Effective Date: April 19, 2018

Introduction

Sift Media, Inc. (“we,” “us,” “our” or “Sift”) is a mobile advertising company that provides a platform to deliver more targeted advertising to consumers. Our technology enables our partners to show mobile application users more relevant advertising that is based on users’ interests and behaviors. In order to provide these services, we collect and use certain information about user activity and preferences.

Sift recognizes the importance of consumer privacy and we are committed to treating your personal information in accordance with applicable data protection laws and regulations. In addition, we support and adhere to all applicable industry self-regulatory programs, principles, and guidance published by the Network Advertising Initiative (NAI), the Digital Advertising Alliance (DAA), and the Interactive Advertising Bureau (IAB). To learn more about each of these organizations, please click the links below:

To this end, we have designed the Sift Privacy Policy (this “Privacy Policy”) in a format that is easy to navigate and read so that you can clearly understand our privacy practices. Please read this Privacy Policy carefully.

What This Policy Covers

This Privacy Policy explains how we collect, use, and share information through our advertising platform (“Services”) and our corporate website at www.sift.co (“Site”), as well as your choices and rights associated with that information. Additionally, this Privacy Policy addresses specific provisions for EU individuals covered under the General Data Protection Regulation (“GDPR”).

Table of Contents

Definitions

The following is a non-exhaustive list of definitions of words and phrases found in this document:

"Analytics Services" refers to usage of data visualization and analysis tools and reports made available to Customers through a secure user interface or via authorized distributed reports characterizing and containing aggregated User Data.

"Customer" refers to app owners, developers, marketers, or agencies making use of Sift Services, or having signed up for Sift Services via our Site.

"Customer Data" refers to any data collected during registration as a Sift Customer or provided by Sift Customers through the use of Sift Services. This may include personal information such as name, mailing address, email address, phone number, and payment information.

“EU” refers to the European Union or European Economic Area.

"End Users" refers to users of mobile applications developed and operated by Sift Customers.

"Sift" refers to Sift Media, Inc.

"Services" refers to either Analytics Services or Targeted Advertising Services, or both.

"Site" refers to our website, www.sift.co.

"Targeted Advertising Services" refers to the use of collected and aggregated User Data to deliver targeted and relevant advertisements.

"User Data" refers to characteristics and behaviors of End Users.

Advertising Services Privacy Policy

This section describes the information we collect, use, and share through our Services.

Information Collection

Customers are responsible for providing End Users with notice and obtaining all applicable End User consents to Sift’s collection and use of User Data.

If you are an End User, Sift may collect information about your device through your interaction with certain mobile apps and advertisements, including device attributes such as: operating system, hardware version, device settings, IP address, time zone, device carrier, applications installed on the device, and device advertising identifiers. We may also collect certain demographic information (such as age, gender, territory) and information about End User behavior when using a customer’s mobile application. If you have enabled location tracking in your application, we may receive certain location information about your device.

If you are a Customer who uses the Services in connection with your mobile applications, we collect certain usage data about the operation of your applications, the mobile devices that run your applications, and user interactions with your applications and certain other applications on the device. We do not collect information that can be used to identify an individual, except on an anonymous basis.

Information Use

We may use User Data to:

  • Perform Analytics Services on behalf of Customers;
  • Perform Targeted Advertising Services on behalf of Customers;
  • Create, analyze, market, distribute to third parties, and make available for sale aggregated and anonymous targeting segments for digital advertising purposes; and
  • Perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our Service.

Information Sharing

We may share information we collect through our Services for the following purposes:

  • To provide our Customers with the Services, such as to deliver relevant advertising, and to provide attribution;
  • For analytics and research purposes;
  • As part of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
  • In response to a subpoena, court order, or other legal matter;
  • To protect our rights and the rights of others if sharing the information may prevent physical, financial or other harm, injury, or loss; and
  • To protect your safety or the safety of others, or in connection with an investigation of suspected or actual unlawful activity.

User Choice and Opt-Out

If you are an End User and want to opt-out from collection and use of identifiers for ad targeting on your device, you can do so through your device settings. For example:

  • Android Devices: Go to Google Settings > Ads, and turn on “Opt out of Ads Personalization.”
  • iOS Devices: Go to Settings > Privacy > Advertising, and turn on “Limit Ad Tracking.”

You can also reset the mobile advertising identifiers on your mobile device to limit advertisers in tracking your past activity. For example:

  • Android Devices: Go to Google Settings > Ads, and tap on “Reset advertising ID.”
  • iOS Devices: Go to Settings > Privacy > Advertising, and tap on “Reset Advertising Identifier,” then tap on “Reset Identifier.”

End Users who do not want the Sift Services to collect any information about them may opt-out of such collection by visiting the Sift Opt-out (https://www.sift.co/optout) and following the opt-out instructions.

Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of categories of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To make such a request, please contact us at privacy@sift.co.

Protecting Children’s Privacy

Our Service is not intended for use by Children under the age of 13. We do not knowingly collect personal information from children under the age of 13 through the Service except as permitted by US law.

Accessing Your Personal Information

You can update, correct, or delete the personal information you provide to us by contacting us at privacy@sift.co. Please be aware that Sift may need to ask you to provide certain credentials to verify your identity.

Please note that we may retain and use your personal information as necessary to comply with its legal obligations, resolve disputes, and enforce our agreements.

Specific Provisions for EU Individuals

Legal Basis for Processing

As the data processor, Sift relies on the explicit consent of the EU individual (End User) that is given through our Customer’s mobile application in order for our Services to process personal data. Please note that Sift will not be storing user profiles of EU individuals and will only retain pseudonymous data such as device identifier and IP address for 30 days.

On other occasions, we may process personal data when it is necessary for the performance of a contract or where required by law. Sift may also process personal data when it is in Sift’s or its Customer’s legitimate interests to do so and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include improving Sift’s Services.

For questions regarding data processing, please contact our Data Protection Officer at privacy@sift.co.

Your EU Data Subject Rights

If you are an EU individual and have provided consent through our Customer’s mobile application for our Services to process your personal data, you may be entitled to:

  • Request access to the personal data that we keep about you;
  • Request that we rectify or erase your personal data;
  • Request that we restrict or object to the processing of your personal data;
  • Request the transfer of your personal data in accordance with your right to data portability;
  • Withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
  • Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you; and
  • Lodge a complaint with a data protection supervisory authority.

All requests submitted to Sift will be processed in a timely manner. To submit a request, please contact our Data Protection Officer at privacy@sift.co.

Children

We do not knowingly collect personal information from children under the age of 16 through the Services.

Data Retention

Sift will not retain data longer than is necessary to fulfill purposes for which it was collected or as required by applicable laws or regulations.

Data Security

Sift cares about the security of your information and we take certain measures to protect your personal data. However, no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your information.

Data Transfers

Please be aware that the information we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store information in the United States and your consent to this Privacy Policy represents your agreement to this processing.

Website Privacy Policy

This section describes the information we collect, use, and share through our Site.

Information Collection

Whenever you visit our Site, Sift may collect personal information that you voluntarily provide to us. Such information may include personal information such as your name, company name, email address, or any other information when you complete the online forms available on the Site.

If you are a Customer with an account, we collect certain personal information from you when you sign up for our Services that can be used to identify you, such as your name, e-mail address, mailing address, phone number, and payment information.

We may also collect certain types of information automatically about your activity and interaction with the Site, such as your IP address, referring URL, browser, operating system, cookie information, viewed web pages, and Internet Service Provider. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, this information alone cannot usually be used to identify you.

Information Use

We may use the information we collect through the Site for the following purposes:

  • Respond to your questions, concerns, or inquiries;
  • Send information about our products and services, including marketing communications;
  • Understand usage trends and preferences;
  • Operate and improve the Site and our Services;
  • Process transactions between customers and Sift; and
  • Perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our Site.

Information Sharing

We may share the information we collect through the Site for the following purposes:

  • With your consent, including through this Privacy Policy;
  • With third party individuals and organizations to assist us in providing Services, including contractors, web hosts, advertising platform and services providers, and others;
  • As part of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
  • In response to a subpoena, court order, or other legal matter;
  • To protect our rights and the rights of others if sharing the information may prevent physical, financial or other harm, injury, or loss; and
  • To protect your safety or the safety of others, or in connection with an investigation of suspected or actual unlawful activity.

Cookies

We use cookies on our Site. "Cookies" are small pieces of information or files that a website puts on your computer which allow Sift to collect information about your navigation of the Site and ease such navigation. For more information about cookies, please visit http://www.allaboutcookies.org cookies.

User Choice and Opt-Out

At any time, you may unsubscribe from Sift’s newsletters list. To do so, please send us an opt-out request to privacy@sift.co or follow the unsubscribe instructions in such communications. 

You can set your browser to not accept cookies, but this may limit your ability to use the Site. You may also be able to change your browser settings to refuse third-party cookies or to indicate when a third-party cookie is being sent. Check your browser's "Help" files to learn more about handling cookies on your browser. You can also opt-out of receiving interest-based ads from certain ad networks, please visit http://www.networkadvertising.org (or if located in the European Union, please visit http://www.youronlinechoices.eu).

Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of categories of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To make such a request, please contact us at privacy@sift.co.

Protecting Children’s Privacy

Our Site is not intended for use by Children under the age of 13. We do not knowingly collect personal information from children under the age of 13 through the Site except as permitted by US law.

Accessing Your Personal Information

You can update, correct, or delete the personal information you provide to us by contacting us at privacy@sift.co. Please be aware that Sift may need to ask you to provide certain credentials to verify your identity.

Please note that we may retain and use your personal information as necessary to comply with its legal obligations, resolve disputes, and enforce our agreements.

Specific Provisions for EU Individuals

Legal Basis for Processing

As the data controller, Sift relies on the explicit consent of the EU individual when entering personal data through the Site (such as when completing the online forms available on the Site). In response, Sift may process the personal data to respond to your inquiry. On other occasions, we may process personal data when it is necessary for the performance of a contract or where required by law.

Sift may also process personal data when it is in Sift’s legitimate interests to do so and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include improving Sift’s Site or Services.

For questions regarding data processing, please contact our Data Protection Officer at privacy@sift.co.

Your EU Data Subject Rights

If you are an EU individual and have entered your personal data through the Site, you may be entitled to:

  • Request access to the personal data that we keep about you;
  • Request that we rectify or erase your personal data;
  • Request that we restrict or object to the processing of your personal data;
  • Request the transfer of your personal data in accordance with your right to data portability;
  • Withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
  • Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you; and
  • Lodge a complaint with a data protection supervisory authority.

All requests submitted to Sift will be processed in a timely manner. To submit a request, please contact our Data Protection Officer at privacy@sift.co.

Children

We do not knowingly collect personal information from children under the age of 16 through the Site.

Third Party Websites

Sift may post links to third party websites on its Site. These third party websites are not screened for privacy or security issues by Sift, and you release us from any liability for the conduct of these third party websites.

Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, does not create rights enforceable by third parties or require disclosure of any personal information relating to members of the Site. Sift bears no responsibility for the information collected or used by any advertiser or third party website. Please review the privacy policy and terms of service for each site you visit through third party links.

Data Retention

Sift will not retain data longer than is necessary to fulfill purposes for which it was collected or as required by applicable laws or regulations.

Data Security

Sift cares about the security of your information and we take certain measures to enhance the security of our Site, including SSL certificates. However, no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your information. If you contact us by email or through our “contact us” form on our Site, please be aware that your transmission might not be secure as these methods generally lack encryption and a third party could potentially view information you send by these methods.

Data Transfers

Please be aware that the information we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store information in the United States and your consent to this Privacy Policy represents your agreement to this processing.

Policy Changes

From time to time, Sift may update this Privacy Policy to reflect changes to our privacy practices. If we do so, the “Effective Date” posted at the top of the Privacy Policy will be updated as well. For any material changes to the Privacy Policy, we will notify you by email (sent to the email address on record) or by providing a notice on the Site prior to the updated Privacy Policy becoming effective. Please review the Privacy Policy periodically to ensure that you understand how we collect, use, and share information.

Any changes to the Privacy Policy will become effective once the updated Privacy Policy is posted on the Site. By continuing to use the Site or Services following such changes, you are agreeing to accept the terms of the revised Privacy Policy.

Contact Us

If you have questions, complaints, or would like to report a potential privacy violation in relation to Sift's Site or Services, please contact our Data Protection Officer at privacy@sift.co.

You can also write to us at our corporate address:

Sift Media, Inc.
Attn: Data Protection Officer
201 West Main Street
Suite 300, PMB 312
Durham, NC 27701