LAST UPDATED: April 2023
EFFECTIVE: April 2023
1. INTRODUCTION
Platee runs a marketing platform solution which provides advertising and monetization services/products (whether owned or through its partners) to marketers and supply partners including through digital media, sites, surveys, owned or operated application(s)/widgets, exchange(s) for demand/supply, marketing automation solutions and other services, such as, fraud detection, reporting, audiences, attribution, analytics, modelling, segments, measurement ("Marketing Platform").
2. SCOPE OF THIS PRIVACY POLICY
2.1 APPLICABILITY
This Privacy Policy explains how Platee collects, uses and shares information from individuals that interact with its services, offering or platforms comprising its Marketing Platform ("Marketing Platform Services") and its website, respectively. Platee is the controller for the personal information we process, unless otherwise stated.
2.2 NON-APPLICABILITY
Platee may offer independent mobile applications, web content services, lock-screen platforms, social entertainment platform(s), widgets, and/or other software features to consumers through smart devices which may be preloaded on the devices, downloadable, hosted on web or made available through other digital media ("Consumer Offering"). This Privacy Policy does not apply to the collection by or processing practices of each of the foregoing services, respectively. If you are a consumer of any such Consumer Offering, the applicable privacy policy should be available to you through such services. Please refer to the respective privacy policies of each Consumer Offering for a description of its data collection and data use practices.
To the extent that foregoing Consumer Offering promotes any interest-based advertising using the Marketing Platform Services, the terms of this policy would apply to the data processing practices for such Marketing Platform Services.
Marketing Platform Services and Consumer Offering are collectively referred to as "Services".
3. Platee MARKETING PLATFORM SERVICES
Platee engages with third party site/app publishers and app developers to serve ads on their digital properties on behalf of its demand side advertising partners through various channels of advertising solutions including exchanges, network, off-network etc. Platee may also serve ads on Consumer Offerings. Platee also engages in campaign planning, measurement (e.g. whether an advertisement was viewed, its timestamp etc.) and attribution of advertisements, whether by itself or through third party measurement partners.
Platee provides Marketing Platform Services, including optimization of advertising campaigns, data analytics/enrichment, segment creation, user acquisition, re-engagement, remarketing or retargeting through various digital advertising channels. Platee receives data into its Marketing Platform from various sources, including end user information collected by our systems, applications/offerings, partners, data/cookie vendors or customers ("Sources"), which may include third party apps, sites and services that you use. Please refer to the privacy policies of the apps, sites, and services you use to understand how those apps, sites and services collect, use, and share data from your interactions with them. Platee is not responsible for how those third-party apps, sites and services collect and use data.
4. WHAT PERSONAL INFORMATION DO WE COLLECT?
When you view an advertisement distributed through Platee on a site, app or other digital media, we may collect information on your device and your interaction with the advertisement. This information enables us to serve advertisements to you, improve our Services including to recognize your device when you use other sites and applications that have partnered with us. Platee may also collect information about you when you elect to interact with our surveys or opinion-based applications. Information we may collect includes:
(a) Device identifiers. Device identifiers are alphanumeric strings that are unique to your device. These include:
liOS devices'Identifier for Advertising (IDFA) and iOS Identifier for Vendors (IDFV)
lGoogle Advertising ID (GAID), or Android ID for Android devices
lIdentifier for Advertising on OTT and CTV platforms
lInternational mobile equipment identity (IMEI), in certain jurisdiction as permitted by applicable law
lCookie IDs
(b) Location information,including:
lGeo-location or precise location of your device if you have given the app or site permission to collect your location information
lLocation information we infer based on data collected through a WiFi identifier that your device is connected to, in accordance with applicable law and provided location access is permitted
lLocation information we infer from your device's IP address, provided that we will not infer location from an IP address to a more precise than city-level of accuracy unless you have given the app or site permission to collect your location information
(c) Network information,including:
lMobile carrier
lNetwork provider or ISP
lNetwork type (e.g., WiFi or cellular)
lIP address
lIDs of WiFi access points to which your device is connected
lDate and time of connection
(d) Information about apps or sites and our Software Development Kit (SDK), including:
lApp or site name or version
lApp identifier
lSDK version
lAPI key identifier
Other information about/on your device, including:
lDevice type (e.g., make and model)
lDevice startup time and update time
lDevice name
lScreen size
lMemory and hard drive capacity
lOperating system and version (e.g., iOS 14, Android, Windows, Blackberry)
lMobile browser used (e.g., Chrome, Safari, Firefox)
lLanguage settings (including country code) and time zone
lApp usage
Advertisement information. We collect information about the ad presented on your device, including:
lThe content type of the ad (the advertiser and category, e.g. games, finance, entertainment, news)
lThe ad type (e.g. whether the ad is a text, image, video or other format based)
lWhere the ad is being served (e.g. the site, digital media or app on which the ad appears)
lWhether you viewed, clicked or otherwise interacted with the ad
Survey information. We may ask users to voluntarily participate in online surveys. These surveys help brands improve their products and services offered to you. If you fill out a survey, we may collect your device information described above and information you provide, including your:
lAge
lName
lEmail address
lPhone number
lGender
lOccupation and income range
lFamily size and other demographic information
lPreference for brands, modes of travel, and other consumer choices.
Other marketing information:
In the context of our Marketing Platform Services, our customers, partners or vendors may also disclose to us certain personal or non-personal information they have separately collected about you during your interaction with their apps, sites or services so that we can effectively provide our Services. This may in the context of websites, including mobile websites, include cookies, other technologies, or other aggregated characteristics or other identifiers related to your device to understand your interaction with such site and to serve certain types of ads relevant to your interests.
These parties serve you cookies in accordance with their own specific privacy/cookie policies and subject to their own applicable legal requirements. We do not use the information they provide to us for any purpose other than as permitted by such third parties or for providing or improving our Services.
We do not collect any sensitive data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric data, data concerning health. We may show targeted advertisements to fitness enthusiasts.
5. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the information that we collect about your device to:
lDisplay advertisements on your device, which may include interest-based advertising customized to your interests, preferences, locations
lFor remarketing or retargeting i.e. to display relevant ads if you have previously visited/accessed/downloaded a site or mobile application that we partner with
lFor bidding to serve advertisements and to determine which ads are most effective
lAnalyze and provide our demand partners or advertisers reports on the effectiveness of advertisements and campaigns, including across different types of devices based on our determination of devices that are related to the same person. We, or third parties whom we engage to provide this service, may use cross-device data to provide interest-based advertising services and to deliver tailored ads to users across multiple mobile devices including over the top applications and smart televisions
lAvoid showing you the same ads too many times
lBuild custom audience segments to enable our customers and partners better target their advertisements and offers
lImprove our Services and assist our customers and partners in improving their products and services
lDetect, deter and prevent fraud, fraudulent traffic or to protect the security of our systems
lWe may process your survey responses and share the response data with the brands who are our customers/marketers
6. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
Platee may share the information we collect or receive about you as described in this Policy as follows:
lPublishers and Supply Partners. We may share your information with publishers (the app or site publishers) to help them understand how users interact with their apps and sites and advertisements on their apps and sites.
lDemand Partners and Advertisers. We may share your information with demand partners, brands and advertisers who use our Marketing Platform, to allow them to understand the performance of their campaigns; and to help them better target their campaigns, products or offerings.
lMarketing Partners. We may share your information with data partners who help us with better understanding your preferences by providing data enrichment, analytics and identification services and measurement companies who help us with attribution and tracking of advertisements distributed through us ("Marketing Partners").
lService Providers. We may share personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include: IT and related services; fraud detection, information and services; payment processors; customer service providers; and vendors to support the provision of the Services.
lGroup. We may share personal information with the Group so that the Services of Platee and/or the Group may be improved and otherwise to serve you and/or our customers better with all our offerings including effective content management "Group" as used in this policy, means, with respect to Platee, its affiliates and group entities listed here.
lDisclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others'rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
lDisclosures in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
lInternational Data Transfers. Where applicable, we will protect information through other legally valid methods, including international data transfer agreements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
7. HOW DO WE KEEP PERSONAL INFORMATION SECURE?
Platee uses reasonable technical and organizational measures to protect the information it collects about you in compliance with its legal and privacy requirements and contractual obligations. We also seek appropriate contractual protection from our partners regarding their collection, use or treatment of user data. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
Platee may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations. In case any information is provided by you in participation of a survey or opinion-based application by Platee, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
9. OPTING OUT OF INTEREST BASED ADS
Opting out of interest-based advertising: If you prefer not to receive interest-based advertising from Platee, you can opt out at any time by going to the Platee Opt Out page and submitting your device ID or any other listed identifier. If you opt-out of interest-based advertising, you will still receive "generic" ads from Platee. To opt-out of our cross-device ad targeting, you must opt-out on every device browser and device using the appropriate opt-out methods.
10. PRIVACY RIGHTS
The privacy laws of your country may grant you the following additional privacy rights relating to their personal information: right to access, request correction, request deletion/anonymization/blocking, restrict/object to processing, withdraw your consent, request data portability, be informed about third parties with whom your data has been shared, and request review of decisions taken exclusively based on automated processing. To exercise these rights, please contact us at:platee.com.
11. INTERNATIONAL TRANSFERS
Platee may share your information with clients, customers, partners, the Group and other third parties described above who are based in countries outside of your country of residence , subject to any contractual or legal requirements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world.
While some countries may not have data protection laws that are equivalent to those of the country in which you reside, we will take reasonable measures to protect your information in accordance with this Privacy Policy.
12. LEAD GENERATION CAMPAIGNS
Platee may offer form-based advertising solutions to marketers that include the collection of voluntary information from you as part of an advertisement that contains a questionnaire. Such information may consist of personal data, non-personal information or data, or both. All the information that you voluntarily provide in response to such form or questionnaire is typically forwarded directly to the relevant marketer’s servers or their landing page and in such cases will be governed by such marketer's privacy policies in place at the time of transfer.
In the event any personal data is directly processed by Platee, you acknowledge that Platee may be required to store such information for the period during which it continues to manage the applicable lead-generation campaign for its marketer on whose behalf the information is collected. This information may be temporarily stored by Platee solely for running such form-based campaigns and will be used only for the purpose of optimization of such campaigns, subject to applicable legal/privacy and contractual requirements. Platee has implemented internal safeguards to protect the temporary storage of this information and uses reasonable technical and organizational measures to protect the same. Platee has mechanisms to delete or anonymize any personal data after the said campaign is concluded or within a period thirty (30) days from the same. Pursuant to the conclusion of the applicable campaign, Platee may retain and use your Information only to the extent necessary for it to create reports for its client, comply with its legal obligations, resolve disputes and enforce agreements and no other purpose. Any non-personal information or data submitted by you may be used for improving our Services.
13. COOKIES
We use cookies and beacons to help us collect some of the information we have described above. This may be done when you interact with us or our third-party partners who enable Platee to collect data related to your interaction with their apps or sites for the purpose of serving relevant Ads to you and/or improve our services. We may also use cookies on our and our advertiser's websites to provide website functionality and advertising to you respectively, and to save you having to provide the information you have already given us on subsequent visits to our site.
We recommend that you review the privacy policies of the third-party apps, services or sites that you directly interact with to learn how those third parties use cookies.
14. PRIVACY OF CHILDREN
Platee complies with the age-gating requirements under applicable privacy laws such as Children's Online Privacy Protection Act (COPPA) and California Consumer Privacy Act (CCPA) in the U.S., Lei Geral de Proteção de Dados Pessoais (LGPD), General law of personal data protection in Brazil and GDPR in the EEA and does not knowingly collect personal data about users of sites or apps directed to children.
15. OTHER WEBSITES
Our website and the ads we service may contain links to other websites. You should be aware that we are not responsible for the privacy practices of such other websites as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these links and we shall not be responsible for any use of such websites.
16. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy at any time. The amended Privacy Policy will be displayed on our site. Please check our Privacy Policy regularly to ensure you have read the latest version.