Privacy Policy
Effective from January 1, 2020
The Company
Ubimo, Inc. (“Ubimo”) is an advertising technology company in the digital media mobile advertising space. Our clients are advertisers, advertising agencies, mobile application publishers, website publishers, and other types of mobile advertising inventory providers. Ubimo’s online advertising campaign system technologies (“Platform”) are designed to provide advertisers with the ability to serve the most relevant advertisement in real time or with real world context based on a given viewers past or present location and experience.
Ubimo’s Platform collects and uses data for two main purposes: (1) to make digital mobile advertising more relevant; and (2) to help optimize the Ubimo Platform in the fast-paced ever-changing digital advertising technology environment. However, Ubimo is also committed to responsible data handling and privacy practices. This privacy policy (“Policy”) is Ubimo’s statement of such commitment.
Ubimo supports industry self-regulations and adheres to applicable industry guidelines. Ubimo is a proud member of the Digital Advertising Alliance (“DAA”) AdChoices Program, and the Interactive Advertising Bureau (“IAB”), and the Network Advertising Initiative (“NAI”), and adheres to the NAI Code of Conduct.
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
The information collected by Ubimo generally falls into three categories:
(A) Device, Internet or Other Network Activity Data (“Device Data”): 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. Device Data includes Device-Identified Information (“DII”) which as defined by NAI Code of Conduct includes any data linked to a particular browser or device if that data is not used, or intended to be used, to identify a particular individual.
(B) Precise Location Data (“PLD”): Precise Location Data, as defined in the 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) Contact Information (“Contact Information”): information submitted by an individual to us through our website, such as your name, physical address and email address.
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 Device Data. The 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 Device Data 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.
Device Data and PLD collected by Ubimo are 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. Device Data 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 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 described above, 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.
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 “pixel tags”, “cookies”, “Mobile Advertising Identifiers”, or similar 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. 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. 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 Device Data and PLI 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 Device Data 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 Device Data 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 reasonably infer that two different devices are used by the same user. Thus, we may use this information to deliver targeted advertisements across multiple computers or devices. This is sometimes referred to as cross-device advertising.
Ubimo may also use information we collect about you to comply with local, national, and international laws or to comply with our legal obligations, resolve disputes, and enforce our agreements and policies.
How Long Does Ubimo Hold Collected Data?
Ubimo retains all information we collect about you for the period necessary to fulfill the purposes outlined in this Privacy Policy. For location data, Ubimo may retain such data for up to 15 months. Ubimo may retain data beyond the foregoing time limits if required or permitted by law.
Third Party Websites & Links
Advertisements rendered via the Platform may contain links to or redirect individuals to other websites. These websites may use cookies, web beacons, and/or other data collection tools. However, Ubimo is not responsible for the privacy practices, policies, or the content of websites that Ubimo does not own or control. Ubimo strongly advises that users familiarize themselves with the privacy policies of any website or mobile application users may interact with.
Ubimo contractually requires its clients to adhere to applicable laws and regulations. However, Ubimo does not have access to, or control of, the cookies, web beacons, and/or other data collection tools that may be placed on any advertisement by a third party. Accordingly, this Policy does not cover the use of cookies and/or other data collection tools by any third party.
Opt Out
Opt Out
Ubimo recognizes your right to make informed decisions about information collection about you. Ubimo understands that in certain jurisdictions you may have the right to: (1) obtain confirmation of the existence of your Contact Information 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 Contact Information on legitimate grounds.
In the event you have provided Contact Information to Ubimo through our company Website and wish to edit or have it removed from our database or to exercise other privacy rights you may have, please contact us at info@ubimo.com. Please know that in order for us to respond to your request we may require that you verify your identity.
Users may also contact Ubimo about other opt out options from Ubimo tracking and interest-based advertising at any time by sending an email to info@ubimo.com.
You may opt out in mobile application environments by clicking on the “AppChoices” icon seen in a given
advertisement.
For further guidance on opting out you may visit the Network Advertising Initiative’s Opt-out page here.
Even though a user has opted out, the user will still see advertisements. The advertisements delivered via Ubimo will simply not be as relevant.
Other ways to opt out
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 info@ubimo.com