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Velti mGage® Advertising Services Suite Privacy Practices Statement for Customers

Velti mGage® advertising services consist of (i) a buy-side ad server for mobile ("Velti mGage® Advertise") and (ii) a reporting dashboard ("Velti mGage® Visualize"), collectively referred to as the "Advertising Services Suite."The Advertising Services Suite is provided by Velti Inc. and its affiliates ("Velti", "us", or "we") to an entity that has signed a platform services agreement to utilize services(s) in the Advertising Services Suite ("Customer"). Velti's Advertising Services Suite allows Customers to centrally manage mobile advertising campaigns across multiple mobile websites or applications and advertisingnetworks. A mobile website or application that displays advertisements is also known as apublisher ("Publishers").This Privacy Practices Statement ("Statement") describes the information collection and use by Velti for Customers through the Advertising Services Suite.

On behalf of each Customer that utilizes the Advertising Services Suite, Velti will collect information from mobile Publishers and advertising networks about an end-user that accesses a Publisher that serves advertisements ("User"). This Statement does not describe the privacy practices of third parties, including, but not limited to Customers, advertisers, advertising exchanges, or Publishers. This Statement only applies to the data collected through services included within the Advertising Services Suite and does not apply to any other Velti services or service.

Information Collection

We are the service provider that will collect and compile User advertising and analytics data to be delivered to the Customer.

In some jurisdictions, information collected may be considered personal information.Information collected includes, but is not limited to:

  • Velti mGage® Advertise:

    impressions, clicks, mobile device information, and geo-data. Such information allows Customers to gain insights such as understanding the performance of advertising campaigns and the ability to deliver more effective campaigns.

  • Velti mGage® Visualize:

    website behavior and consumption, such as: post-click conversions, outlinks, downloads, visit-related information, provider, unique visitors, referrer, location.

  • Third Party Information:

    We may also periodically obtain information about Users from other Velti businesses, subsidiaries, divisions, business partners, contractors, affiliates, advisors, service providers, independent application developers, and other third parties.

  • Information Collected from Advertising Services Suite Customers:

    Velti accepts personal information under the terms of agreements with Advertising Services Suite Customers as well as clients of such Customers. This information is collected when a Customer enters into an agreement to utilize Advertising Services Suite Services with Velti or when such services are provided pursuant to an agreement between a Customer and its clients.

Technology Used for Information Collection

We use various technologies to collect information aboutUser activities for the Advertising Services Suite:

  • Advertisement Request Inspection:

    When an advertisement request is received, we examine incoming data, such as, but not limited to, the http header, content, time, session id, device and operating system, as well as other information defined by a unique identifier.

  • Cookies, Web Beacons, Javascript Code, or Pixel Tags:

    Velti may use standard Internet technologies such as, but not limited to, cookies, web beacons (or "clear gifs"), Javascript code, and pixel tags and other similar technologies, to gather and aggregate information to gauge the effectiveness of mobile advertisements delivered. Javascript tags can be configured to collect additional metrics when requested by a Customer.

  • Log Files and Web Requests:

    Information from a User's browser is automatically collected when a User visits mobile websites with advertisements served by Velti.

  • Clicks:

    When a User clicks on an advertisement, a click event is created. After clicking, a User is taken to a mobile website or another action may be initiated as a result of the click, such as generating a phone call or initiating a download of a mobile application. Such an action is recorded by Velti through a click event.

Sharing of User Information.

As the third party service provider engaged by Customers, Velti will provide User information to Customers as well as clients of Customers through the Velti mGage® Visualize dashboard. The information made available through the Velti mGage® Visualize dashboard for Customers is shared for the purpose of evaluating advertising campaigns and their effectiveness with the target audience.

In addition, Velti will also share User information under the following circumstances:

  • Business Transfers:

    If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information that we have collected from Users to the acquiring company.

  • In Response to Legal Process:

    We may disclose the information we collect from Users to comply with the law, a judicial proceeding, court order or other legal process, such as in response to a subpoena.

  • To Protect Us and Others:

    We may disclose information where we believe that it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of this Statement.

  • For Internal Purposes:

    Velti also shares information internally and with its affiliates to gain insights and improve Velti Services, including for the development and delivery of targeted advertising.

Content Restrictions.

Velti does not knowingly accept advertisements or place advertisements on a mobile website or application if such advertisement is intended to damage or render inoperable software, hardware or security measures of an Advertiser, any User, Velti, or any other third party through use of viruses, worms, corrupted files, cracks or other materials.

Information from Third Parties.

To provide services, Velti interacts with advertising exchanges, Publishers, and advertisers. All of these third parties collect or receive User information from or for Velti to perform its services. Velti only accepts information from these third parties with consent from such third parties. Velti does not make any guarantees about the privacy practices of any of these third parties. Users should read the privacy policy of each Publisher or Advertiser to understand how it collects, uses, and shares information. Although Velti encourages third parties that Velti interacts with to disclose Velti's privacy practices in connection with data collection, Velti is not responsible or liable for any other third party's privacy practices, including the privacy practices of a Publisher, an advertiser, or other business partners.

Opt-out by Velti.

Velti honors User tracking and opt-out preferences specified through mobile operating system device User settings (i.e. the Apple Identifier framework). For Velti mGage® Visualize based data collection from a particular site, Velti provides opt-out technology to third parties to make available to Users to opt-out of data collection by Velti from such particular site.

Information relating to Children.

If we gain actual knowledge that we have received personal information from children, we will use reasonable efforts to remove that information from our records.

Security.

Velti protects User information through taking reasonable physical, electronic, or procedural security measures appropriate to the sensitivity of the information in its control. These measures include safeguards to protect data against loss or theft, as well as unauthorized access, disclosure, copying, use and modification. If we collect information using any Velti technology, then we will use industry-standard practices to safeguard that information. Velti makes commercially reasonable efforts to make the collection and security of such information consistent with this Statement and all applicable laws and regulations.

Storage, Retention and Accuracy of Information.

Velti ensures that any information collected is safeguarded against loss, access, use, modification, disclosure, or other misuse. We take reasonable steps appropriate to the sensitivity of the information to prevent unauthorized use or disclosure of User information. Velti stores information as long as necessary to fulfill its business purposes.

Transfer of Information.

By using Velti's Advertising Services Suite, Customers and Customer's clients consent to gaining Users consent of information being transferred to, stored, and processed internationally where our servers are located and our central databases are operated.

Material Changes to Policy:

We may make changes to this Statement from time to time. If we make any material or substantive changes, we will post a notice of those changes in this Statement.

Contact Information:

For questions or concerns relating to privacy, please send us an email at privacy2@velti.com. Or you may contact us at: Legal Department, Velti Inc., Steuart Tower, One Market Street, Suite 600, San Francisco, CA 94105.