Privacy Policy for End Users
Verve Mobile (“Verve Mobile”, “Verve”, “we”, “us”) is committed to protecting consumer privacy and to clearly informing users about the collection and use of information when using our website and related services. As a result, we have put together this Privacy Policy to explain how we collect, disclose and use certain information relating to Verve Mobile´s generally available website located at www.vervemobile.com (“Site”) and related mobile advertising products and services (“Services”). This Privacy Policy applies to visitors or users of our Site and/or Mobile Offerings (“you” or “End User”). “Mobile Offerings” are applications that utilize Verve technology, including text messages, mobile applications and/or a mobile website. This Privacy Policy does not apply to operators or publishers of applications that use the Verve technology to deliver advertisements in Mobile Offerings (“Publishers”) or their use of the portal on the Site. If you are a Publisher or using such portal, please click here.
YOUR PERSONAL INFORMATION MAY BE PROCESSED BY US IN THE COUNTRY WHERE IT WAS COLLECTED AS WELL AS OTHER COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY. BY USING THIS SITE AND PROVIDING ANY PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TRANSFER OF DATA FROM YOUR COUNTRY TO A COUNTRY THAT HAS LESS STRINGENT LAWS, AND THE PROCESSING OF YOUR PERSONAL INFORMATION IN CONFORMANCE WITH THIS POLICY.
So we are clear about the terminology we are using, when we use the phrase “Personal Information” in this Privacy Policy, we mean contact information (e.g., name, address, email address, or telephone number) and any other non-public information that is used or intended to be used to personally identify an individual, as well as other non-public information that is associated with this Personal Information. When we use the phrase “Anonymous Information” in this Privacy Policy, we mean information that is neither used nor intended to be used to personally identify an individual.
By visiting the Site or using the Services, you are accepting the policies and practices described in this Privacy Policy. The Site is not intended for children under 13 years of age. You must be at least 13 years old to use the Site. We do not knowingly collect Personal Information from any child under 13 years of age.
This Policy describes our practices with respect to you or your company’s Personal Information. In particular, it defines: 1) what Personal Information we collect, 2) how we collect Personal Information, 3) how we use Personal Information, 4) how we protect Personal Information, 5) with who, if anyone, we share Personal Information, and 6) how you can access or correct Personal Information.
Your privacy is important to us. Should you have any questions about our privacy policy, contact us at privacy@vervemobile.com
By visiting the Site and/or using any Services, you agree to the terms of this Privacy Policy in full and without modification. If you do not agree to the terms of this Privacy Policy, you do not have the right to access the Site or to use any of the Services. If you visit the Site, your visit and any possible dispute over privacy is subject to this Privacy Policy and any applicable Terms of Service.
DATA COLLECTION AND USAGE
Personal Information
We only collect Personal Information when you knowingly and voluntarily provide it to us, such as when you provide us feedback or request information from us. You do not have to provide Personal Information to use our Services and we do not collect Personal Information through our Services. Verve Mobile does not collect the phone number or the unique device IDs for mobile devices. However, Verve Mobile may deliver advertising that is targeted based on location or other user-entered information. The advertisements delivered by Verve Mobile may include forms or other prompts that allow users to opt-in to share data. However, it is your choice whether or not to provide that data. For example, we may ask you to provide your precise location information (e.g. longitude and latitude determined by your device through GPS, wifi hotspots or cellular towers). If you elect to provide us this precise location information, we may deliver advertising to you based on this precise location information; if you elect not to provide the precise location information, we will not collect it. To be clear, in addition to precise location information, the prompts may ask you to provide other information, including Personal Information, which we will receive only if you provide it or consent to our receipt through the prompt. Verve Mobile tracks unique users through a unique but anonymous hashcode that cannot be tracked back to a device or any Personal Information. Verve Mobile does not collect nor store the unique device ID of a mobile device. Notwithstanding the foregoing, a Publisher’s Mobile Offering may include text messages, in which case the Publisher will provide Verve Mobile with the applicable phone numbers.
However, if you use a particular Publisher application or mobile website, that application or mobile website may independently collect information from you. Notably, this policy does not cover such information collected by a Publisher through its application or mobile website. When using a particular application or mobile website, you should familiarize yourself with the given Publisher’s terms and conditions and privacy practices. Verve Mobile is not responsible for, and cannot control, a given Publisher’s privacy practices. Publishers may use Verve Mobile technology to request Personal Information from you.
When you opt-in to provide Personal Information to Verve Mobile customers or partners, Verve Mobile restricts access to Personal Information to employees, contractors and agents who need to know the information in order to operate, develop or improve our services and to service our customers. We take all reasonable steps to ensure that these parties comply with confidentiality obligations and do not use such information for any purpose other than providing such services to a Publisher.
Anonymous Information
From Our Site:
We collect Anonymous Information automatically when you visit our Site both through the use of log files and alpha-numeric identifiers known as “cookies” that are usually stored on a user’s computer hard drive cookies. This Anonymous Information we collect via the Site includes your Internet Protocol address, browser type, browser language, device type and version and the date and time of your request. We also use “cookie” technology. We generally use cookies to help with customer tracking and to reduce the time it takes for pages to load into your browser. Our cookies do not contain Personal Information. We may use both session cookies (which expire once you close your web browser) and/or persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience. Persistent cookies can be removed or blocked by following the help file directions in your Internet browser. We also use log files and cookies to improve the quality of our Site and pages you have visited on the Site.
From Our Services:
Verve Mobile utilizes technology to uniquely identify most mobile devices to deliver better targeted marketing messages to consumers. We believe that the presentation of more relevant services assist in providing a more meaningful mobile web experience. For example, this technology enables Verve Mobile to limit the number of times a specific message is presented to a consumer (frequency capping), to support product category preferential marketing and to deliver advertising based on your general location (but not precise location) as determined, for example, through your IP address.
HOW WE DISCLOSE INFORMATION
Personal Information
Verve does not share your Personal Information except as provided in this Privacy Policy. We may disclose certain Personal Information:
- To third party contractors, agents, service providers and vendors who help us provide the Services or the Site, in which case we will take reasonable steps to ensure that these parties comply with confidentiality obligations and contractually require these parties only use the information as needed to provide services to us;
- To third parties to whom you ask or have authorized us to send Personal Information;
- To any subsidiary organizations, joint ventures, or other organizations under our control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy; or
- If we believe in good faith that such disclosure is necessary to (a) resolve disputes, investigate problems, or enforce our Terms of Use; (b) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity; or (c) protect and defend our rights or property or the rights and property of you or third parties.
In the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, we expect that any and all information that we have will be among the assets transferred. Verve will work in good faith to ensure these privacy rights or similar will be conveyed through any such purchase.
How Personal Information is Controlled or Corrected
In the event you provide us with Personal Information, you can review, correct or update that information, or request its deletion, by emailing us at privacy@vervemobile.com. Keep in mind, however, that even if you delete your Account, we may retain your Personal Information in conformance with our data retention policy, under which we may retain such information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law. There may be residual Personal Information that remains within our databases, access logs, and other records. Please remember, however, if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. You may request that we delete, stop using or stop collecting precise location information through the Services or, in some cases, using your mobile device or application settings.
How Personal Information is Protected
We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include firewalls and encryption, internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems. You should take further precautions to protect personal data by safeguarding your user name and password and by limiting the use of shared computers. All Personal Information is stored on our secure servers in the United States of America.
Links to Third-Party Sites
Verve Mobile’s website contains links to other websites. Verve Mobile is not responsible for the security and privacy practices of these websites. Specifically, the www.vervemobile.com website links to sites providing news coverage, to partner sites for case studies, and to industry association sites of which Verve Mobile is a member.
Information Disclosed to Third Parties
This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you. If you disclose information to others, including to Publishers, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.
Changes to Privacy Policy
Verve Mobile is committed to continually examining and reviewing its privacy practices, and may make changes to its Privacy Policy. In the event that any material changes are made to Verve’s privacy practices, we will promptly make changes to this Privacy Policy that disclose the changes and also send you notice to the last email address, if any, you have provided to us.
PRIVACY POLICY FOR PORTAL
Verve Mobile (“Verve Mobile”, “Verve”, “we”, “us”) is committed to protecting consumer privacy and to clearly informing users about the collection and use of information when using our website and related services. As a result, we have put together this Privacy Policy to explain how we collect, disclose and use certain information relating to Verve Mobile´s publisher portal located at www.verveMobile.com (“Portal”) and related mobile advertising products and services (“Services”). This Privacy Policy applies to operators or publishers of applications that use the Verve technology (“you” or “Publisher”) to deliver advertisements in Mobile Offerings, which include text messages, mobile applications and/or a mobile website. This Privacy Policy does not apply to “End Users” who are visitors or users of our generally available website or those Mobile Offerings.
YOUR PERSONAL INFORMATION MAY BE PROCESSED BY US IN THE COUNTRY WHERE IT WAS COLLECTED AS WELL AS OTHER COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY. BY USING THIS PORTAL AND PROVIDING ANY PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TRANSFER OF DATA FROM YOUR COUNTRY TO A COUNTRY THAT HAS LESS STRINGENT LAWS, AND THE PROCESSING OF YOUR PERSONAL INFORMATION IN CONFORMANCE WITH THIS POLICY.
So we are clear about the terminology we are using, when we use the phrase “Personal Information” in this Privacy Policy, we mean contact information (e.g., name, address, email address, or telephone number) and any other non-public information that is used or intended to be used to personally identify an individual, as well as other non-public information that is associated with this Personal Information. When we use the phrase “Anonymous Information” in this Privacy Policy, we mean information that is neither used nor intended to be used to personally identify an individual.
By visiting the Portal or using the Services, you are accepting the policies and practices described in this Privacy Policy. The Portal is not intended for children under 13 years of age. You must be at least 13 years old to use the Portal. We do not knowingly collect Personal Information from any child under 13 years of age.
This Policy describes our practices with respect to you or your company’s Personal Information. In particular, it defines: 1) what Personal Information we collect, 2) how we collect Personal Information, 3) how we use Personal Information, 4) how we protect Personal Information, 5) with who, if anyone, we share Personal Information, and 6) how you can access or correct Personal Information.
Your privacy is important to us. Should you have any questions about our privacy policy, contact us at privacy@vervemobile.com
By visiting the Portal and/or using any Services, you agree to the terms of this Privacy Policy in full and without modification. If you do not agree to the terms of this Privacy Policy, you do not have the right to access the Portal or to use any of the Services. If you visit the Portal, your visit and any possible dispute over privacy is subject to this Privacy Policy and any applicable Terms of Service.
DATA COLLECTION AND USAGE
Personal Information
We collect Personal Information when you knowingly provide it, including when you register for the Portal, provide feedback, or request information. For example, you may provide your e-mail address when you register on the Portal and create a user name and password for you account (“Account”). We use your Personal Information to administer your Account and provide you Services (including the display of customized content, identification, contact information and authentication), to send communications and administrative e-mails, to respond to your inquiries, and to send marketing and product update messages to those who request such messages. We may combine this information with other information about you that we receive from other sources, both on and offline, to improve the quality of our products and services and enhance your experience. We may use personally identifiable information in an aggregate form to gain a broader perspective of what preferences our users have and to measure interest in the various areas of the Portal.
You can opt-out of receiving certain e-mail communications from the Portal by clicking the “Unsubscribe” link at the bottom of each e-mail. Please note that even if you unsubscribe or opt-out, we may still send you Portal and Service related communications.
When you opt-in to provide Personal Information to Verve Mobile customers or partners, Verve Mobile restricts access to Personal Information to employees, contractors and agents who need to know the information in order to operate, develop or improve our services and to service our customers. We take all reasonable steps to ensure that these parties comply with confidentiality obligations and do not use such information for any purpose other than providing such services to a Publisher.
Anonymous Information
We collect Anonymous Information automatically when you visit our Portal both through the use of log files and alpha-numeric identifiers known as “cookies” that are usually stored on a user’s computer hard drive cookies. This Anonymous Information we collect via the Portal includes your Internet Protocol address, browser type, browser language and the date and time of your request. We also use “cookie” technology. Cookies enable us to “personalize” the Portals for each user and tell us how and when pages on our Portal are visited and by how many people. We generally use cookies to help with customer tracking and to reduce the time it takes for pages to load into your browser. Our cookies do not contain Personal Information. We may use both session cookies (which expire once you close your web browser) and/or persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience. Persistent cookies can be removed or blocked by following the help file directions in your Internet browser. If you elect to block cookies, you may not be able to access certain personalized sections of the Portal or our Services, such as reports. We also use log files and cookies to improve the quality of our Portal; to keep track of your login name, passwords, and pages you have visited on the Portal; and to tailor content to your interests and to personalize the Portal on your behalf.
HOW WE DISCLOSE INFORMATION
Personal Information
Verve does not share your Personal Information except as provided in this Privacy Policy. We may disclose certain Personal Information:
- To third party contractors, agents, service providers and vendors who help us provide the Services or the Portal, in which case we will take reasonable steps to ensure that these parties comply with confidentiality obligations and contractually require these parties only use the information as needed to provide services to us;
- To third parties to whom you ask or have authorized us to send Personal Information;
- To any subsidiary organizations, joint ventures, or other organizations under our control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy; or
- If we believe in good faith that such disclosure is necessary to (a) resolve disputes, investigate problems, or enforce our Terms of Use; (b) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity; or (c) protect and defend our rights or property or the rights and property of you or third parties.
In the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, we expect that any and all information that we have will be among the assets transferred. Verve will work in good faith to ensure these privacy rights or similar will be conveyed through any such purchase.
How Personal Information is Accessed or Corrected
You can access, review or correct certain Personal Information by logging into the Portal and accessing the Account section. Since we may use your user name as the account identifier, you may not be able to change your user name. You may, however, delete your Account at any time. Keep in mind, however, that even if you delete your Account, we may retain your Personal Information in conformance with our data retention policy, under which we may retain such information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law. There may be residual Personal Information that remains within our databases, access logs, and other records. Please remember, however, if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.
How Personal Information is Protected
We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include firewalls and encryption, internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems. We take reasonable measures to safeguard Personal Information and to protect against unauthorized access, alteration, disclosure or destruction of such information through our data collection, storage and security practices. You should take further precautions to protect personal data by safeguarding your user name and password and by limiting the use of shared computers. All Personal Information is stored on our secure servers in the United States of America.
Links to Third-Party Sites
Verve Mobile’s website contains links to other websites. Verve Mobile is not responsible for the security and privacy practices of these websites. Specifically, the www.vervemobile.com website links to sites providing news coverage, to partner sites for case studies, and to industry association sites of which Verve Mobile is a member.
Information Disclosed to Third Parties
This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you. If you disclose information to others, including to other Publishers or End Users, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.
Changes to Privacy Policy
Verve Mobile is committed to continually examining and reviewing its privacy practices, and may make changes to its Privacy Policy. In the event that any material changes are made to Verve’s privacy practices, we will promptly make changes to this Privacy Policy that disclose the changes and also send you notice to the last email address, if any, you have provided to us.
Questions and Concerns:
If you have any questions or concerns about our privacy practices, you may contact us:
Verve Mobile
725 S. Coast Hwy 101
Encinitas, CA 92024
Email: privacy@vervemobile.com
This Privacy Policy was last updated on April 18, 2012.
