Privacy Policy

Liftoff

Privacy Policy

Effective: August 2024

Liftoff Mobile, Inc. (“Company,” “we,” “us,” “our”) is a mobile advertising company that provides customers with an advertising and optimization platform and software (the “Services”). In order to provide our Services to customers, we collect and use certain information about user activity and preferences. As such, we know that our users (“you”, “your”) care about their personal information and how it is used and shared, and we take your privacy very seriously. Taking the importance of your privacy into consideration, we have created and enacted this privacy policy to help you understand our privacy practices.

KEY POINTS

• Liftoff Mobile, Inc. is the data controller of personal information processed through our interaction with you or processed in order to serve you with ads.
• We obtain and process information about end users who are targeted with our customers’ ads (insofar as the information is required for such ad targeting), customer and supplier personnel (for the purposes of liaising and contracting with customers and suppliers and for business development purposes) and users of our website (to provide the website and answer queries and requests).
• We may send you marketing updates about our services, however you can unsubscribe at any time.
• We share information with third party service providers, our affiliates and partners, our group companies and where required by law.
• You have a number of rights that you may exercise in relation to our use of your personal information, and you may exercise these by contacting us at [email protected] or [email protected].

I. WHAT DOES THIS PRIVACY POLICY COVER?

The privacy practices and policies that we outline in this privacy policy will apply to the way that we use your information. Generally speaking, you will fall into one of four categories:

• “Site Visitor”: accessing or browsing the www.liftoff.io site (the “Site”);
• “Customer”: requesting the provision of Services from us;
• “Partner”: providing services to us, to allow us to provide Services to our Customers: or
• “Targeted End User”: using mobile apps provided to you by our Customers (acting as an “End User”).

This privacy policy applies to the Site and our Services. This privacy policy describes how Liftoff Mobile, Inc. collects, uses, shares and stores information that identifies you (“personal information”) as well as your choices regarding the use, access and correction of your personal information. Please note that this policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

This Privacy Policy covers the following:

• Who we are
• The information we collect and how we use and store your personal information
• Cookies
• International transfers
• How we share your personal information and who we share it with
• Security
• Data retention
• Your rights and your options for opting out of these practices
• Changes to the privacy policy
• Children’s Privacy
• Complaints, questions and suggestions

II. WHO WE ARE

Liftoff Mobile, Inc. is the data controller of the personal information that we collect from you. It is a company registered in Delaware (registration number C3511707), whose registered office is at 555 Bryant Street, Suite #133, Palo Alto CA 94301.

You can contact us in relation to this privacy policy by email at [email protected] or [email protected].

III. THE INFORMATION WE COLLECT AND HOW WE USE AND STORE YOUR PERSONAL INFORMATION

The type of personal information that we process falls into three categories:

• Information we collect from Customers and Partners in connection with the provision of our Services;
• Information we collect and use when Targeted End Users interact with our Customers’ mobile applications and which we need to provide our Services; and
• Information that Site Visitors provide to us via the Site.

A. Information We Collect from Customers and Partners

If you are one of our Customers or Partners (or a representative of one of our Customers or Partners), we collect the following information from you, and process it for the following purposes (based on the following legal basis if you are located in the UK / European Economic Area (“EEA”)):

• Name
• Email
• Browser information
• Geographic data
• Payment Information from Partners

Customers and Partners wishing to opt out of receiving information from Liftoff can click “UNSUBSCRIBE” in marketing emails or email us at [email protected] or [email protected].

We also collect certain types of information automatically through the use of Cookies as outlined below and other similar tracking technologies. These tracking technologies enable us to personalize the Services to Customers.

When you provide us with personal information about your contacts we will only use this information for the specific reason for which it is provided in order to reach out to the individual nominated as a mobile hero. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at [email protected] or [email protected].

B. Information We Collect and Use About Targeted End Users When They Interact With Our Customers’ Mobile Applications

If you are a Targeted End User, we collect certain device information provided by our advertising exchange Partners or our Customers which we process it for the following purposes (based on the following legal basis if you are located in the UK / EEA):

In pursuit of the above purposes, we do the following:

• Match and combine data from other data sources: Information about your activity on a Customer’s app service may be matched and combined with other information relating to you and originating from various sources (for instance your activity on a separate online service, your use of a loyalty card in-store, or your answers to a survey), in support of the purposes explained in this notice;
• Link different devices: In support of the purposes explained in this notice, your device might be considered as likely linked to other devices that belong to you or your household (for instance because you are logged in to the same service on both your phone and your computer, or because you may use the same Internet connection on both devices);
• Identify devices based on information transmitted automatically: Your device might be distinguished from other devices based on information it automatically sends when accessing the Internet (for instance, the IP address of your Internet connection or the type of browser you are using) in support of the purposes exposed in this notice;
• Use precise geolocation data: With your acceptance, your precise location (within a radius of less than 500 metres) may be used in support of the purposes explained in this notice.
• Actively scan device characteristics for identification: With your acceptance, certain characteristics specific to your device might be requested and used to distinguish it from other devices (such as the installed fonts or plugins, the resolution of your screen) in support of the purposes explained in this notice.

Our Privacy Principles for the use of data about Targeted End Users

• Liftoff’s systems aggregate events/data at granularities that cover many users, as opposed to a specific user, unless the user consents. For instance: users with iPhone X’s in San Francisco have clicked on ads in app A 100 times and installed app B 50 times.
• Liftoff does not tie together events/data across apps in a user-specific way, without the user’s consent. For instance: we do not track that a person did X in app A and also Y in app B from a different publisher, if the person opts-out of interest-based advertising.

• Instead, Liftoff only ties events/data from a given specific user within the context of a given app. E.g. user with app-local ID 123 installed app A, then finished the tutorial, then made a purchase.
• This allows Liftoff to understand the conversion rates from one event to another within an app, but not track the activities of a user across different apps.

• Liftoff does not record or store personal information that the user cannot easily revoke, such as email address, physical address, photographs or phone number to personalize our advertising. Liftoff relies upon device IDs to uniquely identify a user, and Liftoff solely relies upon the user’s consent in allowing Liftoff to access this information.
• Liftoff does not export per-user data outside of Liftoff, except for validation purposes to a company that already has access to that data
• Details of how to opt-out of interest based advertising from us can be found at: https://liftoff.cn/opt-out/.

C. Information You Provide to Us via Our Site

When you visit our Site, we collect the following information from you, and process it for the following purposes (based on the following legal basis if you are located in the UK / EEA):

If you do not want to receive any communications from us (as set out in the table above), please indicate this by contacting us at [email protected] or [email protected]. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.

Additionally, you may sign up to receive reports and communications from us by following the “Join Our Newsletter” link on our Site. If you would like to opt-out of receiving any information that you receive from us, such as our newsletter, you may update your email preferences by using the “UNSUBSCRIBE” link found in emails we send to you or at your member profile on our Site or by contacting us at [email protected] or [email protected].

User Data Supplementation

We may receive information about you from other sources as required in connection with our legitimate interests, including publicly available databases or third parties from whom we have purchased data (including marketing data). We combine this data with information we already have about you to help us to update, expand and analyze our records, identify new Customers, deliver our marketing services and provide more tailored advertising, products and Services.  If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Cookies and Tracking Technologies

Liftoff and our partners use cookies or similar technologies to analyze trends, administer the Site, track users’ movements around our Site, and to gather demographic information about our user base as a whole. A full list of cookies we use on this site is found on our Cookie Policy.

You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Site or Services.

Automated decision making

We perform the following automated decision making processes using your personal information:

• To build lookalike targeting models to target users who are similar to the Customer’s existing users. Our Machine Learning does this automatically for every Customer. The more upfront device IDs Liftoff has, the more beneficial this is.
• For power predictive ML features e.g. users who have purchased in the past are much more likely to purchase again in the future
• To exclude existing users from User Acquisition campaigns, and power targeting rules for re-engagement campaigns e.g. target users who have registered but not purchased.

Information Related to Data Collected through the Service

If you are using our analytics platform, the use of information collected through our service shall be limited to the purpose of providing the Service for which you have engaged Liftoff Mobile, Inc.

Liftoff collects information under the direction of its Customers, and has no direct relationship with the individuals whose personal information it processes. If you are a Targeted End Users of one of our Customers and would no longer like to be contacted by one of our Customers that use our service, please contact the Customer that you interact with directly.  We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Customers.

We acknowledge that you have the right to access your personal information. A Targeted End User who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Liftoff’s Customer (the data controller). If requested to remove data we will respond within a reasonable timeframe.

We will retain personal information we process on behalf of our Customers for as long as needed to provide services to our Customer. Liftoff will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

IV. INTERNATIONAL TRANSFERS

As we are based in the United States, if you are located outside the United States and provide personal information to us, or to one of our group companies, your information will be transferred to us in the United States in accordance with this privacy policy.

Data Privacy Framework

Liftoff Mobile, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. We have certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, we commit to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Liftoff Mobile, Inc. at: [email protected]. We commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS an alternative dispute resolution provider based in the United States.  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit www.jamsadr.com/eu-us-data-privacy-framework for more information or to file a complaint.  The services of JAMS are provided at no cost to you. If your complaint is not resolved by us or by JAMS, you may, under certain conditions, invoke binding arbitration for complaints regarding compliance with the EU-U.S. DPF and the Swiss-U.S. DPF. Please see here for additional information.

In the event we transfer your data to third parties which perform services on our behalf, we shall remain liable under the EU-U.S. DPF Principles and Swiss-U.S. DPF Principles if the third party processes your personal information in a manner inconsistent with these Principles, unless we prove we are not responsible for the event giving rise to any damage.

The Federal Trade Commission has jurisdiction over our compliance with the EU-U.S. DPF and the Swiss-U.S. DPF. We may be required to disclose personal information we handle under the EU-U.S. DPF and the Swiss-U.S. DPF in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Other international transfers

If you are based in the United Kingdom or European Economic Area, please note that we may also transfer personal information that we collect from you to third party data processors located in countries that are outside of the United Kingdom or European Economic Area (including to the United States) or to members of our group of companies (including to the following entities based in the following countries: Liftoff Mobile Pte Ltd in Singapore and Liftoff Mobile KK in Japan) in connection with the above purposes.

If you are based in the United Kingdom or European Economic Area, please note that we may also transfer personal information that we collect from you to third party data processors located in countries that are outside of the United Kingdom or European Economic Area (including to the United States) or to members of our group of companies (including to the following entities based in the following countries: Liftoff Mobile Pte Ltd in Singapore and Liftoff Mobile KK in Japan) in connection with the above purposes.

Please be aware that countries which are outside the United Kingdom or the European Economic Area may not offer the same level of data protection, although our collection, storage and use of your personal data will continue to be governed by this privacy policy.

If we provide any personal information about you to any such non-UK and non-EEA members of our group of companies or third parties, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy. These measures may include the following:

1. ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, or by the European Commission in the case of transfers out of the EEA, which means that the recipient country is deemed to provide adequate protection for such personal data; or
2. having in place standard model contractual arrangements with the recipient which have been approved by the European Commission or the UK Government (as applicable). These model contractual clauses include certain safeguards to protect the personal data.

Further details on the steps we take to protect your personal information in these cases is available from us on request by contacting us by email at [email protected] or [email protected].

V. HOW WE SHARE YOUR PERSONAL INFORMATION AND WHO WE SHARE IT WITH

Sharing of Information We Collect

We neither rent nor sell your personal information in personally identifiable form to anyone. However, we do share your personal information with third parties as described in Section III and in this Section. If you have consented to us sharing your personal information but later change your mind, you may contact us and we will cease any such activity.

Affiliated Businesses and Third Party Websites We Do Not Control

In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through the Services (either alone or jointly with us). You will be able to recognize when an affiliated business is associated with such a transaction or service, and we will share your personal information with that affiliated business only to the extent that it is necessary and related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies. This privacy policy applies only to personal information that we collect through the Site and Services. If you have any questions about these practices, please contact us at [email protected] or [email protected].

Service Providers

We employ third party companies and people, for example cloud service providers (“Third Party Service Providers”), such as Amazon Web Services, Dropbox, Salesforce and Unity Technologies to perform tasks e.g., provide computer and network infrastructure services on our behalf or as advertising exchange partners and we may need to share your information with them to provide products or Services to you. We only share your personal information with Third Party Service Providers to the extent necessary for them to assist us and they do not have any right to use your personal information we share with them beyond what is necessary to assist us. We may also work with Google to deliver the best advertising opportunities to its clients through the use of remarketing tags. Traffic Clients and other data subjects can consult Google’s policies to learn more about Google’s processing policies here.

Third Party Digital Advertising Partners

If you are a Targeted End User, we will share data about you with Partners, to be used by those Partners for advertising-related purposes, including establishing (on behalf of advertisers) whether to bid on the opportunity to show you ads. When we share data in this manner, we will also share with the relevant Partner details about whether you have consented to, or objected to, the use of your data by the Partner for specified purposes.

Group Companies

We may provide your personal information to our subsidiaries or affiliated companies for the purpose of processing personal information on our behalf to provide the Site and the Services to you. These parties are required to process such information based on our instructions and in accordance with this privacy policy. They do not have any independent right to share this information.

Compliance with laws and legal proceedings

We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Merger or Acquisition

If Liftoff Mobile, Inc. or any of its subsidiaries are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

VI. SECURITY

The security of your personal information is important to us.  Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us

We take appropriate steps to pseudonymize your personal data. For Targeted End Users, the advertising device IDs (which are the only per-user identifiers that we track, and can be reset by the user at any time) are SHA1-hashed before insertion. Since SHA1 is a one-way hashing algorithm, the original raw advertising device ID cannot be reverse-engineered from the hashed version.

If you have any questions about the security of your personal information, you can contact us at [email protected] or [email protected].

VII. DATA RETENTION

If you have provided us with personal information for the purposes of holding an account with us, we will retain your information (including personal information) for as long as your account is active or as needed to provide you Services.

If we hold information about you through any other means we shall only process this information for as long as is necessary for the purpose and in any event for no longer than 28 days.

Information relating to Targeted End Users is retained for 30 days in pseudonymized form before it is automatically deleted from our active database. Backups are stored indefinitely.

We will delete it after the timescales stated above, except we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

VIII. YOUR RIGHTS

Opting-out of interest-based advertising from Liftoff

As described in this privacy policy, third parties may use cookies and similar tracking technologies to collect information and infer your interests for interest-based advertising purposes. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements by clicking here(or if located in the European Union click here. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.

Refer to our opt out page for instructions on how to opt-out of interest-based advertising when you are a Targeted End User.

Data Subject Rights

• You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at [email protected] at any time. You have the following rights:

1. Right of access.  You have a right of access to any personal information we hold about you.  You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the UK or EEA.
2. Right to update your information.  You have a right to request an update to any of your personal information which is out of date or incorrect.
3. Right to delete your information.  You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us by email.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are, by contacting us by email.

4. Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us by email.  

• We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are by contacting us by email.

5. Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes.  If you exercise this right, we will stop using your personal information for this purpose.  
6. Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services.

• This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.

7. Right to object.  You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.

• We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make.

IX. CHILDREN’S PRIVACY

We do not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register for the Services (as that term is defined in our Terms of Use). If you are under 16, please do not attempt to use the Site or register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 may provide any personal information to us or use the Site or the Services. In the event that we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible unless your parent or guardian has provided us with their consent for your use of our Site or Services. If you believe that we might have any information from or about a child under 16, please contact us at [email protected] or [email protected].

X. CHANGES TO THIS PRIVACY POLICY

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

XI. COMPLAINTS, QUESTIONS AND SUGGESTIONS

We have a Data Protection Officer to assist with all queries regarding our processing of personal information.  who can be contacted at [email protected].

If you have complaints about our Site or Services, please contact us at: [email protected] or [email protected]. In the EEA, you may also make a complaint to the appropriate data protection authority for data protection matters or seek a remedy through local courts if you believe your rights have been breached.