January 01, 2020
This Section describes how we collect and use Information in the usual course of business, including through our websites (such as “http://www.mobgc.com” or any other website on which this Notice is posted) and other corporate services, web portals, and dashboards we make available to our Clients, as well as in connection with our events, sales and marketing activities.
As you navigate through this Site, some of your personal information may be actively collected (for example, names, birth dates, personal ID card numbers, addresses, telephone numbers, E-mail addresses, occupations, education, work experience and related information) or passively collected (which you did not actively provide) such as your browser type, domain name, IP address, pages visited, and the length of your user session using various technologies and means, such as Internet Protocol Address, cookies, Internet Tags and navigational data collection. In order to improve our service quality, it may be necessary to ask for personal information to fulfill your requests and provide a better service. GCMOB is entitled to take measures to validate the authenticity of personal information you provide. If you give us personal information of somebody else, we will assume that you have their permission to do so. Transmissions to and from this Site may not be confidential and consequently, may be read or intercepted by others.
The provision of personal information by you may be necessary where in our legitimate interest for the following purposes: (i) to provide you with GCMOB products or services or information in relation to the same; (ii) to sign you up for an event or training; (iii) to contact you and respond to your requests and enquiries; (iv) for business administration, including statistical analysis; (v) to personalise your visit to the Site and to assist you while you use the Site; or (vi) to improve the Site by helping us understand who uses the Site.
The servers used in the operation of the Site automatically identify a computer by its IP address. Although, we will not be able to identify the computer using its IP address once you have left the Site. If we, in good faith, determine that you have or are attempting to misuse or harm the Site, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property.
Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganisation or otherwise.
GCMOB has entered into EU standard contractual clauses (“Model Contracts”) for intra-group transfers of personal information to its affiliates. You can request a copy of these Model Contracts by submitting your request via email to email@example.com.
If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA. If you are residents of the State of California in the United States, effective from January 1, 2020, you have a right to:
(i) exercise certain consumer rights such as request to know, disclose, access or delete your data, collected in the last 12 months, by writing to us at firstname.lastname@example.org; and (ii) opt out of selling of your data by clicking on the following link: DO NOT SELL MY DATA.
We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. We will only keep your personal information for as long as necessary and in any event in relation to personal information collected by us on the Site we will only keep this personal information for one (1) year.
We may contact you periodically by e-mail to provide information regarding our products, services and content that may be of interest to you. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.
If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the communications or request to be opted-out of receiving such communications via email to email@example.com.
The Site may contain links and pointers to other sites on the Internet that are owned or operated by third party vendors and other third parties (the “Outside Sites”). GCMOB is not responsible for the availability of, or the content located on or through, any Outside Site, including any webcasting or other form of transmission received from any Outside Sites. You should contact the site administrator or Webmaster for those Outside Sites if you have any concerns regarding such links or the content located on such Outside Sites. GCMOB permits certain third party links to the home page of its Site, provided that GCMOB is provided with notice of such links and does not thereafter object to such linking. GCMOB reserves the right to revoke unilaterally any consent that it may at any time give to any linkage, including linkages to the home page. The Outside Sites are being provided to you only as a convenience and any link or pointer contained on this Site does not imply endorsement of the Outside Sites.
All Site content, design, text, graphics, images, logos, buttons, icons, interfaces, audio and video clips, and the selection and arrangements thereof are the exclusive property of GCMOB, or its respective content providers, and are protected by Hong Kong SAR and international copyright laws. All software used on the Site is the property of GCMOB or its respective software suppliers, and such software is protected by Hong Kong SAR and international copyright laws and other applicable laws and treaties. Users of this Site shall not transmit/post any information to this Site that infringes the copyright or other intellectual property rights of others.
When you: (i) view ads served by GCMOB’s Advertising Service; (ii) interact with GCMOB’s Advertising Service; or (iii) interact with services provided by GCMOB’s business partners, we and/or our business partner may collect the following personal information from you:
Device make, device model, operating system (e.g. iOS), device type (e.g. smartphone, tablet, etc.), device properties related to screen size and orientation, audio volume and battery, network connection type, IP address, Internet browser user-agent used to access the Advertising Service, identifier for advertisers (IDFA), timestamp, iOS identifier for advertising, OS version of device, geo-location data, information about when and for how long you use the Advertising Service or any service provided by GCMOB’s business partners, transactional data related to your interaction with an application, website, platform, or service provided by GCMOB’s business partners, such as information about the actions taken in an application like purchases or application installations; device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
We use your personal information to display advertising on your device, which may include interest-based advertising customized to individuals’ inferred interests, preferences, locations and other features.Where required, the publisher will obtain your consent for and on our behalf for the processing of your personal information to display advertising on your device. You can withdraw your consent at any time.
Where necessary in our legitimate interests we use your personal information: (i) to understand and analyze your usage trends and preferences and improve our Advertising Service; or (ii) for purpose of anti-fraud and traffic quality monitoring in order to perform the contractual obligations to our advertisers and publishers.
We may also use your personal information to comply with applicable laws, regulations or codes of practice.
We may disclose your personal information to our business partners, including advertisers, publishers, and data tracking companies. These business partners may use your personal information to show you advertisements, measure your ad/site interaction, and better understand the site and app traffic usage or user behaviour in order to improve their services. Such partners’ use of the information that we disclose to them will be governed by their privacy policies.
We may disclose your personal information to our trusted agents and service providers so that they can perform requested services on our behalf. For example, we may share payment information with a third party service provider in order to assist us with processing credit card payments. These entities are prohibited from using User’s information for any purposes other than providing us with requested services. We may also share aggregate or anonymous information with other third parties in accordance with the terms of this Policy.
We may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganisation or otherwise.
If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of you personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.
If you are residents of the State of California in the United States, effective from January 1, 2020, you have a right to:
(i) exercise certain consumer rights such as request to know, disclose, access or delete your data, collected in the last 12 months; and (ii) opt out of selling of your data by clicking on the following link: DO NOT SELL MY DATA.
The security of your information is our utmost priority, and we take strict measures in order to protect our data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the Advertising Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for your information. Physical access is strictly controlled both at the perimeter and at building ingress points by our staff utilizing video surveillance and other electronic means.
We also protect your privacy by seeking to minimize the amount of sensitive data and PRI that we store on our servers in the first place. We also seek appropriate contractual protection from our partners regarding their treatment of user data.
GCMOB may retain the information relating to you collected as necessary for internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).
Our Clients are responsible for ensuring that their mobile apps comply with data privacy protection legislation applicable to minors and children, such as the United States’ Children’s Online Privacy Protection Act (“COPPA“), including where relevant by obtaining parental consent prior to the collection of personal information. With respect to COPPA specifically, we rely upon our Publisher Clients to confirm whether or not their app is subject to COPPA. As required by COPPA, Vungle will enable a flag in our system when a Client indicates their app is subject to COPPA such that the End User’s device history is disassociated, and the only End User personal information used by the Vungle Ad Services would be persistent identifiers (e.g., IP address and device identifiers) to provide “support for internal operations” of the Vungle Ad Services (as permitted by COPPA).