Privacy Policy

Effective Date: 25 May 2018

To ensure that your privacy is protected and your information choices are respected, we have set out in this Privacy Policy an explanation of how Pocketmath Inc. and its affiliate companies, Pocketmath Pte. Ltd, Pocketmath Limited and Pocketmath Pty Ltd (collectively “Pocketmath”, “we”, “us” or “our”) may collect, share and use data relating to individuals collected via the Pocketmath website www.pocketmath.com, as well as through the Pocketmath demand side platform which allows users to purchase mobile advertisements on participating ad networks, exchanges, publishers, applications and web sites (the “Pocketmath Services”).

This Privacy Policy describes: (a) how Pocketmath collects information from you and other users of the Pocketmath Services, applications, and third-party websites with whom we engage (“Publishers”); (b) how we use that information to enrich your web experience; and (c) when we share that information with our publishers, advertiser clients and other third parties.

A. ABOUT THIS POLICY

This Privacy Policy governs our use and disclosure of information that we collect when you visit a website that directly or indirectly uses the Pocketmath Services, or view advertisements we serve. This Privacy Policy does not otherwise apply to the practices of other websites, such as those of our publishers and advertiser clients, or other services or companies that we do not own, manage or control. Unless otherwise noted herein, we do not control the privacy practices of such third parties, and you are subject to the privacy policies of those third parties when you use their services.

B. INFORMATION COLLECTED BY POCKETMATH

As we explain in more detail below, we may collect information about you in the following ways: when you visit our website; when you complete a registration form on our website; when you use or interact with Pocketmath Services; when you install or use the Pockemath API plugin; when you visit a website that directly or indirectly uses the Pocketmath Services; or when you view or respond to advertisements served by us or on our behalf.

Direct Information

We collect “Direct Information,” which means any information that you directly give us. For example, by registering with us, you will be directly giving us certain information, some of which identifies you personally, such as your name, email address, and other registration information. From time to time, you may also directly give us additional information about yourself if you engage in any other transactions with us, such as when you give us your phone number to seek customer support.

Usage Information

We collect “Usage Information,” such as general click stream behavior, web pages viewed (including the URL addresses and content of such pages), search queries from which you are directed to a page, navigation from page to page through our publisher networks, time spent on each page, items that you click or select, IP address, cookie-based information, information about your geographic location (e.g., derived from your IP address), and your Internet Service Provider.

Technical Information

We also collect “Technical information,” such as the type of browser you are using (e.g., Internet Explorer or Mozilla Firefox), the type of operating system you are using (e.g., Windows or Mac OS), the central processing unit on your computer, and your manner of connecting to the Internet (e.g., connection speed through narrowband or broadband access).

Information from Third Parties

Together with the information that we collect from you, we may combine non-personally identifiable information (e.g., demographic information such as zip code) that we receive from our publishers, advertiser clients and other third parties. For example, we may also receive publicly available information from third party websites with whom you have registered (e.g., social networks).

C. INFORMATION USED BY POCKETMATH

We may use your Direct Information to: (a) fulfill requests for our services; (b) communicate with you and respond to your inquiries; (c) conduct research about the use of the Pocketmath Services; (d) enable you to create an account, store log-in credentials, and customize your access and use of Pocketmath Services; (e) contact you from time to time about Pocketmath Services; and (f) provide offers for products and services of Pocketmath and our partners, publishers, advertiser clients and other third parties that may be of interest to you.

We may use the Direct Information, Usage Information and/or Technical Information that we collect (alone or in combination with information that we receive from our Publishers, advertiser clients and other third parties) to assemble non-personal, demographic and behavioral information to group users that share a common interest into “Audience Segments.” These Audience Segments do not contain personally identifiable information; for example, these segments may disclose that a user located in a geographic area may be interested in cars, but these segments do not identify or include the name, e-mail address, phone number, mailing address, or user name of any specific individual. We may use these Audience Segments to: (a) match advertisements that may be of interest to our users that fall within that segment; and (b) assist our publishers, advertiser clients and other third parties to deliver advertisements and offers that may be of interest to users within a given segment.

In some cases, if you have chosen to make personally identifiable information (e.g., your name) publicly available through third party websites (e.g., social networks), we may seek your consent to use that personally identifiable information in connection with services that we offer in conjunction with our publishers, advertiser clients and other third parties. We will not disclose your personally identifiable information without your consent.

We and our publishers, advertiser clients and other third parties also use such information for other related purposes (e.g., research to better understand the results of our online advertising campaigns or the interests or activities of users of the Pocketmath Services). We may also be engaged by any publisher that uses the Pocketmath Services to collect Usage Information on such publisher’s websites, such as for the purpose of obtaining additional information about such publisher’s own users and in accordance with such publisher’s privacy policy (rather than for our independent purposes).

Subject to applicable laws, regulations and the further terms herein, we may use Technical Information to analyze your browsing patterns and content, in order to personalize and target ads to you.

D. SHARING INFORMATION

Direct Information

We do not sell Direct Information, nor do we share any Direct Information (including any Direct Information combined with other Usage Information or Technical Information) with any third party for marketing purposes.

We may disclose any information we collect, including your personally identifiable information, if: (a) you specifically authorize it (e.g., you respond to an offer made by a third party on the Pocketmath Services); or (b) we reasonably believe that we are required to do so by law, regulation or other government authority or to protect our rights and property or the rights and property of the public or any user.

Information Shared for Advertising

We use non-personally identifiable Direct Information, Usage Information (e.g., Audience Segments) and/or Technical Information with third party advertisers and publishers to assist us and them in delivering relevant, personalized advertising that is aligned with user interests. For example, these companies may use such information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) in order to provide advertisements about goods and services that are likely to be of greater interest to you. Your preferences collected through this process may be used to influence a selection of types of marketing messages that you receive across websites of our publishers, advertiser clients and other third parties.

Pocketmath requires its advertiser clients and third-party partners, who are each independent controllers of your personal data, to comply with all applicable laws and regulations, to comply with the terms of this Privacy Policy, and to provide you with sufficient notice of their processing of your personal data.

When you consent to Pocketmath’s processing of your personal data, you are also consenting to the processing of your personal data by the Pocketmath advertiser clients and third-party partners with whom we share your data. If you withdraw your consent (if you are located in the European Economic Area, the United Kingdom, or Switzerland) or opt-out (if you are located in the United States or another country), we will also inform our current advertiser clients and third-party partners with whom we have shared your data of your withdrawal or opt-out so that they, as independent controllers of your personal data, can also respect your choice. Such advertiser clients and third-party partners may also have separate legal bases for collecting, using, retaining, and sharing your personal data.

We encourage you to read the Publishers, Pocketmath advertiser clients and third-party partners’ policies to understand their privacy practices, the legal bases for their processing of your personal data, and any additional options that they provide for exercising control over such processing.

Please note that our publishers’ websites and their independent advertisers may independently collect other demographical information about you after they place their own cookies or web beacons on publishers’ websites. The use of cookies and pixel tags by our publishers, advertiser clients and other third parties are subject to their own privacy policies. We are not responsible for the information practices of these third parties.

E.CONTROLLING THE PROCESSING OF YOUR DATA

We give you control over the types of personal data we collect from you and how we process that personal data to personalize your advertising experience.

European Economic Area, the United Kingdom and Switzerland

Consent: If you are located in the European Economic Area, the United Kingdom, or Switzerland, Publishers who would like us to serve you personalized ads must first obtain your consent so that Pocketmath and our partners can process your personal data for this purpose. Some Publishers may choose to obtain your consent for this purpose even if you are located outside of these regions. If you provide your consent, we will collect, use, share, and otherwise process all of the personal data described above for the purpose of serving you personalized advertising that Pocketmath and our partners believe is most relevant to you.

If you decide that you do not want a personalized advertising experience, we will not process your personal data for this purpose. For example, we will not collect, use, or share your IDFA (iOS Identifier for Advertising) or AdID (Android Advertising Identifier), your precise location data, or your demographic or interest information. However, we will still serve you contextual advertising -- ads targeted to the content or type of app you are using (for example, serving an ad for a video game to a gaming app).

Withdrawal of Consent: You can withdraw your consent to Pocketmath Services at any time. We believe that Pocketmath Services enhance our users’ web experience. If you do not want us to collect any further information from you via our ad delivery process, then you may choose to opt-out via optout.pocketmath.com.

Publishers may provide a way for you to withdraw your consent directly from within an app or website. If you withdraw your consent from within an app or website, once Pocketmath receives notice of your withdrawal of consent via such Publishers, we will no longer collect, use, share, or otherwise process personal data from that app or website to personalize your advertising experience.

In addition, you can use your device settings to let such Publishers know that you wish to withdraw your consent to Pocketmath Services across all of your apps on that device.

  • On iOS, you may withdraw your consent by enabling the “Limit Ad Tracking” setting.
  • On Android devices, you may withdraw your consent by enabling the “Opt out of Ads Personalization” setting.

Once Pocketmath receives notice of your withdrawal of consent via the foregoing, we will effectuate your withdrawal of consent, and we will no longer collect, use, share, or otherwise process personal data from that device to personalize your advertising experience.

Unless we have another legal basis for storing your personal data, we will also delete or de-identify the personal data we have stored about you within 30 days when you use one of these methods to withdraw consent. We will also inform our current third-party partners if you withdraw your consent so that they, as independent controllers of your personal data, can also respect your choice to withdraw consent.

Even if you do not consent to a personalized advertising experience, or you later withdraw such consent, we will still process your personal data when necessary to comply with law or to support our legitimate interests.

Legal Necessity: We will process personal data as necessary to comply with law. For example, if you consent to a personalized advertising experience, but later withdraw such consent, we will continue to retain a record of the IDFA or AdID of your device for the purpose of recording when you consented and withdrew consent from our processing of your personal data. As part of your withdrawal of consent request, we will also make available the IDFA or AdID of your device to our current third-party partners so that they, as independent controllers of your personal data, can also respect your choice to withdraw consent.

Legitimate Interests: We will process personal data as necessary to support our legitimate interests as allowed under applicable law, but we will protect your privacy in doing so.

United States and Other Countries

Opt Out: If you are located in the United States or another country outside the European Economic Area, the United Kingdom, and Switzerland, you can opt out of receiving personalized advertising by using your applicable device settings:

  • On iOS, you may opt out by enabling the “Limit Ad Tracking” setting.
  • On Android devices, you may opt out by enabling the “Opt out of Ads Personalization” setting.

If you opt out through your device settings, once Pocketmath receives notice of your withdrawal of consent via the foregoing, we will effectuate your withdrawal of consent, and we will no longer collect, use, share, or otherwise process personal data from that device to personalize your advertising experience.

In addition to the foregoing, if you do not want us to collect any further information from you via our ad delivery process, then you may also choose to opt-out directly from Pocketmath via optout.pocketmath.com.

Accessing, Restricting, and Rectifying Personal Data We Collect About You

Pocketmath collects the minimum amount of personal data about you that is necessary to provide the Pocketmath Services. As a result, we do not have sufficient information available to provide secure, authenticated access to the personal data that we store about you or to confirm that specific personal data relates to you. However, as noted above, if you live in the European Economic Area, the United Kingdom, or Switzerland, you can exercise control over whether we continue to process your personal data, and request that we delete or de-identify such personal data, by withdrawing your consent at any time. You can also contact us using the details below.

Deletion

Unless we have another legal basis for storing your personal data, if you are located in the European Economic Area, the United Kingdom, or Switzerland, we will delete or de-identify the personal data we have stored about you within 30 days of when you withdraw your consent.

F. BE CAREFUL IF YOU POST INFORMATION AVAILABLE TO THE PUBLIC

Whenever you voluntarily post information in public areas of websites operated by Pocketmath or the Internet (e.g., journals, Blog, message boards, and forums), you should be aware that this information may be accessed by the public. Please exercise discretion in deciding what information you disclose.

G. CHILDREN

Pocketmath does not permit the Pocketmath Services to be used to collect information from apps or websites directed to children under the age of 13 for purposes of personalized advertising. Pocketmath may collect information from apps and websites directed to children for other purposes, such as serving advertisements based on contextual information, like the content or type of app you are using (for example, serving an ad for a video game to a gaming app).

In addition, if you live in the European Economic Area, the United Kingdom, or Switzerland, you must be at least 16 years of age to consent to a personalized advertising experience. Pocketmath does not collect or otherwise process personal data from individuals in the European Economic Area, the United Kingdom, and Switzerland whom it knows to be under 16 years of age, except to comply with law or to support our legitimate interests as described above.

H. ACQUISITIONS

We reserve the right to transfer your information (e.g., personally identifiable information) in the event of a transfer of ownership of Pocketmath and/or its relevant assets, such as acquisition by or merger with a different company. If the different company plans to materially change this Privacy Policy, you will be notified beforehand.

I. SECURITY

To bring you the Pocketmath Services, we operate globally. Where the laws of your country allow you to do so, you authorize us to transfer, store, and use your data in the United States, Singapore, and any other country where we operate. In some of the countries to which we transfer personal data, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those of your country.

When we transfer personal data outside of the European Union or EFTA States, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws, contractual obligations placed on the recipient of the data (model clauses may be requested by inquiry as described below), or EU-US and Swiss-US Privacy Shield principles.

We implement physical, electronic and procedural restrictions (e.g., password protection), in an effort to help protect confidentiality of your personally identifiable information. Please remember that no technological environment is completely secure, and we cannot guarantee confidentiality of any communication or information posted or otherwise transmitted on Pocketmath or any other website over the Internet.

J. CHANGES IN PRIVACY POLICY

From time to time, we may change this Privacy Policy by posting a notice of such change on our website. You should visit our website periodically to review any such change. When you continue to use or interact with Pocketmath Services after such change, your subsequent provision of information (e.g., personally identifiable information) to us will be subject to such change. If such change materially expands our rights to use your personally identifiable information that we have collected, we will notify you through email or a prominent posting on our website.

K. RETENTION

We may retain your Direct Information, Usage Information and/or Technical Information to the extent set forth herein and as permitted by applicable law, but we reserve the right to delete any such information (e.g., including any data that you may have saved on the Pocketmath services) without any liability to you.

L. FOR CALIFORNIA USERS

Your California Privacy Rights: California privacy law allows California residents to obtain specific disclosures about a business’s privacy practices if it shares information with other companies for direct marketing purposes. To make a request to Pocketmath under California’s privacy law, please send an e-mail to: legal@pocketmath.com.

M. HOW TO CONTACT US

If you have any questions or concerns about this Privacy Policy or its implementation, or if you believe that your account information is inaccurate, you may send an email to: legal@pocketmath.com.

If you live in the United States, the data controller responsible for your personal data is Pocketmath, Inc. with an address of:

Pocketmath, Inc.
Attn: Privacy Policy Inquiry
600 Congress Avenue, Floor 14
Austin, TX 78701

If you live outside the United States, the data controller is Pocketmath Pte Ltd, with an address of:

Pocketmath Pte Ltd
Attn: Privacy Policy Inquiry
883 North Bridge Road #15-05
Singapore 198785