Last Updated: September 15th, 2016.
Opera Mediaworks Inc. and its associated business units (“Opera Mediaworks” or “we”, “us”, “our”) is a technology company that creates and delivers advertisements to mobile devices. This privacy statement (“the Policy”) explains what kinds of information we collect and how Opera Mediaworks strives to collect, use and disclose information in a manner consistent with the laws of the countries in which it does business. This Policy applies to our advertising platform (the “Platform”) our advertising mediation service (the “Service”) as well as our websites located at http://www.operamediaworks.com/, http://www.adcolony.com/, http://www.mobilike.com/, and http://www.fourthscreen.com (collectively, our “Websites”). Opera Mediaworks is strongly committed to protecting the privacy of visitors to our Websites and other Internet users (“Users”). If you have any concerns about this Policy, or your privacy when your business or mobile device accesses our Service, please send an email to firstname.lastname@example.org and we will try to address your concern. If you would like to understand the privacy practices that pertain to the Opera browser, please click here.
Website Privacy Practices
PERSONALLY IDENTIFIABLE INFORMATION (PII)
Opera Mediaworks collects personally identifiable information (“PII”) when you choose to provide it to us. PII is any information that specifically identifies or locates a particular person or entity. We receive and store any PII you provide to us. The types of PII collected may include your name, postal address, telephone number, and email address. For example, you may choose to send PII about yourself in an email, by completing an online form on the Websites, or by signing up for our service or e-newsletter. You may also provide us with PII in order to setup an account with us. Opera Mediaworks uses this information for our reasonable business purposes, including to contact you to respond to your inquiry, to provide the service requested or to maintain your account with us. Once obtained, Opera Mediaworks will store your PII for as long as needed to provide services and for a reasonable time thereafter for record keeping purposes.
NON-PERSONALLY IDENTIFIABLE INFORMATION
Opera Mediaworks also collects non-personally identifiable information (“Non-PII”) from our Websites. Non-PII is pseudonymous information that cannot by itself be used to specifically identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to the Websites, the referring URL and your computer’s operating system. We use this information to help manage and improve the Websites.
We may utilize “cookies” to automatically collect information about visitors to the Websites. Cookies are alphanumeric identifiers that reside within your browser and that allow us to recognize your browser and tell us how and when pages on our Websites are visited and by how many people. Our cookies do not collect PII. You may be able to change the preferences on your browser to prevent or limit your computer’s or mobile device’s acceptance of cookies, but this may prevent you from taking advantage of some features of the Websites. We may also collect information on our Websites using Web “beacons.” Web beacons are electronic images used on the Websites or in our emails. We use web beacons to deliver cookies, count visits, understand usage and activity on the Website and to tell if an email has been opened and acted upon. For more information about cookies and web beacons, please visit http://www.allaboutcookies.org/cookies/.
CONTROLLING OUR USE OF THE PII COLLECTED VIA THE WEBSITE
You can always opt not to disclose PII to us, but keep in mind some PII may be needed to take advantage of some features of the Websites. You may request deletion of your PII by sending an e-mail to email@example.com.
OVERVIEW OF OPERA MEDIAWORKS’ PLATFORM & SERVICES
Opera Mediaworks provides an advertising technology platform (our “Platform”) and advertising mediation service (our “Service”) to connect mobile application and website publishers (collectively, “Mobile Apps and Sites”) with advertisers. Our Platform facilitates the efficient serving of advertisements on Mobile Apps and Sites by collecting information across multiple non-affiliated Mobile Sites and Apps. Our Platform and Service obtains information from Mobile Apps and Sites in order to deliver, tailor and report on the ads being run across our advertising network and Platform by advertisers (our “Clients”).
INFORMATION COLLECTED BY OUR TECHNOLOGY PLATFORM
In the course of running our Platform and Services, we collect information from Mobile Apps and Sites and use such data for a number of purposes.
- Our technology Platform collects and uses Non-PII, including but not limited to: the name of the Mobile Apps and Sites on which the advertisement is served, the IP address used to access the Internet, device identifiers (e.g, Android Advertising ID), the type of phone or other mobile device used (e.g., iPhone, iPad etc.), the operating system (e.g., iOS), the date and time a particular ad is served, whether one of the ads we facilitate was delivered and, if applicable, a record if that ad was “clicked” or if it originated a follow-up action to a third party e.g, “conversion” event. We also collect Non-PII to help us optimize and/or refrain from advertising for a Mobile App that is already downloaded onto a device.
- Our technology Platform also collects and uses location data about a device from Mobile Apps and Sites and advertising exchanges and may match the device location to certain residential or commercial points of interest such as a “household”, “neighborhood”, “coffee shop” or “Sports arena” for interest based advertising, ad targeting, analytics and market research purposes.
- We sometimes work with third-party data partners and advertising exchanges to enhance our advertising and targeting capabilities on the Platform. As determined by our partners’ business and privacy policies, we may also receive and retain information from partners’ Mobile Apps and Sites including but not limited to: the current location of the device, third party applications on the device or in use at the time of our advertising transaction with the device, the Users age, gender or other demographic indicator, and we may use or derive PII obtained from third parties such as street address to help match data sets, although such PII is processed outside of our Platform.
- We also collect Non-PII over time and across multiple Mobile Apps and Sites and use Non-PII to provide reports to advertisers and others and to help us display advertisements that may be of interest to Users. Based on the privacy rules of the site /application owner and their business agreement with Opera Mediaworks, we may integrate this Information with that acquired from other application owners or websites. In places outside of the United States, Canada and the EU, we may receive non-PII interest segments from the Opera Mini browser. This information is then used to deliver advertisements and promotional information to the specific device identified based on the User’s online behavior or interests. This activity, called online behavioral advertising or interest based advertising, is enabled by the information collected. The information may be controlled by the User via our online tools and “opt out” mechanism at www.operamediaworks.com/choices. For more information, please scroll down to “choices regarding ad targeting”. • We enable Clients to match their own Non-PII derived via CRM data sets with our Non-PII data for use on the Platform via third-party service providers. In some instances, we conduct this data matching internally. In either case, we take reasonable steps to ensure that any PII that comes in from Clients via their CRM databases is walled off from the digital ad serving functions. Once matched, we use that Non-PII to target ads, for analytics and market research purposes.
Opera Mediaworks complies with the Digital Advertising Alliance (DAA) Self-Regulatory Code.
CHOICES REGARDING AD TARGETING AND DATA USE
Opera Mediaworks offers multiple choice mechanism that enables Users to opt-out of Opera Mediaworks’ use of information for interest based advertising as well as certain uses of precise location. We do not currently respond to browser based Do Not Track signals. Please note that you will continue to receive advertising after you opt-out, but it may not be tailored to your interests. Please also note that our opt-out mechanism is browser and device specific. Therefore, if you use multiple browsers and/or devices you will need to perform the opt-out operation for each browser or device. Certain devices and device configurations may prevent our opt-out from operating correctly.
Opt-out from our interest based advertising services on mobile apps. We honor the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). For devices where we are able to see that such a selection has been made, we will not track your future activities for the purposes of serving interest based advertising.
Precise Location Choices. If you’d like to adjust your choices regarding the use of precise location data by third parties such as Opera Mediaworks, you may do so via your device settings. For your convenience, we provide links to instructions for both Apple iOS and Android devices. Also, most mobile applications that collect precise location information offer mechanisms to control the collection and use of precise location information. Please note that these choice mechanisms won’t impact previously collected precise location information.
Opt-out from our partner’s interest based advertising services. Many of our partner’s that enable targeted advertising are members of one or more digital advertising industry self-regulatory programs. You may click below for the Network Advertising Initiative (“NAI”) and Digital Advertising Alliance (“DAA”) opt-out tools to learn more about targeted or interest based advertising and to opt out of certain targeting programs.
HOW WE SHARE INFORMATION ONWARD TRANSFER OF DATA
Opera Mediaworks may share information with trusted third-party partners. These third party contractors are prohibited from using the information for purposes other than performing services for Opera Mediaworks.
The company may share Non-PII data collected via our Platform. For example, we provide our Clients with information about how many Users view or click the advertising served using our Platform. Similarly, we may share some Non-PII with the Mobile Apps and Sites on which we serve ads in order to optimize and report on the delivery of those ads. This information cannot be used to contact or identify any person individually, but may be considered personal data in some jurisdictions.
Opera Mediaworks may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Opera Mediaworks may also disclose your information to third parties when obligated to do so by law and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person.
Finally, Opera Mediaworks may transfer information, including any personally identifiable information, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If Opera Mediaworks is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via a notice on our Websites of any change in ownership or uses of your PII, as well as any choices you may have regarding your PII.
In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Opera Mediaworks is potentially liable.
Security – The security of your information is important to us. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. However, due to the inherent nature of the Internet as an open global communications means, we cannot guarantee that your information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely secure from intrusion by others, such as hackers. If you contact us by e-mail, a “contact us” or a similar feature on our Web site, you should be aware that your transmission might not be secure and that a third party could view information you send by these methods in transit.
Children – Opera Mediaworks adheres to the Children’s Online Privacy Protection Act. We do not knowingly create nor use any interest based advertising segments of children under 13 as part of our Services. Our Website is not directed at children under the age of 13. If we are made aware that we have received PII from someone under 13, we will use reasonable efforts to remove that information from our records.
Access – You have a right to access to your Personal Information and you may update, correct, or delete your account information and email preferences at any time by logging-in to your account and changing the information on file or by e-mailing Opera Mediaworks at firstname.lastname@example.org with your request. To protect your privacy and security, we take reasonable steps to verify your identity before granting Users profile access. Similarly, if you’ve provided us with PII via the Websites, you may send us an email at email@example.com and we will respond within a reasonable time.
Data Integrity, Purpose Limitation– We process information in a way that is compatible with and relevant for the purpose for which it was collected as described above. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
Data Retention – We store PII such as email address, telephone number or billing details for so long as you continue to have a business relationship with Opera Mediaworks and for a reasonable time thereafter for record keeping purposes. You may ask us to delete that information by following the instructions below. Where we store PII obtained from Client CRM files as described above, we use and retain such PII only as directed by our Clients. We store pseudonymous information such as device identifiers and cookie IDs so long as our systems continue to encounter a particular User. We store information collected via our Service for up to three years after which time this information gets archived.
Redress for EU and Swiss Citizens – In compliance with the U.S.-EU and U.S.-Swiss Safe Harbor Principles, Opera Mediaworks commits to resolve complaints about our collection or use of personal information. Citizens of the European Union or Switzerland with inquiries or complaints about our collection or use of personal information should first contact Opera Mediaworks at firstname.lastname@example.org.
Questions or comments regarding this Policy should be submitted to the Opera Mediaworks Privacy Office by mail or e-mail as follows:
Opera Mediaworks Privacy Office
1875 South Grant St. 8Th Floor
San Mateo CA 94402
ENFORCEMENT, PRIVACY COMPLAINTS BY EUROPEAN UNION AND SWISS CITIZENS
We have further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
We have further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by the privacy department at Opera Mediaworks, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.