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 THE SERVICES 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.
Data Collection and Usage
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 hardware device IDs for mobile devices. Verve Mobile may identify your device using an anonymized (cryptographically hashed) hardware device ID, device manufacturer-supplied ID meant for advertising use (e.g., Apple’s Advertising Identifier), randomly-assigned unique identifier, or other user-entered information (“User Identifier”). The User Identifier cannot be tracked back to a device or any Personal Information or an immutable identifier supplied by the device manufacturer.
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, Wi-Fi 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 the User Identifier for purposes of advertising.
However, if you use a particular Publisher application or mobile website, that application or mobile website may independently collect information from you. A Publisher’s use of Services may include text messages, in which case the Publisher will provide Verve Mobile with the applicable phone numbers. 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. For example, some Publishers may request Personal Information from you within a Verve Mobile application or mobile website for purposes of granting access to content that requires a subscription. Verve Mobile collects and stores Personal Information requested by Publishers only to the extent necessary to deliver the Publisher’s content or services. Again, Verve Mobile is not responsible for, and cannot control, a given Publisher’s privacy practices. Verve does not connect this Personal Information with location or other data collected as part of ad calls.
When you opt-in to provide Personal Information to Verve Mobile customers or partners, Verve Mobile employs reasonable practices to restrict 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 us.
In order to make advertising messages as relevant as possible to users, location data may be used for targeting ads and as input into location targeting segments based on high-level characteristics of locations. Location data is also used to aggregate impressions, clicks, and other interaction metrics to modeled household locations for the purposes of demonstrating marketing impact of advertiser campaigns. Your ability to opt-out of location-based tracking is dependent on your mobile phone and its settings and, to the extent your mobile device allows you to opt-out of the location based tracking, we honor that setting on the device.
From Services that utilize mobile applications: Verve Mobile utilizes technology to uniquely identify most mobile devices to deliver targeted marketing messages to consumers. We believe that the presentation of relevant marketing messages assists 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. This technology uses the aforementioned User Identifier.
Third Party Cookies
Standard Log Files
As is common with most such Services, we automatically gather certain information and store it in log files. However, none of this information identifies individual users using Personal Information. Information in our log files includes Internet Protocol (IP) addresses, browser type, referring URL, operating system, date/time stamp, and bytes transferred. We use this to analyze trends, administer our Services, track and understand how people use our Services, and gather demographic information about our user base.
We may permit Publishers and advertisers to use a software technology called pixels (a.k.a., web beacons/web bugs), which are tiny graphics with a unique identifier, similar in function to cookies, to report anonymous individual or aggregate information and help us better manage content on our Services. In addition, we may use pixels in our advertisements to let us know which ads have been viewed.
Information from Third Parties
We may also get information about you from other sources. We may add this to information we obtain from your use of Services.
How We Disclose Information
- To third party contractors, agents, service providers and vendors who help us provide the Services, 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;
How Personal Information is Controlled or Corrected
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 Services contains links to and presents information from other websites. Verve Mobile is not responsible for the security and privacy practices of these websites. Verve Mobile’s Services may link to a specific Publisher’s site or partner sites for additional content such as weather, classified listings, image sharing services, and social media services.
Information Disclosed to Third Parties
Questions and Concerns:
If you have any questions or concerns about our privacy practices, you may contact us:
Verve Wireless, Inc.
5973 Avenida Encinas, Ste. 101
Carlsbad, CA 92008