Privacy Policy

TRUSTe Privacy Certification

Effective Date: May 31, 2016

Smaato, Inc., (“Smaato”, “we”, or “our”) values the privacy of our users, members, and others who visit and use our website www.smaato.com, our Software Development Kit (“SDK”), The Smaato Publisher Platform (“SPX”), and our Legacy Smaato Portal (the “Smaato Site”) (collectively or individually “Users” or “you“). The Smaato Site contains information regarding a variety of services offered by Smaato (collectively the “Service”). This Privacy Policy governs information you provide to us or that we learn from your use of the Smaato Site, and tells you how we may collect, use, and share this information.

Smaato has received TRUSTe’s Privacy Seal signifying that this Privacy Policy and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request. The TRUSTe program covers information that is collected through our Smaato Site, SDK, SPX Platform, and Legacy Smaato Portal.

Smaato complies with the U.S. – EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and, retention of personal data from the European Union member countries. Smaato certifies that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Smaato’s certification, please visit http://www.export.gov/safeharbor/.


The Information Smaato Collects

User Provided Information: When registering for an account or expressing an interest in obtaining additional information about Smaato or its Service, you may provide “personal information,” such as your name, mailing address, email address, telephone number, credit card number, and other billing information as needed. In addition, Smaato may give you the option to provide us with certain information about your business.

Cookies Information: When you visit the Smaato Site, we use cookies – a small text file containing a string of alphanumeric characters – to personalize your experience on the Smaato Site. Smaato may use both session cookies and persistent cookies. Persistent cookies, unlike session cookies, remain after you close your browser, and may be used by your browser on subsequent visits to the Smaato Site. Using persistent cookies, we can “remember” what you have done on the Smaato Site previously and personalize our Site for you. Cookies may be disabled through your browser settings. Please note that disabling cookies may prevent you from accessing some of the Smaato Site’s functionalities and offerings.

Automatically Collected Information: When you visit the Smaato Site or open one of our HTML emails, we may record certain information from your browser through clear gifs/web beacons or similar technologies. This “automatically collected” information may include your Internet Protocol address (“IP Address”), browser type, the web pages or sites that you visit just before or after the Smaato Site, the pages you view on our Site, and the dates and times that you visit.

When your end users connect to the Service on their mobile devices, Smaato may automatically receive, from their mobile phone service providers, information about their device such as, but not limited to: unique mobile device number (a number uniquely allocated to user device by the device manufacturer), IP Address, geo-location of your device (using GPS or a different geo-location data), International Mobile Equipment Identity (IMEI), device type (e.g. smartphone, tablet), operating system (e.g. Android, Windows, iOS, Blackberry), network provider, mobile browser (e.g. Mozilla, Safari, Internet Explorer, Chrome), the carrier user ID (a number uniquely allocated to you by your network provider), and/or other unique identifiers for their devices (“Mobile Device Information”). For the avoidance of doubt, your end users are not “Users” covered by this Privacy Policy. Any information that you collect from your end users is governed by your own privacy policy, if any, and not this Privacy Policy.


The Way Smaato Uses Information

Smaato uses the collected information:

  • to provide and improve the Smaato Site and Service;
  • to fulfill your requests regarding the Smaato Site and/or the Service; and
  • to send you newsletters, and to contact you about special offers, new products, and services.

If you no longer wish to receive our newsletters, please click the “Unsubscribe” link within the email, access the email preferences in your account settings, or contact us at privacy@smaato.com. We will also use your email address for non-marketing or administrative purposes, such as notifying you of major Site and Service updates.

Smaato may use all of the information that we collect from our Users:

  • to understand the usage trends and preferences;
  • to improve the Smaato Site and Service’s appearance, features, and functionality; and
  • to improve our marketing and promotional efforts.

When Smaato Discloses Information

Smaato may disclose both personally identifiable and automatically collected information to affiliated companies, service providers, or other businesses or persons to:

  • process such information on our behalf;
  • to perform website maintenance and security functions; and
  • to improve the appearance, features, and functionality of the Smaato Site and Service.

We use reasonable efforts to: (i) see that these parties process such information in compliance with our Privacy Policy, (ii) limit their use of such information to the extent necessary to provide these services to us, and (iii) see that these parties use appropriate confidentiality and security measures.

We may also share automatically collected and other aggregated, non-personally-identifiable information with third parties to understand the usage patterns for certain content, services, advertisements, promotions, and/or functionality on the Service and the Smaato Site.

Except as otherwise noted in this Privacy Policy, Smaato does not share personal information about Users with third parties unless doing so is appropriate to carry out a User’s request; is legally required; or Smaato reasonably believes such disclosure is necessary to protect Smaato’s property, other legal rights, or the rights or property of others. We do not share your personal information with other third-party organizations for their marketing or promotional use without your consent, or except as part of a specific program or feature for which you have the ability to opt-in.


User Profile and Password

You have access to your personal information, and you may update, correct, or delete your member information and email preferences at any time by logging into your account, or by e-mailing Smaato at support@smaato.com with your request. To protect your privacy and security, we take reasonable steps to verify your identity before granting Users profile access. YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF YOUR UNIQUE PASSWORD AND ACCOUNT INFORMATION AT ALL TIMES.


Children

Consistent with the federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will not knowingly collect personal information from anyone under the age of thirteen (13) (hereafter “Children Information”). If we become aware that Smaato has collected or received such Children Information, we will immediately remove such information from Smaato’s records.

The Federal Trade Commission’s guidance and FAQs relating to COPPA are located at https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions.


Third-Party Advertisers and Links to Other Sites

Smaato allows third-party ad servers or ad networks to serve advertisements within the Smaato Site. These third-parties may send, directly to your browser, advertisements and links that appear within the Smaato Site. They may automatically receive your IP Address when this happens, and use certain tracking technologies (such as, but not limited to, cookies, JavaScript, and/or web beacons), which track your browsing activities and interests, to measure the effectiveness of their advertisements, and personalize their advertising content.

Smaato does not provide any of your personal information to these third-party ad servers or ad networks without your consent, or except as part of a specific program or feature for which you have the ability to opt-in. However, please note that if an advertiser asks Smaato to show an advertisement to a certain audience or audience segment and you respond to that advertisement, the advertiser or ad-server may conclude that you fit the description of the audience they were trying to reach. If you do not wish to have this information used for the purpose of serving you interest-based advertisements, you may opt-out by clicking http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices/; or if you are located in the European Union, click http://www.youronlinechoices.eu/).

Smaato’s Privacy Policy does not apply to, and we cannot control the activities of, such other advertisers or websites. Please consult the respective privacy policies of these third-party ad servers or ad networks.


Our Commitment to Data Security

No data transmissions over the Internet can be guaranteed 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems. We use secure server software (SSL) and firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software. You can help to ensure the security of your information by taking simple precautions such as preventing unauthorized access to your log-in information, and sign off of your account when you are finished using your computer.

If Smaato learns of a security systems breach, we may attempt to notify you via the most recent email address we have on file, or post a notice on the Smaato Site. Depending on where you live, you may have a legal right to receive a security breach notice in writing. To receive a free, written, security breach notice (or to withdraw your consent from receiving electronic notice), please contact us at privacy@smaato.com.


In the Event of Merger or Sale

If Smaato should ever file for bankruptcy or have its assets or stock sold to or merged with another entity, the information Smaato receives from you through the Smaato Site is a Smaato asset and may be transferred to any such entity. You will be notified via email and/or a prominent notice on the Site of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.


Changes and Updates to this Privacy Policy

We may occasionally update this Privacy Policy to reflect changes to our privacy practices. The amended Privacy Policy will be displayed on our Site. If we make any material changes, we will notify you by means of a notice on the Smaato Site, prior to the changes becoming effective. Please check our Privacy Policy regularly to ensure you have read the latest version and to stay informed of our privacy practices. Your continued use of the Smaato Site constitutes your agreement to this Privacy Policy and any updates.


Contacting Smaato

If you have any questions, comments, or concerns about this Privacy Policy, please email us at privacy@smaato.com, or contact us at:

Smaato, Inc.
240 Stockton Street, 10th Floor
San Francisco, CA 94108

+1 (650) 286-1198 (AMERICAS)
+49 (0)40 3480 9490 (EMEA)
+65 3157 1444 (APAC).