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
At this time, Ubimo’s Platform and services offered in connection with the Platform are focused solely and exclusively in the United States and its territories. Ubimo does not collect, process, or monitor personal data of citizens/data subjects of the European Union. For more information click here.
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.
(B) Precise Location Data (“PLD”): Precise Location Data, as defined in the National Network Advertising Initiative Code of Conduct 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.
(C) 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 Device Identifiable Information (“DII”) 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. As defined in the NAI code of Conduct, DII includes any data linked to a particular browser or device if that data is not used, or intend to be used, to identify a particular individual.
Ubimo may collect the following information about your device:
(a) device type (e.g. smartphone, tablet, etc.)
(b) operating system (e.g. iOS, Android, Windows, Blackberry)
(c) network provider, mobile browser used (e.g. Safari, Internet Explorer etc.)
(d) platform, SDK version, timestamp, API key (identifier for application), application version,
(e) iOS Identifier for Advertising, iOS Identifier for Vendors,
(f) model, manufacture of device, OS version of device,
(g) session start/stop time, locale (specific location where a given language is spoken),
(h) time zone, network status such as WiFi,
(i) the geo-location of your device (using GPS or other geo-location data) and the Identifier for Advertising (IDFA) or the Google Advertising ID (AAID) etc.
Ubimo may also collect the geo-location of your device only when an app or site is active on the device. One way Ubimo derives a device’s location is by collecting the device’s latitude and longitude coordinates through GPS. Ubimo may infer the geo location of a device based on data collected through a WiFi identifier that the device is connected to, subject to country specific laws and/or industry guidelines related to such collection or inference practices. e.g: In the U.S. and Ubimo may infer geo-location through WiFi identifiers pursuant to obtaining user consent through applicable apps or sites.
Finally, Ubimo may also collect “non-sensitive” aggregated and anonymous health segments, which concern data unrelated to a specific health condition or treatment. Such non-sensitive health segments include interests concerning health and wellness, diet and weight loss, and nutrition, as well as purchase data concerning over-the-counter-pain relievers, cough/cold medicine, first aid supplies.
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 up to 15 months, including client analysis, internal analysis, fraud prevention, cybersecurity audits, legal compliance, and client disputes. Ubimo may retain data beyond the foregoing time limits if required by law or Court Order.
Third Party Websites & Links