Ubimo’s website, www.ubimo.com (“Website”), and Platform, as well as protocols in place to protect such data. The Policy also sets forth consumers’ (“users”, “you”, “your”) right to know what type of data Ubimo has collected about them, and the users’ choice with respect to how Ubimo handles, stores, and processes such information – including the choice to opt out of targeted advertising and data collection.
Ubimo Data Collection & Usage
Information collected in the mobile digital advertising space generally falls into two categories:
(A) Non-Personally Identifiable Information (“Non-PII”): non-identifiable anonymous information about the device and IP address used to access the Internet; the browser or application data; operating system; screen resolution; which, and how many, client web pages have been viewed by a browser or application; search terms used or other interaction with a client website; referring and exit pages; the date and time an advertisement was viewed; location data; device-specific identifiers; and other similar information. Note this information may qualify as Personally Identifiable Information in certain jurisdictions.
(i) Precise Location Data (“PLD”): Precise Location Data, as defined in the National Advertising Initiative Mobile Application Code is information that describes the precise geographic location of a device derived through any technology that is capable of determining with reasonable specificity the actual physical location of an individual or device, such as GPS-level latitude-longitude coordinates or location-based Wi-Fi triangulation.
(B) Personally Identifiable Information (“PII”): information that can be used to directly identify an individual, such as your name, physical address, e-mail address, Social Security Number, credit card number, account numbers, passwords, personal health information; and other similar information.
What Data, Exactly, Does Ubimo Collect?
When an advertisement is rendered to a user via the Platform, the technology is designed with the goal of collecting Non-PII. The Platform is NOT designed to intentionally collect PII. Accordingly, data collected through the Platform consists primarily of common information found in typical internet communication protocols and Real-Time Bidding (“RTB”) protocols, from which Ubimo can then infer such things as: browser type (e.g., Safari, Chrome, Internet Explorer); operating system (e.g., Mac OS or Windows); browser language (e.g., English or Spanish); Internet Protocol (IP) address; Internet Service Provider (e.g., Comcast or Verizon); and mobile advertising identifier, for mobile devices such as smartphones and tablets. Ubimo may also match this non-PII across devices, browsers, or applications for the purposes of identifying devices and serving more precise advertising.
Ubimo also receives PLD via the Platform generated from the use of a mobile device, such as the latitude/longitude coordinates provided by a mobile application publisher or other supply source in connection with the opportunity to purchase advertising impressions. PLD may be transferred to clients and business partners, including for use in targeting advertising based on the current device location. Mobile application publishers and other publishers are solely responsible for providing a mechanism through which a user may enable or disable the collection of PLD from a device. However, Ubimo may infer the location of a given device(s), for the purposes of analyzing population density, movement, and/or patterns, from GPS coordinates analyzed in conjunction with WiFi access points a given device is in near proximity to. But Ubimo does not store the precise latitude/longitude coordinates that are inferred, and further trims such data points after two (2) decimal places, rendering it imprecise.
Non-PII collected by Ubimo is primarily used to identify the relevant audience to which an advertiser may target advertising with the strongest likelihood of a positive response. Ubimo also analyzes emerging trends from an advertising campaign based on the data yielded from a specifically targeted audience. This analysis is also shared with Ubimo’s clients and business partners. Non-PII collected by Ubimo is also used to populate advertising data segments, which are based on a user’s browsing patterns and interactions with a client’s mobile applications, and advertisers, in turn, are able to utilize these advertising data segments in order to build a more effective advertising campaign optimized for the intended audience.
Ubimo may also receive and utilize Non-PII from third parties, which may include certain identifiers connected to interest–based advertising, as well as advertising data segments that may be utilized by Ubimo’s clients to target advertising through the Platform
How Does Ubimo Collect Data?
When an advertisement is served to a computer or mobile device via the Platform, Ubimo employs the use of either “pixel tags”, “cookies”, or “Mobile Advertising Identifiers” stored on a user’s computer or mobile device (“Data Indicators”) (explained below). The Data Indicators are used to assist Ubimo and its clients in gauging a user’s interests and behaviors with the goal of delivering more relevant advertising to that user. To be sure, this information can then be used by Ubimo’s advertising clients to better cater to a user’s needs and deliver ads for the types of products and services which a user may actually be interested in. However, it is important to note that none of these Data Indicators personally identify an individual or enable Ubimo or its clients to personally identify an individual. Rather, the Data Indicators enable the Platform to determine with a reasonable level of certainty that a computer or device is the same as one with which the Platform has previously interacted.
What does Ubimo Do with the Data Collected?
As explained above, Ubimo uses the Non-PII collected to identify and target the most relevant audience in real-time, based on the context of location and experience, that will most likely have the strongest and most positive response to an advertisement served at a given moment. Ubimo also analyzes Non-PII collected during given advertising campaigns for trends, nuances, anomalies, and other factors that can be used to optimize the Ubimo Platform and serve Ubimo clients better.
Ubimo may also use Non-PII collected and advertising data segments created therefrom for the purposes of cross-app advertising (advertising between browsers or applications on a single device) or cross-device advertising (advertising between multiple devices). In certain instances, Ubimo may be able to infer, with a reasonable degree of certainty, that two different devices are used by the same user (i.e., Joe Smith is the user of both an iPad and iPhone previously served via the Ubimo Platform). Thus, we may use this information to deliver targeted advertisements across multiple computers or devices. This is sometimes referred to as cross-device advertising.
How Long Does Ubimo Hold Collected Data?
Ubimo may retain any data collected in any format, such as web log data, aggregations, and reports, for as long as necessary for reasonable and legitimate business purposes including client analysis, internal analysis, fraud prevention, cybersecurity audits, legal compliance, and client disputes.
Third Party Websites & Links
Ubimo recognizes your right to make informed decisions about information collection about you. Ubimo understands that, under applicable law, at any moment, you may exercise your right to: (1) obtain confirmation of the existence of your PII in Ubimo’s database; (2) verify its content, origin and accuracy; (3) request its correction, updating, amendment, deletion or transformation into anonymous form and its blocking due to violations of the law; and (4) oppose the processing of your PII on legitimate grounds.
In the event you have provided PII to Ubimo through our company Website and wish to edit or have it removed from our database completely or to exercise your privacy rights, please contact us at firstname.lastname@example.org. Please know that in order for us to respond to your request we may require that you verify your identity.
Users may also opt out of Ubimo tracking and interest-based advertising at any time by either: (i) opting-out directly from Ubimo’s online behavioral advertisements by clicking on the ad-choices icon appearing on such advertisements; or (ii) opting-out by changing your Do Not Track Settings on your mobile device as described below.
When a user opts-out, Ubimo will limit the information it collects and stores about a user’s computer or device and Ubimo will not deliver ads that are targeted to the user’s interests. If a user uses multiple browsers, computers or mobile devices, the user must opt out from each browser, computer, and mobile device individually.
When Ubimo receives an opt-out request, Ubimo records the opt-out on our servers and in browser environments we will attempt to place an HTTP opt-out cookie onto the requesting user’s computer or device. Please note that if cookies are not enabled on your browser, or if you use certain ad-blocking tools, our opt-out mechanism may not work properly. Please also note that deleting your cookies does not opt you out. When you opt out, Ubimo also stops serving interest-based advertising on that browser. In many instances, even if you delete your cookies, we are able to maintain a record of your opt-out on our servers. However, if you clear your cookies, or if you use a different browser or device, you may need to renew your opt-out choice.
Ubimo will collect and store information from your computer or device only as needed to honor your opt-out and for limited research and development purposes to improve our browser- and device-recognition technology, which also helps to improve our ability to honor your opt-out.
You may opt out in mobile application environments by clicking on the “AppChoices” icon seen in a given advertisement.
Even though a user has opted out, the user will still see advertisements. The advertisements delivered via Ubimo will simply not be as relevant.
You may also limit ad tracking in mobile application environments on your device. For the most effective and up-to-date methods for doing so, you should consult instructions provided by those device manufacturers. We offer the following information solely for informational purposes, and we cannot guarantee that the methods below are the most current:
- Apple instructions for how to Limit Ad Tracking on devices such as iPhones and iPads
- Google instructions for how to express choice on Android devices
If you have questions about how to opt out or limit mobile tracking, please contact us at email@example.com
Ubimo Data Security Protocol
Ubimo has implemented reasonable security measures and protocols to protect the information and data in its care. This includes, but is not limited to, the use of encryption methods. No method of transmission over the Internet, or method of electronic storage, is entirely secure, however. Therefore, while Ubimo strives to use commercially reasonable means to protect information, Ubimo cannot guarantee absolute security.
Data Disclosure to Third Parties
Except for information collected through the Platform and provided to our clients, affiliates, and partners in an anonymous format to operate or enhance our services for the purposes described above, or as required by law, Ubimo does not rent, sell or share the information collected through the Platform with third parties.
In providing its services, Ubimo works with a variety of third-party vendors and partners. These include publishers, data providers, content providers, and other service providers. Ubimo may share anonymous, non-PII with them, including statistical, demographic, contextual, behavioral and predictive information, about our users and their use of the Platform, to the extent necessary for Ubimo to provide its services. Ubimo may also enhance the non-PII collected via our Platform with non-PII collected from trusted business partners. Such information remains anonymous non-PII and cannot be used to contact or identify any person individually.
Ubimo may share information about individuals as it deems reasonably necessary in order to comply with applicable law, to exercise and protect the legal rights of Ubimo or its personnel and representatives, and to investigate, prevent or respond to suspected illicit activities, including fraud and threats of harm to individuals.
If Ubimo sells all or part of its business, or if any of its departments or Platform is acquired or merged with another company, we may transfer information about you, including PII submitted by you on our Website, to the successor company as part of that transaction. To the extent consent is required under applicable law for such a data transfer, we will obtain your consent.
In accordance with the Children’s Online Privacy Protection Act (“COPPA”), Ubimo does not knowingly collect PII from, and does not intend for advertisers to target children under 13 years of age. If you believe your child or someone else has provided Ubimo with PII about your child and you would like to have the information removed, please contact us and we will use reasonable efforts to remove such information from our records.
Data Collection on our Website
Ubimo collects personal information on the Ubimo Website when visitors choose to reveal it to us, such as when a visitor contacts Ubimo to request a demonstration of our products or services or to otherwise send us questions. Ubimo will collect personal information such as your name and email address. Ubimo uses information from the Website log files to determine how a visitor found out about Ubimo, what their interests are regarding our services, and how to further improve the Website and our service.
If you create an account on the Ubimo Website, Ubimo will retain your information for as long as your account is active with us or for as long as you are receiving our services. After you have closed your account with us or ceased to use our services, we may retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
You may also provide Ubimo with your personal information on the publicly accessible blog on the Ubimo Website. Please be aware that any information provided in these areas may be read, collected, and used by others who access it. To request removal of your personal information from the Ubimo blog, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove personal information, in which case we will advise if we are unable to do so and why.
Ubimo may provide personal information to companies that provide services to help Ubimo with our business activities, such as an email service provider to send emails on our behalf or a recruitment partner to process job application data. These companies are authorized to use personal information only as necessary to provide these services to us.
As is true of most websites, Ubimo gathers certain information automatically and stores it in log files. This information may include IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. Ubimo does not link this automatically collected data to other information we collect. Ubimo collects information automatically through the use of various technologies including cookies.