This Privacy Policy sets forth the rules under which Kochava uses information collected from users of the Kochava.com website. The policy is presented in a Question/Answer format to provide users with succinct and easily navigable explanations regarding their privacy.

In general terms, what type of service does Kochava provide?
To whom does this Privacy Policy apply?
Is the Kochava.com website intended for persons under thirteen years of age?
Does this Privacy Policy apply to linked websites?
What type of information does Kochava collect from users of the Kochava.com website?
Does Kochava use web cookies on the Kochava.com website?
Is a user able to block Kochava from placing web cookies on its computer?
Is Kochava a participant in the EU-U.S. Privacy Shield program?
Does Kochava collect any personally identifying information (“PII”) from its users?
How does Kochava use the PII it receives from users?
Does Kochava process PII on behalf of its clients?
Does Kochava share the PII it receives from users with third-parties?
How may a user opt-out from receiving communications from Kochava?
How is Kochava held accountable for onward transfers of end-user information?
Is a user able to limit the use or disclosure of its PII?
Is a user able to access its PII?
How should a user lodge a privacy complaint against Kochava?
Is an independent dispute resolution mechanism in place to resolve privacy complaints brought by citizens of an EU member nation?
Must Kochava disclose PII in response to lawful requests by public authorities?
Is Kochava subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)?
Where does Kochava store its collected information?
To whom should a user direct its questions regarding this Privacy Policy?


In general terms, what type of service does Kochava provide?
Kochava provides attribution and analytics services to marketers. Kochava provides these services to businesses- it does not provide them to the individual end-users who typically use the marketer’s products. A typical Kochava client is one who has a mobile app it wishes to promote. Such a client may market its app through any number of advertising networks. Kochava ingests, processes, and organizes specific types of non-personally identifying information associated with an end-user’s interaction with the client’s ad. Within certain boundaries, as later described in this Privacy Policy, the client determines which types of information it wants the Kochava platform to ingest on its behalf.


To whom does this Privacy Policy apply?
This Privacy Policy applies to users of the Kochava.com website. Because clients and prospective clients are the principal users of the Kochava.com website, this Privacy Policy most directly affects Kochava clients and prospects. The data Kochava collects on behalf of a client is subject to the terms and conditions as between client and its end-user. If Kochava accesses or uses any end-user data collected on behalf of a client, then such access or use is strictly incidental to Kochava’s performance of its service contract with the client.


Is the Kochava.com website intended for persons under thirteen years of age?
No. The Kochava.com website is not intended for the use of persons under thirteen years of age. Kochava does not knowingly solicit or collect personally identifying information (“PII”) from or about children, nor does Kochava knowingly market its products or services to children.


Does this Privacy Policy apply to linked websites?
No. Although the Kochava.com website may contain links to other sites, Kochava is not responsible for the content, security, or privacy practices employed by those sites. Kochava neither owns nor controls the third-party websites; thus, this Privacy Policy does not apply to information provided to or gathered by them.


What type of information does Kochava collect from users of the Kochava.com website?
By way of industry-standard web log files and similar tools, each time a user visits the Kochava.com website, Kochava collects the URL from which the user visited, the pages visited, the computer’s browser information, and the IP address.


Does Kochava use web cookies on the Kochava.com website?
Yes. Kochava uses web cookies to track the pages viewed during each visit to the Kochava.com website. Kochava uses this information to help improve the user’s experience and to better understand how users use the site. Kochava does not attempt to link web cookie data to PII.


Is a user able to block Kochava from placing web cookies on its computer?
Yes. A user may set its browser to refuse web cookies before accessing the Kochava.com website. In doing so, however, certain features of the site may not function properly and the user assumes all responsibility for any resulting loss of functionality.


Is Kochava a participant in the EU-U.S. Privacy Shield program?
Yes. Kochava is a participant in the EU-U.S. Privacy Shield program and adheres to all of the principles therein. Kochava self-certifies its compliance with the Privacy Shield Principles. For more information regarding the program and its principles, visit https://www.privacyshield.gov/. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles will govern.


Does Kochava collect any personally identifying information (“PII”) from its users?
No, unless it is voluntarily provided by the end-user. Kochava does not collect any PII when a user visits the Kochava.com website unless the user voluntarily provides such information as a result of: (a) submitting an inquiry through the Kochava.com “Contact” page; (b) submitting a request for a product demonstration through the “Request a Demo” page; (c) registering as a client on the “Sign Up” page; or (d) submitting an application for employment. Such PII may include, among other information, a user’s full name, physical address, email address, phone number, company name, and website URL. Users are under no obligation to provide Kochava with PII of any kind; however, refusal to do so may prevent the user from using certain features of the site.


How does Kochava use the PII it receives from users?
Kochava may use user PII to: (a) inform the user of customized business solutions; (b) directly communicate with the user regarding the use of the Kochava services; or (c) review a user’s application for employment. By using the forms found on the Kochava.com website or engaging Kochava under a license and services agreement, a user consents to the use of PII for Kochava to contact and deliver information to the user.


Does Kochava process PII on behalf of its clients?
No. Kochava prohibits its clients from instrumenting the Kochava platform to ingest or otherwise process their end-users’ PII.


Does Kochava share the PII it receives from users with third-parties?
No, unless Kochava is unable to meet a user’s particular business objective. Under such circumstances, Kochava may elect to disclose a user’s PII in order to match the user with a registered Kochava partner. These partners are contractually obligated to treat a user’s PII with at least the same level of confidentiality as does Kochava.


How may a user opt-out from receiving communications from Kochava?
A user may opt-out from receiving communications from Kochava by contacting Kochava via email (privacy@kochava.com) or by contacting the legal department via telephone (855-862-4282).


How is Kochava held accountable for onward transfers of end-user information?
Although Kochava does not process PII on behalf of its clients, Kochava may need to share other types of data with third-party partners or sub-processors to effectively process data on behalf of a client to serve its needs. In such instances, Kochava executes all required contracts, clauses, or addenda to ensure that the third-party agent processes PII in a manner consistent with this Privacy Policy and the Privacy Shield Principles. Despite taking these precautionary measures, Kochava may be liable in some circumstances for transferring personal information to a third party that violates the Privacy Shield Principles.


Is a user able to limit the use or disclosure of its PII?
Yes. A user may instruct Kochava to limit the use of its data and PII to that which is strictly necessary for Kochava to directly deliver the services to the user. A user may also instruct Kochava to limit the use of its data and PII to the express reason Kochava provided for such use. A user may also instruct Kochava to permanently delete its PII in the event the user no longer desires any communication from Kochava. Furthermore, a user may instruct Kochava to withhold disclosure of its PII to third-parties. A user may request the above limitations by contacting Kochava via email (privacy@kochava.com) or by contacting the legal department via telephone (855-862-4282).


Is a user able to access its PII?
Yes. A user may request access to all of its Kochava-collected PII by contacting Kochava via email (privacy@kochava.com) or by contacting the legal department via telephone (855-862-4282).


How should a user lodge a privacy complaint against Kochava?
A user should contact Kochava with its privacy complaint via email (privacy@kochava.com) or by contacting the legal department via telephone (855-862-4282).


Is an independent dispute resolution mechanism in place to resolve privacy complaints brought by citizens of an EU member nation?
Yes. In the event a citizen of an EU member nation seeks to have an unresolved privacy complaint against Kochava addressed by an independent third-party, the user may contact Privacy Trust, located in London, England. For more information or to file a complaint, a user is encouraged to visit the Privacy Trust website: https://www.privacytrust.com/. Furthermore, if a user privacy complaint is not resolved through these means, a binding arbitration option may be available before the Privacy Shield Panel in certain limited circumstances.


Must Kochava disclose PII in response to lawful requests by public authorities?
Yes, in accordance with the Privacy Shield Principles, Kochava may be required under certain circumstances to disclose PII in response to lawful requests by public authorities.


Is Kochava subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)?
Yes. Kochava voluntarily subjects itself to the investigatory and enforcement powers of the FTC, as required by its participation in the EU-U.S. Privacy Shield program.


Where does Kochava store its collected information?
Kochava distributes and stores all of the information it collects in secure servers located in the United States. As such, all PII provided by a user to Kochava is hosted on servers located in the United States.


To whom should a user direct its questions regarding this Privacy Policy?
A user may direct its questions regarding this Privacy Policy to the legal department via email (privacy@kochava.com), via telephone (855-862-4282), or via U.S. Mail (201 Church Street, Sandpoint, ID 83864).


This Privacy Policy was last updated January 17, 2017.