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 Website Visitor 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 Framework and Swiss-U.S. Privacy Shield Framework. Kochava has certified to the Department of Commerce that it adheres to 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 PII from website visitors?
No, unless it is voluntarily provided by the visitor. 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 on the “Careers” page. 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 website visitors?
Kochava may use a visitor’s 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, the visitor consents to the use of PII in order for Kochava to contact and deliver information to them.

Does Kochava share the PII it receives from website visitors with third-parties?
No, unless Kochava is unable to meet a visitor’s particular business objective. Under such circumstances, Kochava may elect to disclose a visitor’s PII in order to match them with a registered Kochava partner. These partners are contractually obligated to treat the PII with at least the same level of confidentiality as does Kochava. Despite taking these precautionary measures, Kochava may be liable in some circumstances for the onward transfer of personal information to a third party that violates the Privacy Shield Principles.

How may a website visitor 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).

Is a website visitor able to limit the use or disclosure of its PII?
Yes. A visitor may instruct Kochava to limit the use of its data and PII to that which is strictly necessary for Kochava to directly service the visitor. A visitor may also instruct Kochava to limit the use of its data and PII to the express reason Kochava provided for such use. A visitor may also instruct Kochava to permanently delete its PII in the event the visitor no longer desires any communication from Kochava. Furthermore, a visitor may instruct Kochava to withhold disclosure of its PII to third-parties. A visitor 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 website visitor able to access its PII?
Yes. A visitor 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).

Does Kochava process PII on behalf of its commercial clients?
It depends on how PII is characterized under the terms of the contractual relationship between Kochava and the client. Some jurisdictions define PII more broadly than others to include things like device ID or IP address. Other jurisdictions define PII more narrowly to only include things like email address or first/last name. Kochava almost always processes device ID and IP address, while Kochava almost never processes email address or first/last name. By default, Kochava’s software is programmed to not collect the most obvious types of PII (e.g. email, first/last name). Kochava’s standard license contract requires clients to obtain consent and post privacy policies in order to use Kochava’s services. Furthermore, app stores like iTunes and Google Play have safeguards in place to ensure app developers have proper consent mechanisms and privacy policies in place if the app is programmed to collect certain types of PII.

How should a website visitor 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 or Switzerland seeks to have an unresolved privacy complaint against Kochava addressed by an independent third-party, the website visitor may contact JAMS. For more information or to file a complaint, a user is encouraged to visit the JAMS website: https://www.jamsadr.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 and Swiss-U.S. Privacy Shield programs.

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 website visitor to Kochava is hosted on servers located in the United States.

To whom should a user direct its questions regarding this Privacy Policy?
A website visitor 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 Website Visitor Privacy Policy was last updated May 22, 2018.