NEXAGE SERVICE PRIVACY POLICY 

Effective Date: December 05, 2014

Nexage is committed to being a responsible participant in the mobile advertising ecosystem and to protecting personal information about Internet, mobile Internet, and mobile application users. This privacy policy explains what information we collect, how we secure it, and how we use it in relation to the service Nexage provides to its customers.

Nexage is an independently-operated subsidiary of Millennial Media.  To learn about Millennial Media’s data collection and use practices for other parts of its business, please visit http://www.millennialmedia.com/privacy-policy/.

Nexage operates a mobile advertising exchange platform (the “Platform”) where we partner with publishers and application developers (referred to collectively as “Publishers”) to sell available advertising inventory on their sites and applications to our advertising buying customers.  Our goal in doing so is to (1) provide Publishers with a mechanism to efficiently sell their advertising inventory while deriving the most value for the Publisher, and (2) enabling our ad-buying partners to reach the audience that meets their advertising campaign goals. In operating our service, Nexage adheres to all laws and industry guidelines in relation to our privacy practices.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

Publishers transfer certain information to Nexage that we use to enable the delivery of relevant advertisements to consumers on their mobile phones by our ad-buying customers. When our Publisher’s end-user devices interact with our Platform, it may automatically pass information that our Publishers provide or is otherwise accessible on the advertising request.  Nexage endeavors to receive the assurance from our Publishers that, through clear notice mechanisms, the Publisher has the right to pass such information to the Platform. This Publisher notice should advise the end-user why the information is being collected and that it’s being used for advertising purposes. Nexage regularly works with its partners to provide improved mechanisms to manage consumer notice and control over their advertising experience in the mobile environment. 

WHAT INFORMATION DO WE RECEIVE FROM OUR PUBLISHERS OR IS OTHERWISE ACCESSIBLE BY NEXAGE:

Non-Personally Identifiable Information.  Publishers and developers may send non-personally identifiable information* (NPII) to Nexage with an ad request in accordance with the Publishers stated privacy practices and notices. Examples of this type of information include, but are not limited to, age, gender, zip code, and location information.  

Anonymous Device Identifiers. Many mobile devices have identifiers (“Device IDs) which are accessible by Publishers and which can be passed to Nexage with an ad request. These Device IDs do not enable Nexage to identify individuals, but rather can be used for certain advertising purposes. It can be used to limit the number of times a specific advertisement is presented to the same device, track a device to show that the device interacted with an ad (i.e. “clicked” on it, watched a video ad, or downloaded an application as a result of an advertisement). If Nexage stores a Device ID, it would be for these advertising administrative purposes, and would not be used to create profiles of end-users over time.

Nexage may also partner with third parties that have their own methods of identifying a device. These can be used as described above, or in some cases can be used for the purposes of supporting 3rd party targeted advertising solutions. Where these solutions are employed, Nexage will work with our Publishers or otherwise endeavor to provide end-users with the ability to opt-out of these solutions.

Personall Identifiable Information.  Nexage’s agreements with its Publishers prohibit the passing of information that alone, or in combination with other data provided by the Publisher, would enable Nexage to identify any person individually.   

Other Information Available from the Ad Request. Nexage may also collect information that it can see about an end-user’s device and the manner in which it has connected to the Internet (such as mobile carrier, IP Address, phone model, etc.). This information is not necessarily provided by the Publisher, but the information is passed from the device via an application or mobile website to support the delivery of advertising or to otherwise support functionality of the device or application.

Information Collected by Nexage Directly.  Nexage may also collect NPII about how consumers interact with ads delivered, such as anonymously counting clicks. Further, when available, Nexage may partner with third-party companies that enable targeting of advertising based on information that is in addition to what the Publisher may provide or is otherwise available to Nexage. When partnering with these third-party data providers, Nexage does not accept, use or store PII.  These services may have information about end-users past browsing or application use which can be used to enable the delivery of more relevant advertising to the end-user.

Cookies: Nexage may use a simple technology feature on your mobile browser (not on mobile applications – where cookies are not generally utilized). Nexage will place a cookie on your browser unless your browser settings are set to prohibit this. Cookies are used to recognize a device they have encountered before. This may be used by Nexage for frequency capping (limiting the number times you see an advertisement) and other advertising administrative type functions, and may also be used to support 3rd party targeted advertising solutions. As with Device IDs, where cookies are being used to support 3rdparty targeted advertising solutions, Nexage will work with Publishers or will otherwise endeavor to enable end-users to opt-out of this type of advertising.  As the mobile advertising ecosystem evolves, and if cookies or equivalent technologies become more available for mobile advertising, Nexage may amend this policy to provide further notice regarding their use. 

UNDERSTANDING ADVERTISING AND TARGETED ADVERTISING

At Nexage, we try to make sure that end-users, Publishers and ad-buyers have access to information that would enable them to understand best practices around advertising and targeted advertising, as well as methods to provide or take advantage of opportunities to opt-out of certain types of advertising. Targeting and Opt-out solutions are limited in mobile advertising compared to online advertising, primarily because the technologies used in online are not as readily available in the mobile ecosystem. Regardless, to ensure that you understand what information we may receive from publishers and developers, Nexage encourages you to review the privacy policies for mobile web sites and applications that you use.  To learn more about targeted advertising and managing your privacy preferences, you can also visit the Network Advertising Initiative’s website.

INFORMATION SHARING AND DISCLOSURE

Nexage may provide copies of log files to Publishers and ad-buying partners and certain relating to the performance of advertising campaigns, and other specific transactions they are a party to on the Platform.  These files contain information that allows partners to analyze the effectiveness and performance of their advertising campaigns.  Our partners also have the ability to use information collected in connection with the use of our Platform for their own purposes, provided such is in compliance with their own privacy practices as communicated to their end-users. The information provided to Publishers or ad-buyer does not contain PII.  Where Nexage provides information to our partners, they are required to use the information they receive in compliance with applicable laws and regulations.

Nexage may share the information it collects with selected partners, vendors, agents or others who work on our behalf, in order to provide products or services for our Publishers or ad-buying customers.  Nexage does not work with, receive or endeavor to compile PII, so information provided to third-parties will never contain PII.

Notwithstanding the other statements in this policy, Nexage may disclose information if required by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect or defend legal rights or property, or (iii) protect the personal safety of individuals or the public.

CHILDREN’S PRIVACY

Nexage does not knowingly collect, store, or use information about children under the age of 13.  If we become aware of information in our system that relates to a child under 13, we will take commercially reasonable steps to delete that information. 

STORING OF DATA AND SECURITY

Nexage takes data security seriously.  Anonymous and aggregated information that we may store on our servers is done so in a secure manner with electronic, physical, and administrative safeguards designed to protect against unauthorized access to such information.

CHANGES TO POLICY

Nexage reserves the right to change this privacy policy from time to time, by posting a new policy on www.nexage.com.  In the event that we must make a material change to our practices or this policy, we will make every effort to update this policy at least 30 days prior to implementing the change.

If you have questions about this policy or the privacy practices applicable to Nexage’s mobile ad services, contact us at privacy@nexage.com.

*TERMINOLOGY

Non-personally identifiable information (NPII) – When we refer to non-personally identifiable information (NPII), we mean information such as demographic, behavioral, unique device identifiers, age, gender, zip code, or other information that alone, or in combination with other available information, does not identify you to Nexage.

Personally identifiable information (PII) – When we refer to personally identifiable information (PII), we mean information such as first and last name, email or home address, or phone number that, either by itself or in combination with data reasonably obtainable by Nexage from another source, could be used by Nexage to personally identify an end- user.

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