Effective Date: 25th May, 2018
As a leader in mobile marketing, Hotmob uses proprietary technology offering advertising solutions for our clients, including working with advertisers to deliver advertising campaigns across our network of mobile application (“App”) and website (Web), (collectively, “Hotmob Services”).
Hotmob works with different partners to enrich user experience in mobile advertising. The partners include, but not limited to, Fraud and Measurement Partners, Data Partners, and Creative Partners (collectively, “Third Parties”). We are the data controller of Hotmob Services, but the Third Parties will be its own data controller for its products and platforms.
Section 1 – describes how Hotmob process personal data if you visit our website www3.hot-mob.com.
Section 2 – describes how Hotmob process personal data to serve advertisement when users are using an app integrated Hotmob SDK.
Section 3 – describes the Third Parties Policy
Section 4 – describes how the user withdraws their consent on data collection and process Web and App
1. Personal Data we collect when you visit hot-mob.com
Hotmob collects Personal Data when you visit www3.hot-mob.com and these data are stored in our log files. We adopt various technologies to collect this data, including “cookies” and other Third Parties’ services.
A cookie is a small text file that is stored on your web browser for record-keeping purposes. We use a persistent cookie to assist us with the collection and use of anonymous browsing data. A persistent cookie remains on your mobile device for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “Help” file. But remember, rejecting cookies may affect the way your favorite sites behave. We do not link the information we store in our cookie to any personally identifiable information (PII) you may submit while on a site.
2. Personal Data We Process to Serve Advertising
Personal data collection
Hotmob collects personal data when you use an app that integrates with Hotmob Services. The data do not include a specific individual’s name, address, telephone number, and email address, but the data we collect does enable us to recognize your device over time and across apps. Depending on where you live and user’s privacy choices. The personal data we collect including:
- Device identifiers, such as IP address, iOS Identifier for Advertising (IDFA), Android Advertising ID, or a Hotmob-specific identifier.
- Device information, such as the device type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, mobile browser (e.g., Chrome, Safari), and screen size.
- App usage, including the apps on your device that use the Hotmob Services and the version of such apps, the app on your device that is requesting an ad, and user network connection type (e.g., WiFi, cellular).
- Ads information, such as ads served, viewed, or clicked on, the ad placement, whether the ad been clicked on, and whether you visited the landing page.
Personal data usage
We will use the personal data collected by App that integrated with Hotmob Services for several usages:
- Serving Advertisements: Allowing publisher partners to offer advertising inventory in their apps and fill that inventory with ads.
- Interest-Based Advertising: Allowing Hotmob and Third Parties to infer what you may be interested in and serving ads to you based on these inferred interests. Hotmob’s policies prohibit Third Parties from sending or targeting advertisements based on, information that we consider sensitive or are prohibited by law, such as race, religion, politics, sex life, or health.
- Ad Reporting and Conversions: Reporting to publisher partners on information about when and how ads are shown on their App or Web and are clicked on.
- Frequency Capping: Preventing you from seeing the same ad or type of ad too many times.
- Fraud Detection and Prevention: Identifying invalid clicks (or ad queries) and protecting Hotmob and advertisers from fraudulent behavior.
- Providing and Operating Our Services: Auditing, researching, and analyzing data in order to maintain, protect, and improve our services, and to ensure that our technologies function properly.
If you choose to opt-out of Hotmob’s services, we will not process your personal data for these purposes. Such as, we will not collect, use, or share your iOS Identifier for Advertising or Android Advertising Identifier, or your Hotmob-specific identifier. However, we will still serve you contextual ads targeted to the content or type of app that you are using (for example, serving an ad about a trip promotion on a travel app).
Personal Data Sharing
If you provide consent to Hotmob, we may share personal data with advertisers and publishers in order to improve advertisement targeting, make and create offers, provide performance reports, and to improve our systems and products.
3. Privacy Practices of Third Parties
Hotmob requires Third Parties, who are each independent controllers of your personal data, to comply with all applicable laws and regulations, to comply with the Hotmob Publisher Partner Policies and Advertising Demand Partner Policies, and to provide you with sufficient notice of their processing of your personal data.
When you consent to Hotmob processing your personal data, you are also giving consent to the processing of your personal data by the Third Parties 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 other countries), we will also inform current Third Parties with whom we have shared your data to about your withdrawal or opt-out so that they, as independent controllers of your personal data, can also respect your choice. Third Parties may also have separate legal bases for collecting, using, retaining, and sharing your personal data.
We encourage all users to read Third Parties’ policies to understand their privacy practices, the legal basis for processing your personal data, and any additional options that they may provide for exercising control over such processing.
4. Opting Out
Hotmob collects the minimum amount of personal data about you that is necessary to provide the Hotmob Services. As a result, we do not have sufficient information to provide secure and authenticated access to the personal data that we stored or to confirm that specific personal data is related to a specific user. However, 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 to delete or de-identify such personal data, by withdrawing your consent at any time. You can also contact us using the details below.
To opt-out from our web, you can easily deny or opt-out of cookies by manually delete or, following the instructions contained in the “Help” section, of the browser. Hotmob’s opt-out is effective for the browser, and may not work if the browser is set to block third-party cookies. If you delete the cookies after opting-out or uses a different browser you will have to opt-out again. If you use a different browser, you will need to opt out again. Hotmob opt-out cookie is set to remain effective for at least five years.
To opt-out on iOS, you need to enable the “Limit Ad Tracking” setting on your iOS device.
To opt-out on Android, you need to enable the “Opt out of Ads Personalization” setting on your Android device.
Our publisher partner may also provide ways to opt-out from their apps. Once you opt-out by either way from the above, we will no longer collect, use, share or otherwise process personal data from that app to personalize your advertising experience, effective on your next visit to the Web or the App integrated with Hotmob Services.
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 Parties partners if you withdraw your consent so that they, as independent controllers of your personal data, can also respect your choice.
But to comply with the law or to support our legitimate interests, we will still process your personal data if necessary to, even if you do not consent to a personalized advertising experience, or if you later withdraw such consent.
5. Other information
Hotmob takes steps to protect the security of information that we collect. By using reasonable security measures designed to ensure the security, confidentiality, and integrity of consumer data, and to protect against unauthorized access to, and unauthorized use or disclosure of such data. While Hotmob cannot guarantee that these measures can stop all threats, we believe they provide reasonable protection.
Change of Ownership
Additionally, there may be times where we will need to disclose information to protect our system or our rights or to ensure your safety or the safety of others. We may also transfer all or some of the data discussed in this policy, in connection with a corporate merger, acquisition, the partial or total sale of assets, bankruptcy, or any other corporate change.
Updates to This Policy
If you have any questions or comments about this policy, you may contact us by email at [email protected] or by mail at:
4/F, Tungtex Building,
203 Wai Yip Street, Kwun Tong,
Kowloon, Hong Kong
Attention: Data Privacy