"MRI” means the British Virgin Islands Company that is a exclusive agent of Revmob, authorized to operate the Revmob program with worldwide users.
“Program” means the mobile advertising program you are engaging, also referred to herein as an “advertising network” or solely “network”.
“Revmob” means the Brazilian company Pubmobile Intermediação de Publicidade e Propaganda Ltda that licensed the program for MRI to operate globally.
“Users” means any and all participants of the Program, also referred to as “participants”.
MRI and Revmob can also be collectively referred to as “We”.
Sources, Use and Disclosure of Data
In the operation of the Program, MRI and Revmob (or its partners and affiliates) may collect certain information from participants of the advertising network. Such personal or technical information is provided by the Users themselves according to the permissions granted by the Users, through automatic collection or the combination of both.
Information received from Users may be collected from the registration data the Users choose to submit or by any other way, such as email or telephone (“Login Personal Data”). In general, every information relied on the questionnaires is valuable for improving the Users' experience and as to customize and improve the Program and the Users' experience. Notwithstanding, we hereby inform that neither MRI nor Revmob share any Login Personal Data with third parties, as we only store them for means of registering the Users on our Program. In addition, we have signed strict non-disclosure agreements (“NDAs”) with our employees, partners and every other internal collaborators so that MRI and Revmob can assure that the same data protection standards (“Data Protection Standards”) we apply with third-parties are practiced on the day-to-day of both companies.
Our Data Protection Standards are compliant with the most advanced data protection regulations throughout the world, mainly the General Data Protection Regulation (“GDPR”) from the European Union. In case any of our Users have any doubts regarding our Data Protection Standards, they can contact us through email@example.com. We will gladly answer every question our Users have regarding how we use threat and share their personal data.
By sending an e-mail to the above address, Users and data subjects in general can request information with regards to (i) whether or not Ad Serving Data concerning them is being processed, and to access the stored Ad Serving Data; (ii) receiving Ad Serving Data in a structured, commonly used and machine-readable format; (iii) rectification of Ad Serving Data; (iv) requesting erasure of Ad Serving Data; (v) objecting to the processing of Ad Serving Data; (vi) Request to restrict processing of Ad Serving Data.
Information automatically collected derives from the Users interaction with the Program, apps and/or websites developed by Revmob and/or MRI or other sources (collectively referred to as “Apps”), such as tracking the apps and/or websites the Users have used, clicks on advertisements and ads, web browser, indexed data and the connection with the information received and stored. For means of clarification, other than the Login Personal Data, MRI and Revmob only collect and store from data subjects that interact with the Apps (i) general device and advertising identifiers; and (ii) IP Address and Geolocation (collectively referred to as “Ad Serving Data”).
Neither MRI nor Revmob apply any intelligence to the Ad Serving Data they collect in order to develop profiles from a user or practice any kind of behavioral advertising. The only purpose for collecting and storing Ad Serving Data is to enable (i) the delivery of mobile advertising ads through the Program and into the Apps (ii) and fraud analysis.
Ad Serving Data may be shared with third-parties for the only purpose of enabling the delivery of mobile advertising ads. Moreover, Ad Serving Data is shared in a manner that it is impossible for those third parties to identify the data subjects of the Apps or their identities. Our Data Protection Standards require that Revmob or MRI, as applicable, apply constant contractual efforts to make sure that third-parties are also compliant with GDPR and other major regulations, mainly with regards to full transparency towards data subjects and other principles of data protection (for instance, we require them to keep records regarding the purposes, destination and mechanisms through which Ad Serving Data is shared with their partners, as well as any opt-ins/opt-outs regarding the foregoing data subjects).
In case any of our Users do not want Revmob or MRI to apply any use for their data (such as newsletters, e-mails containing marketing content etc.), both companies are prepared for the immediate cease of this use. To assure the foregoing statement, Users shall contact the following e-mail addresses:
Revmob and MRI Online Account Holders should edit their online profile to correct any inaccurate information and to keep the information current, complete and accurate. If there are further issues with the accuracy of information, consumers may contact Revmob and MRI at the addresses above for further resolution. Account Holders are responsible for all activity undertaken through their account or password, and for maintaining the security of their password and other personal information. Account holders are not permitted to allow others to use their account or password assigned to them without the written permission of Revmob and MRI.
Security of Users' Data and Transfers
With respect to security: the Program contains appropriate security measures in place to protect against the loss, misuse or alteration of information that it has collected from Users.
Revmob or MRI may transfer the Ad Serving Data they collect to countries other than the country where the foregoing data were originally collected for the purposes ad serving and mobile advertising. Those countries may not have the data protection standards as of GDPR, for instance. Notwithstanding, Revmob and MRI will protect Ad Serving Data and take steps, where necessary, to ensure that international transfers comply with Data Protection Standards.
Ad Serving Data regarding Children
We do not knowingly collect any Ad Serving Data relating to children under 14 (fourteen) years old. In addition, we require third-parties to certify to us that their activities are not primarily directed to children. We also apply reasonable efforts to contractually require third-parties to ensure that their data protection practices comply with applicable privacy laws and requirements, such as safeguarding children's privacy (such as by complying with the U.S. Children's Online Privacy Protection Act of 1998).
Effectiveness and term of this Policy
May 25th, 2018