Privacy Statement Effective Date as of November 19, 2015

The following statement describes Kochava privacy practices for mobile Analytical Data contained in the Kochava Collective and other information features which may be provided through the Kochava Collective Services.

This Privacy Statement Only Applies to the Kochava Collective

This policy does not imply responsibility for practices of Companies that Kochava does not own or control, to people that Kochava does not employ or manage, or to services not defined within the Statement.

Definitions Relating to the Kochava Collective

  • “Analytical Data” or “Data” means all Company Data authorized by Company for use by Kochava to provide Services via the Kochava Collective Site.
  • “The Kochava Collective Data Members” or “Members” are companies who register to use the Kochava Collective Analytical Data and Services, add (and maintain) records, and are legally authorized to provide such information to the Kochava Collective.
  • “The Kochava Collective Services” includes the provision of custom Analytical Data for Kochava customers.

The Kochava Collective Analytical Data and Services

The purpose of the Kochava Collective Analytical Data and Services is to maintain and provide up-to-date, targeted mobile device information. This allows Kochava customers access to and the opportunity to buy media from specific Members who have direct relationships with end users.

Data Authorization and Consent

Members should clearly understand that provision of Analytical Data and the related need of Kochava to store and process Analytical Data for the Kochava Collective Services requires Members to undertake: 1) obtaining full authorization and consent of data usage and collection from originating users; 2) obtaining fully necessary authorization and consent from originating users to anonymously process and transfer (including possible international transfer) data provided; 3) complying with applicable laws and regulations, including but not limited to formulating and publishing a policy relevant to personal information protection and privacy protection; and 4) making relevant disclosures and explanations to the originating user, allowing transfer of collected data to third parties for targeted advertising purposes. Members should also provide end users with an easy-to-operate selection mechanism, indicating how and when the user may exercise opt-in provisions and how and when the user can modify and withdraw such option, so that the user can choose to agree or disagree with the collection and use of his/her information and transfer of such information to the third parties.

Collection of Mobile Analytical Data and Company Information

The Kochava Collective Analytical Data contains anonymized mobile device information submitted by or obtained from a variety of sources, including but not limited to, the Kochava Collective Data Members who are legally authorized to provide such information, third-party data providers, and publicly available sources.

Most of the Kochava Collective Analytical Data comes from the Kochava Collective Data Members, however, the Company may supplement the Kochava Collective Analytical Data with publicly available information or with information from trusted data providers who are legally authorized to provide such information.

Information Provided by the Buyers of the Kochava Collective Analytical Data

From time to time, users seeking source or network origination information related to the Kochava Collective Analytical Data will want to provide specific information on their users to determine if there is a match within the Kochava Collective data set (Lookalike Analytical or Devices). Utilization of the Kochava Collective in this manner will only provide matches to the user, and will not expose specific data or anonymized device identifiers to any other third party.

Notice and Data Management

Mobile contact information is added to the Kochava Collective Analytical Data by Members who have direct relationships with end users and who are legally authorized to provide such information. Individuals may contact Members directly for inquiry of the types of information previously submitted, included, or maintained in the Kochava Collective.

Kochava will store data for as long as it is necessary to provide products and services to our Members and others, including those described above.

For additional information on how the Kochava Collective Analytical Data is used please contact privacy@kochava.com.

Onward Transfer/Access

Personal information may be transferred to countries Members or individuals do not reside in order to process and store data in accordance with our Privacy Statement and provide products and services. Some of these countries may not have the same data protection safeguards as the country where you reside. By using our products and services, you consent to us transferring your data to these countries. We are committed to ensuring your information is protected and apply safeguards in accordance with applicable law.

Confidentiality and Security

The Company uses reasonable security controls to protect Analytical Data from loss, misuse, and unauthorized access.

Segmented Analytical Data is only provided to the applicable Member who originally submitted the information to the Kochava Collective.

We have physical, electronic, and procedural safeguards that comply with federal regulations to protect personal information.

Data Integrity

The Company limits Analytical Data available in the Kochava Collective to information provided by trusted data providers (Members) who are legally authorized to provide such information. This information is typically associated to anonymized data used to register an app on a mobile device. On occasion other Data is appended to anonymized data which is derived from publicly available information or other sources where consent has been granted.

Third Party Advertisers

We partner with third-party advertising companies who serve ads to individuals and who are introduced to Members based on Member data which has been legally authorized to be submitted in the Kochava Collective. These companies may use this information in order to provide advertisements about goods and services of interest to individuals directly through Members and their respective relationship with end users.

Information Sharing and Disclosure

Kochava may share Analytical Data: (i) when required to do so in response to a subpoena, court order, or law enforcement request; (ii) in order to establish or exercise its legal rights or defenses; (iii) as authorized by its clients to do so in the course of providing the Services; and (iv) with any entity that merges with or acquires Kochava, if applicable.

Changes to this Privacy Policy

Kochava may update this policy. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your Kochava Collective account or by placing a prominent notice on our site.

Information, Questions, or Suggestion Contact

Questions regarding this Kochava Collective Data Mobile Contact Information Privacy Statement or the information practices of the Company may be directed to Kochava by contacting Legal@kochava.com or mailing the Kochava Collective Analytical Data Privacy Office, 201 N. Church Street, Sandpoint, Idaho, 83864.