### Privacy Policy

1. Introduction

  This Policy applies to information collection and use while Users view ads served by the Mintegral Services or whilst interacting with the Mintegral Services.

  Our technology enables our partners to show Users more relevant advertising that is based on Users’ interests and behaviors. In order to provide Mintegral Services, we may collect and use certain information about User activity and preferences. We understand how important it is to keep such User’s personal information confidential and discrete, especially in today's online world. To this end, we have designed this Policy in a format that is easy to navigate and read so that our privacy practices can be clearly understood.

  The Mintegral Services may link to third party websites, Apps or other third party content. Please note that we cannot control the treatment of a User’s information by such third parties, and that the privacy practices of third parties likely differ from those described in this Policy.

2. How We Collect Users’ Information
  Depending on the nature of a User’s interaction with the Mintegral Services, we may collect information directly from such User or from our business partners (e.g. mobile application developers, Ad Exchanges platform). For example, when we partner with an Ad Exchange platform and the Ad Exchange platform initiates an ad request to our DSP, it may share User’s information with us. Where required, the publisher will obtain User consent for and on our behalf for the processing of User personal information to display advertising on a User’s device. A User can withdraw their consent at any time. In addition, we may acquire information from other trusted sources to update or supplement the information that the User voluntarily provides to us or that we collect automatically or collect from our business partners (e.g. mobile application developers, Ad Exchange platforms).

3. Information We May Collect From Users

  When you view ads served by Mintegral Service, we and/or our business partners (e.g. mobile application developers, Ad Exchange platforms) may collect your information including the following:

  Device make, device model, operating system (e.g.iOS), device type (e.g. smartphone, tablet, etc.), device properties related to screen size, orientation and battery, carrier, name and properties of mobile application through which a consumer interacts with the Advertising Services, country, time zone and locale settings (country and preferred language), network connection type, IP address, Internet browser user-agent used to access the Advertising Services, identifier for advertisers (IDFA), network provider, SDK version, timestamp, API key (identifier for application), application version, iOS Identifier for advertising, OS version of device, time zone, network status such as WiFi, the geo-location of your device (using GPS or other geo-location data) and the Identifier for Advertising (IDFA) or the Google Advertising ID (AAID), GAID, etc., international mobile equipment identity (IMEI), Internet (IP) addresses or geo-location data, the content type of the ad (what the ad is about, e.g. games, finance, entertainment, news), the ad type (e.g. whether the ad is a text, image, or video based ad), device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.

  We provide Mintegral Service for our mobile application developers through Mintegral. We may collect the email address, account name and password, IP address and address of individuals using Mintegral on behalf of our mobile application developers.

4. How We Use Users’ Personal Information

  We use your personal information to display advertising on your device, which may include interest-based advertising customized to individuals’ inferred interests, preferences, locations and other features. Where required, the publisher will obtain User consent for and on our behalf for the processing of User personal information to display advertising on a User’s device. A User can withdraw their consent at any time.

  Where necessary in our legitimate interests we use your personal information: (i) to understand and analyze your usage trends and preferences and improve our Mintegral Service; or (ii) for purpose of anti-fraud and traffic quality monitoring in order to perform the contractual obligations to our business partners.

  We may also use personal information about Users to comply with applicable laws, regulations or codes of practice, and to protect our legitimate interest and protect the rights or property of us or any other third parties.

5. Disclosure of Users’ Personal Information

  We may disclose the User’s personal information to our business partners, including our advertisers, to report the measurement of Users’ interactions with the Apps, and for anti-fraud and traffic quality monitoring in order to perform the contractual obligations to our business partners (e.g. advertisers). These business partners may use the Users’ personal information to show Users relevant ads, measure Users’ ad/site interaction, identify Users’ interest areas, and better understand the site and app traffic usage or User behavior in order to improve their services. Our business partners’ use of the information that we disclose to them will be governed by their privacy policies.

  We may also share aggregate or anonymous information with other third parties in accordance with the terms of this Policy.

  Our affiliates may also have access to Users’ personal information for the purposes set out in this Privacy Policy.

  We may share Users’ personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer Users’ personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.

6. International Transfers

  When you are located in the EEA, personal information collected from you, including though our Mintegral Service, will be transferred to recipients in countries located outside the EEA (including in China, US, India, Korea, Singapore, Australia, Japan, Canada, France, Ireland, London, Germany, Brazil.), which do not provide a similar or adequate level of protection to that provided by countries in the EEA. Where required by law, the publisher will obtain your consent to the transfer of your personal information to recipients, as described in this Privacy Policy, which are located outside the EEA. You may withdraw your consent at any time.

  Mintegral has entered into EU standard contractual clauses (“Model Contracts”) for intra-group transfers of personal information to its affiliates. You can request a copy of these Model Contracts by submitting your request via email to privacy@mintegral.com.

7. Your Data Rights

  If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of you personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.

  To exercise this right please contact privacy@mintegral.com.

8. Security of Your Personal Information

  The security of User’s information is our utmost priority, and we take strict measures in order to protect our data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for User’s information. Physical access is strictly controlled both at the perimeter and at building ingress points by our staff utilizing video surveillance and other electronic means.

  We also protect User’s privacy by seeking to minimize the amount of sensitive data and PRI that we store on our servers in the first place. We also seek appropriate contractual protection from our partners regarding their treatment of user data.

  Mintegral may retain the information relating to you collected from our business partners as necessary for the provision of the services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

9. Children

  We ensure that we complies with the Children's Online Privacy Protection Act (COPPA), and does not knowingly collect personal information about Users of Apps directed to children under the age of thirteen (13). For more detailed information please visit our COPPA policy.

  If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.

10. Marketing

  We may contact you periodically by e-mail to provide information regarding our products, services and content that may be of interest to you. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.

  If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the communications or request to be opted-out of receiving such communications via email to support@mintegral.com.

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