Attribution: A user event resulting from marketing activity. For example, a user may click on an advertisement, download an app, or make an in-app purchase – each of these actions is an Attribution within the Kochava Platform.
Customer: A person or company that promotes its product or a component of its product using the Kochava Platform. For example, a Customer may promote its mobile application, a specific promotion within its app, an app update, event, or a company announcement, and use the Kochava Platform to attribute such an event.
Geographic Location Data: Customers may collect Geographic Location Data from an IP address through the Platform to give them deeper insight into the performance of their advertising campaigns. Geographic Location data is non precise geographic data that determines location from IP address, GPS coordinates and/or Wi-Fi networks.
Kochava Platform: A back-end technology that provides unique attribution matching using advertising identifiers and/or statistical identifiers to measure the performance of a mobile ad campaign.
Kochava Platform SDK: A computer code inserted into a Developer’s mobile app to enable the Developer to collect Unique Advertising Identifiers and Statistical Identifiers from the user for the purpose of measuring performance.
Non-Personally-Identifying Information: Information that, without the aid of additional information, cannot be directly associated with a specific person.
Partner: A third party that Customer works with to promote applications, networks, offers, and/or advertisements, including, but not limited to, ad networks, publishers, advertisers, affiliates, analytics providers, and data providers.
Personally-Identifying Information: Information that can be directly associated with a specific person without any additional data.
Postbacks: Server-to-server communication that allows a party to share information.
Statistical Identifiers: A method of providing attribution when Unique Advertising Identifiers are unavailable. Statistical Identification involves the collection of publicly-available HTTP headers from an end user’s device. The Kochava Platform uses the HTTP headers to probabilistically determine which device is responsible for the Attribution and collects the following data points: country code, device brand, device model, device carrier, IP address, language preference, operating system name, operating system version, user agent (browser type), and timestamp.
Unique Advertising Identifiers: Unique, user-specific character strings for advertising that may be reset by the user. Examples of Unique Advertising Identifiers include IDFA (developed by Apple for the iPhone), Google Ad ID (developed by Google for Android), and Windows advertising ID (developed by Microsoft for the Windows Phone).
Web Beacon: An object that is embedded in a web page that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page.
Web Cookie: A string of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the site.
EU – U.S. Privacy Shield
Kochava distributes and stores all of the information it collects in secure servers located in the United States. Any personal information that you provide to Kochava will be hosted on United States servers.
Kochava primarily processes personal data as an agent on behalf of and under the instruction of third parties. You may have the right to contact such third parties directly to limit or stop them from sharing your personal information with Kochava.
Kochava has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, Privacy Trust, located in London, England. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the Privacy Trust website at https://www.privacytrust.com for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, in certain limited circumstances, a binding arbitration option may be available before the Privacy Shield Panel.
Pursuant to the Privacy Shield Principles, Kochava may be required under certain circumstances to disclose personal information in response to lawful requests by public authorities.
To learn more about the Privacy Shield program, or to view our certification, please visit: https://www.privacyshield.gov/. To learn more about the Swiss Safe Harbor program, please visit: http://2016.export.gov/safeharbor/.
VISITORS TO OUR WEBSITE
Information Collected by Kochava
As a visitor to our site, you can browse our pages without having any Personally Identifiable Information revealed about you. Information we automatically collect via industry standard web log files and other tools includes the URL from which you visited, the page you are visiting, your computer browser information and your IP address.
Kochava uses Web Cookies to track the pages that users visit during each Website session, both to help us improve users’ experiences and to help us understand how the Website is being used. As with other Non-Personally-Identifying Information gathered from users of the Website, Kochava analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Kochava, its partners and others better understand how the Website is being used. Kochava does not attempt to link information gathered using Web Cookies to Personally-Identifying Information.
KOCHAVA USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.
Kochava may use Web Beacons on the Website to count users who have visited particular pages and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Kochava may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides. As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. There are portions of our web site, www.kochava.com where we may need to collect Personal-Identifying Information from you for a specific purpose, such as to provide you with certain information you request. The information collected from you may include your name, address, telephone, fax number, e-mail address, and other personal information. Users of the Kochava.com are under no obligation to provide Kochava with Personally-Identifying Information of any kind; however, a user’s refusal to do so may prevent the user from using certain Website features.
Use and Disclosure of Information By Kochava
Kochava gathers information on behalf of our Customers for the purposes of:
- providing you and our Customers with custom information about our service offerings that support your business needs;
- matching you and our Customers with compatible participants in our partner program in the event that we are unable to support your business needs ourselves; and
- reviewing your application for employment if you are seeking work.
We recognize that certain information may be sensitive. As such, we restrict our collection of such information to the critical data needed to deliver our services. If you use the forms on our Site, you may receive emails from us to facilitate your inquiry. You cannot opt out of emails that are necessary to provide our services. By using our forms or accepting of our Terms of Service, you agree that we and our partners may use your Personally-Identifying Information to contact you and deliver information to you. We may share your Personally-Identifying Information with companies that provide services to us (“Vendors”) and with our Customers. Our Vendors and Customers are contractually restricted from using your Personally-Identifying Information for any purpose that exceeds the scope of the contractual relationship. Furthermore, our Vendors and customers are prohibited from disclosing your Personally-Identifying Information to anyone else. We may also share your Personally-Identifying Information with compatible participants in our partner program in the event that we are unable to meet your business needs.
Information of Minors
This web site is not intended for persons under 13 years of age. We do not knowingly solicit or collect Personally-Identifying Information from or about children, and we do not knowingly market our products or services to children.
Links To Other Sites
INFORMATION COLLECTED BY CUSTOMERS UTILIZING THE KOCHAVA PLATFORM
The Kochava Platform is designed to collect and use data such as Unique Advertising Identifiers, Statistical Identifiers, Geographic Location Data and other data provided by the Customer for attribution. When an end user clicks on an advertisement, installs an app, or takes an action inside of an app, The Kochava Platform uses our SDK and redirect links to collect information, such as a Unique Advertising Identifier, to perform attribution. The Kochava Platform also enables Customers to view and measure information provided by Kochava, Customers, and the Customers’ other partnerships. Customers and Partners may also send information to The Kochava Platform via Postback. The Kochava Platform does not collect names, addresses, phone numbers, or financial information (like credit cards or banking information) from end users.
All data collected by The Kochava Platform is anonymous and no personally identifiable information is collected through our platform. Under certain circumstances, IP Address may be considered personal data under the EU’s 1995 Data Protection Directive. As a precaution, we adhere to the EU – U.S. Privacy Shield and US-Swiss Safe Harbor frameworks due to the possibility that the European Data Protection Authority might deem some of the information we collect to be personal data. Customers own the data that they provide to and collect through The Kochava Platform, including end user data. When a Customer removes or exports its data from The Kochava Platform, its use of data is governed by its own privacy policies and applicable laws, rules, or regulations. As part of The Kochava Platform, a Customer is permitted to extract and submit electronic data and information to Kochava’s servers. In this context, Kochava acts as a data processor and does not determine how its client’s data is utilized in Kochavas’s servers. Kochava does not choose or determine the types of data that are submitted to Kochava’s servers through The Kochava Platform. Any access to or use of such data by Kochava is incidental to completing Kochava’s contractual data processing obligations to its Customer. As part of Kochava’s professional services operations, Kochava processes data and information, potentially including personal data, on behalf of its Customers. In this context, Kochava acts as a data processor on behalf of its Customers. As part of Kochava’s internal operations, Kochava transfers data of its Customers and current and prospective business partners to Kochava’s U.S. data centers for processing and storage.
Access & Opt-Out
You may review and update the information that you provide to us through this web site by contacting us as described below. Any information collected by Customers utilizing The Kochava Platform is owned and controlled by the individual Customer. Opting out of The Kochava Platform will not stop end users from receiving interest-based advertisements from our Customers or other publishers or ad networks. Users who want to opt out of a particular ad network, publisher, or advertiser’s ads must contact those companies directly to opt out. The Kochava Platform allows its Customers the option to choose not to enter any Personally-Identifying Information into Kochava’s systems. You can inquire from these Customers as to this option, and your rights and obligations in this regard flow from your relationships with those Customers.
For What Purposes Can Customers Use Data Collected Through The Kochava Platform?
Customers use information collected from end users on The Kochava Platform to view reports and data related to their advertising campaigns. The Kochava Platform also allows Customers to view and utilize the information they collect to optimize their advertising campaigns. Customers may also use The Kochava Platform to share their data with Partners—including measurement partners, advertising networks, and publishers—via Postback, data exports, and/or API calls. Customers may use the information they collect on The Kochava Platform for the following purposes, which include, but are not limited to:
- Measuring the performance of ad campaigns (for example, by comparing the lifetime value of a user against the expenses required to obtain that user);
- Measuring the value of particular end users;
- Measuring the performance of various Partners, including ad networks and publishers;
- Creating customized performance reports (for example, how well a particular advertisement is performing in a particular geographic region);
- Determining when end users respond to ads; and
- Device attribution.
What Data Does Kochava Collect From Customers?
Customers submit their full name, mailing and/or billing address, email address, company name, and website URL. We use Customers’ information to service Customer accounts and respond to inquiries. This type of information is not collected from end users, except in rare circumstances when a Customer directs The Kochava Platform to collect email addresses on its behalf. We hold all such information in strict confidence.
Information Security & Storage Duration
We maintain strict physical, electronic, and administrative safeguards to protect your Personally-Identifying Information from unauthorized or inappropriate access. We restrict access to information about you to those Kochava employees and our Customers who need to know the information to respond to your inquiry or request. Employees who misuse Personally-Identifying Information are subject to disciplinary action. Kochava allows Customers to choose how long data is stored in The Kochava Platform. Customers are able to create and manage custom data-retention policies that dictate when data is removed from The Kochava Platform (e.g. after 180 days). When the Customer does not select a custom data-retention policy, Kochava uses industry standard data-retention policies.
Third Party Disclosure
CHANGES TO THIS POLICY