This Privacy Policy (“Policy”) covers the websites at www.medialets.com, www.medialytics.com, and any subsidiary websites (the “Sites”), owned and operated by Medialets, Inc. (the “Company”, “we”, “us”, “our”) and any services which we provide to publishers of applications which operate on mobile devices and mobile websites designed for display on mobile devices and to end users of such applications (the “Services”).

As a general rule there are two categories of users of the Site and Services: “Publishers” who are operators or publishers of applications that use the Company technology to deliver advertisements in their mobile applications or mobile website, and “End Users” who are visitors or users of our Site, individual users of mobile applications or individual visitors of a mobile website. By visiting the Site or using the Services, you are accepting the policies and practices described in this Privacy Policy.

This Policy describes our practices with respect to you or your company’s personally identifiable information (“You”). In particular, it defines: 1) what personal information we collect, 2) how we collect personal information, 3) how we use personal information, 4) how we protect personal information, 5) with who, if anyone, we share personal information, and 6) how you can access or correct personal information.

Your privacy is important to us. Should you have any questions about our privacy policy, contact us a privacy@medialets.com.

A. Sites

By visiting the Sites and/or using any Services provided on or through the Sites, you agree to the terms of this Policy in full and without modification. If you do not agree to the terms of the Policy, you do not have the right to access the Sites or to use any of the Services. If you visit the Sites, your visit and any possible dispute over privacy is subject to this Policy and any applicable Terms of Service, including limitations on damages and the application of New York State law.

The Information We Gather and How We Use it

The Site and the Services are primarily directed to Publishers, although we welcome End Users who want to know more about our Services. When you access the Site or Services, we may collect the following information:

  • Personal Information – We collect Personal Information when you knowingly provide it, including when you register for the Site, provide feedback, or request information. Personal Information is information that may be used to identify or locate an individual, like a person’s full name, postal address, e-mail address, or phone number, as well as other non-public information that is associated with this Personal Information. We use your Personal Information to administer your account and provide you Services, to send communications and administrative e-mails, to respond to your inquiries, and to send marketing and product update messages to those who request such messages. Typically, Publishers, rather than End Users visit the Site in order to access and register for the Services. For example, Publishers may provide their e-mail address when they register on the Site and create a user name and password. We may combine this information with other information about you that we receive from other sources, both on and offline, to improve the quality of our products and services and enhance your experience.
  • Non-Personally Identifiable Information – We collect Non-Personally Identifiable Information automatically when you visit our Site. Non-Personally Identifiable Information is information that is not used nor intended to be used to personally identify an individual and is not associated with, nor linked to, Personal Information. This Non-Personally Identifiable Information we collect via the Site includes your Internet Protocol address, browser type, browser language, the date and time of your request, and the web page you have visited immediately prior to visiting the Site.

How Personal Information is Collected

To serve you better, we use “cookie” technology. Cookies are alpha-numeric identifiers, usually stored on a user’s computer hard drive, which enable us to “personalize” the Sites for each user. Cookies also tell us how and when pages in our Sites are visited and by how many people. We generally use cookies to help with customer tracking and to reduce the time it takes for pages to load into your browser. Our cookies do not collect personal information. We may use both session cookies (which expire once you close your web browser) and/or persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience. Persistent cookies can be removed or blocked by following the help file directions in your Internet browser. If you elect to block cookies, you may not be able to access certain personalized sections of our Services, such as Publisher reports. We also use log files and cookies to improve the quality of our Site; to keep track of your login name, passwords, and pages you have visited on the Site; and to tailor content to your interests and to personalize the Site on your behalf.

When you visit our Sites, our servers automatically record information that your browser sends, including your web request, Internet Protocol address, browser type, browser language and the date and time of your request. This type of collective data enables us to figure out how well the Sites are working so that we can continue to improve our product and services in order to benefit our customers.

When you contact us via contact forms on the Sites, send e-mails or conduct other communications to Medialets, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.

How Personal Information is Used

We use the information we collect from you and your users to:

  • Provide our products and services to users, including the display of customized content, identification, contact, information and authentication
  • Ensure the technical functionality of our products, services and network
  • Improve upon our products and services
  • Better understand the products and services that are of interest to our users

We may use personally identifiable information in an aggregate form to gain a broader perspective of what preferences our users have and to measure interest in the various areas of the Site. In some cases e-mail addresses or phone numbers may be used to contact users regarding service updates, confirmations, opt-in surveys and select partner offers. You may opt-out of receiving marketing messages regarding partner offers.

How Personal Information is Protected

Medialets takes all reasonable measures to protect the security of your personal information during transmission, including the use of Secure Sockets Layer (SSL) software that encrypts the information you supply to our Sites. We also take reasonable measures to safeguard personal information and to protect against unauthorized access, alteration, disclosure or destruction of such information through our data collection, storage and security practices. You should take further precautions to protect personal data by safeguarding your user name and password and by limiting the use of shared computers. All personal information is stored on our secure servers in the United States of America.

How Personal Information is Shared

Medialets does not share your Personal Information except as provided in this Policy or approved by you. We share Personal Information and Non-Personally Identifiable Information collected via the Site with other companies or individuals as follows:

  • With other companies or individuals that help us operate our business, such as with vendors that assist us in sending e-mail, marketing and customer service.
  • With any of our subsidiaries, joint ventures, or other companies under common control with us, in which case we will require them to honor this policy. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred.
  • With third parties to whom you ask us to send Personal Information.
  • In addition, we may aggregate your anonymous information with the anonymous information of others and share that aggregated information with third parties without restriction.

Medialets restricts access to Personal Information to employees, contractors and agents who need to know the information in order to operate, develop or improve our services and to service our customers. We take all reasonable steps to ensure that these parties comply with confidentiality obligations. They may not use such information for any purpose other than providing such services to our Company.

Medialets may also share personal information if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

  • Comply with any applicable law, regulation, legal process or enforceable governmental request
  • Detect, prevent, or otherwise address fraud, security or technical issue
  • Enforce or investigate violations of applicable Terms of Service
  • Protect against harm to the rights, property or safety of Medialets, its employees, its users or the public, as required or permitted by law
  • Allow service providers, vendors, contractors and other agents to fulfill their obligations on behalf of Medialets

Medialets may sell all or certain of our assets or business or Sites. In the event there is an acquisition or sale of some or all of the assets of Medialets, or any product or service thereof, personal information may be shared with relevant buyers or proposed buyers. Medialets will work in good faith to ensure these privacy rights or similar will be conveyed through any such purchase.

Medialets may share aggregate information about you with advertisers, publishers, business partners, sponsors, and other third parties.

How Personal Information is Accessed or Corrected

You can access or correct certain personal information, such as applicable passwords, directly in the Account sections of the Sites. If you have provided Personal Information such as your e-mail address when registering for our Sites, you may modify that information at any time by visiting your Account settings. Notably, since we may use your user name as the account identifier, you may not be able to change your user name. In addition, you can delete your account at any time. Keep in mind, however, that even if you delete your account, we may retain your Personal Information in conformance with our data retention policy, under which we may retain such information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law. There may be residual Personal Information that remains within our databases, access logs, and other records. In addition, we are not responsible for updating or removing your Personal Information already disclosed to third parties who have been provided information as permitted by this Policy. You can opt-out of receiving certain e-mail communications from the Site by clicking the “Unsubscribe” link at the bottom of each e-mail. Please note that even if you unsubscribe or opt-out, we may still send you Site and Service related communications.

Children’s Privacy

The Sites are not intended for children under 13 years of age. You must be at least 13 years old to use the Sites. We do not knowingly collect personally identifiable information from any child under 13 years of age.

B. Mobile Devices, Websites and Applications

Medialets is a provider of technology, tools and services that enable the delivery of advertising on Publisher mobile devices, websites and apps and allow Publishers to learn more about the use of their applications and the advertising delivered through a set of analytic tools. As a service provider, Medialets makes every effort to protect user privacy. However, Medialets does not control the privacy practices of the Publishers. For details on an individual Publisher’s privacy policies, we recommend visiting or contacting the Publisher directly.

In certain instances, Medialets may use HTML5 storage for enabling functionality within an ad or for counting purposes. This can be removed by clearing your browser’s cache. Additionally, should you choose to use our opt-out controls, we will store an anonymous value in your HTML5 database to remove you from being counted by Medialets’ servers.

What Personal Information is Collected

  • Personal Information – We do not collect Personal Information through our technology or services. Medialets does not collect or store the phone number or the unique device IDs for mobile devices. However, Medialets may deliver advertising that is targeted based on location or other user-entered information. Medialets does not store or connect this information to the unique device ID. The advertisements delivered by Medialets may include forms or other prompts that allow users to opt-in to share data. However, it is an End User’s choice whether or not to provide that information. Medialets tracks unique users through a unique, but anonymous, hashcode that cannot be tracked back to a device or any personal information.
  • Publisher Collection of Information – If you use a particular Publisher application or mobile website, that application or mobile website may independently collect information from you. Notably, this policy does not cover such information collected by a Publisher through its application or mobile website. When using a particular application or mobile website, you should familiarize yourself with the given Publisher’s terms and conditions and privacy practices. Medialets is not responsible for, and can not control, a given Publisher’s privacy practices. Publishers may use Medialets technology to request personal information from you. When you opt-in to provide Personal Information to Medialets customers or partners, Medialets restricts access to Personal Information to employees, contractors and agents who need to know the information in order to operate, develop or improve our services and to service our customers. We take all reasonable steps to ensure that these parties comply with confidentiality obligations. These parties may not use such information for any purpose other than providing such services to a Publisher.
  • Non-Personally Identifiable Information – We collect Non-Personally Identifiable Information via our Services and technology. For example, when you use a Publisher mobile application that uses our technology to deliver advertisements, we anonymous track the number of advertisements delivered to a mobile device or mobile website so that we can provide reporting to the Publisher. We also collect anonymous information so that the Publisher can learn more about how End Users are using their applications.

How Information is Shared

We generally do not share Personal Information collected via our Services and technology except as specifically directed by the End User. Medialets may share information collected via our Services and technology with other companies or individuals if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

  • Comply with any applicable law, regulation, legal process or enforceable governmental request;
  • Detect, prevent, or otherwise address fraud, security or technical issues;
  • Enforce or investigate violations of applicable Terms of Service;
  • Protect against harm to the rights, property or safety of Medialets, its employees, its users or the public, as required or permitted by law;
  • Allow service providers, vendors, contractors and other agents to fulfill their obligations on behalf of Medialets.

We share Non-Personally Identifiable Information with the Publishers who use the Medialets technology to deliver advertisements for their own analytics purposes. For example, we provide our Publishers with statistics on trends and the top content segments used so that they can understand how End Users are using their applications. Publishers can use filters to refine the data by domain, time period, geography, and other options. All of this information is anonymous and only available to Publisher’s on an aggregated basis.

Any of our subsidiaries, joint ventures, or other companies under common control with us are required to honor this Policy. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, we expect that any and all information that we have will be among the assets transferred.In addition, we may aggregate your Non-Personally Identifiable Information with the Non-Personally Identifiable Information of others and share that aggregated information with third parties without restriction.

Medialets may share aggregate, anonymous Non-Personally Identifiable Information about you with advertisers, publishers, business partners, sponsors, and other third parties.

How Personal Information is Protected

We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include firewalls and encryption, internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems. Medialets takes all reasonable measures to protect the security of your personal information during transmission, including the use of Secure Sockets Layer (SSL) software that encrypts the information which you supply to our Sites. We also take reasonable measures to safeguard personal information and to protect against unauthorized access, alteration, disclosure or destruction of such information through our data collection, storage and security practices. You should take further precautions to protect personal data by safeguarding your user name and password and by limiting the use of shared computers. All personal information is stored on our secure servers in the United States of America.

Children’s Privacy

We do not knowingly collect personally identifiable information from any children under 13 years of age.

C. General Information

Links to Other Sites

Our Site and Services contain links to third party websites and services. The fact that we link to a website or service or deliver an advertisement to a third party mobile application is not an endorsement, authorization or representation that we are affiliated with that third party, nor is it an endorsement of their privacy or information security policies or practices. This privacy policy applies only as provided in the scope section above. Other websites and services follow different rules regarding the use or disclosure of the personal information. We encourage you to read the privacy policies or statements of the other websites you visit.

International Users

The Site and Services are hosted in the United States. If you access the Site or Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Site or Services, you are transferring your Personal Information to the United States and are consenting to that transfer. Additionally, you understand that your Personal Information may be processed in countries (including the United States) where laws regarding processing Personal Information may be less stringent than in your country.

Modifications

Please note that we may amend this Policy at any time, and from time to time, at our sole discretion. We will post any policy changes on this page and, if the changes are significant, we may provide a more prominent notice, which may include an e-mail notification. The information we collect today is subject to the Policy in effect at the time the information is used. The Policy will always be dated and indicate the most recent modification date. By using our Sites or products and services, you signify your assent to this Policy in full. Your continued use of our Sites will signify your acceptance of the changes to our policy.

Opt-out Button

Medialets stores a unique identifier (unrelated to and not associated with your unique mobile device ID) when you are served an ad by us in a browser. That identifier helps to deliver relevant advertisements, provide aggregated reporting and limit the number of times you see a particular ad. To Opt Out of this tracking, click or tap the button below from the device and browser from which you want to opt out. If you opt out of such tracking, we will continue to collect information from you, but you will no longer have a unique identifier associated with your browser and this information will not be associated with you. Please note that opting out can limit the relevancy of the advertising you receive through Medialets-enabled campaigns.

Opt Out

Questions

Medialets regularly reviews its compliance with this Privacy Policy. If you have any questions or concern about privacy on the Sites, please send an e-mail to privacy@medialets.com.

Policy Dated: August 2012