Privacy Policy

Last Updated on March 28, 2023.

We, at Digital Media Turbine USA, Inc. and our affiliated companies (collectively, “Digital Turbine”, “we”, “us” or “our”), put great efforts in making sure that we secure Personal Data and use it properly.

This Privacy Policy (“Policy”) explains our privacy practices for processing Personal Data related to you when you use the DT Hub described below (collectively: the “Service”). The term “personal data” or “personal information” (both shall be referred to in this policy as “Personal Data”) refers to information that identifies an individual or relates to an identifiable individual or as otherwise defined under applicable data protection and privacy laws

DT provides a wide range of services on your device. Some services are provided by DT as a ‘business’ and some are provided by DT as a ‘service provider’ on behalf of your mobile device carrier (both ‘business’ and ‘service provider’ terms are defined under the California Privacy Rights Act of 2020 (CPRA). This policy applies to end-users of the Service only (“Customers”) where DT hold a position of a business.

The summary of this policy will give you a quick and clear view of our practices. Please take the time to read our full policy. If you do not agree to this Privacy Policy, please do not access, or otherwise use our Service.

A Summary of The Policy

Personal Data That We Collect

When you use the Service, we do not collect or otherwise process any Personal Data.  However, if we decide to include new features into the Service that will require the processing of your Personal Data, we will post an update to this Policy and make it available to you through the DT Hub’s menu.

What Do We Do with Personal Data?

We maintain the Service, make it better and continue developing it, and protect us and the Service from misuse and law violations. Read More.

Who do we Share Personal Data Related to You?

We use service providers, for example, to store data. We will transfer information when we change our corporate structure, and we will share the information with our affiliate entities. Read More.

Disclosure of Personal Data to Authorities

We will obey orders and other lawful requirements by authorities to disclose information. Read More.

Aggregated and Analytical Information

Aggregated data is not identifiable and therefore not Personal Data. We use it for legitimate business purposes and for standard analytical tools. Read More.

Your Choice

You may opt-out of using the Service, via your mobile device setting where you can disable our Service’s app called “GamesHub” by deleting it from your device. Read More.

Your EU Data Subject Rights

If we process personal data related to you when you are in the EU, further terms apply to our processing in relation to your rights as a data subject under EU data protection laws. Read More.

Specific Provisions for California Residents

If you reside in the State of California, further terms apply to our processing in relation to your rights as a data subject under the California Consumer Privacy Act of 2018 (CCPA). Read More.

Personal Data retention

We retain Personal Data to provide the Service and for legitimate and lawful purposes, as further explained in the data retention section of the policy. Read More.

Transfer of Data Outside Your Territory

We keep Personal Data related to you in the United States and in the EEA, and will store them at additional sites, at our discretion. Our service providers provide us adequate security and confidentiality commitments. Read More.

Information Security

We implement systems, applications, and procedures to secure Personal Data related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. Read More.

Dispute Resolution

Contact us at: privacy@digitalturbine.com or write us for every request and complaint. We will make good-faith efforts to resolve any existing or potential dispute with you. Read More.

Changes to this Privacy Policy

We will update our policy from time to time after giving proper notice. Read More.

Contact Us

Please contact us at: privacy@digitalturbine.com for further information. Read More.

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The Digital Turbine Privacy Policy

Personal Data That We Collect

When you use the Service, we currently do not collect any Personal Data from you or from your mobile device. However, if we decide to include new features into the Service that will require the processing of your Personal Data, we will post an update to this Policy and make it available to you through the DT Hub’s menu.

If we would use your Personal Data in the future we would use Personal Data related to you for the following purposes:

• to provide you and other Customers with the Service and to enable specific features of the Service, such as app’s selection and installation;
• to provide you with notifications related to your use of the Service, such as personalized apps’ recommendations;
• where the provision of feedback is available to provide your feedback;
• to provide you with technical support related to our Service;
• to maintain the Service and to make it better for you and other Customers using it; and,

to continue developing the Service.

• to record the installation of apps you choose to install on the device.
• to provide you with gaming- related content and/or experience that may also include targeted ads.

We obey the law and expect you to do the same. If necessary, we will use Personal Data related to you to enforce our terms, policies, and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Service, and to take any action in any legal dispute and proceeding.

We commit to process Personal Data related to you solely for the purposes described in this policy.

We do not sell, rent, or lease Personal Data related to you.

Personal Data related to you is shared with certain members of our staff, as well as external consultants and with our affiliates, who are all governed by this Policy.

We also share Personal Data related to you with our agents worldwide and with third-party service providers which process Personal Data related to you on our behalf. Such agents and service providers will be contractually bound to keep Personal Data related to you confidential and appropriately secure.

A merger, acquisition or any other structural change will require us to transfer Personal Data related to you to another entity, as part of the structural change, provided that the receiving entity will comply with this Policy.

We will share Personal Data related to you only subject to the terms of this Policy, or subject to your prior consent.

We will need to disclose Personal Data related to you in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We use anonymous, statistical, or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that we or others can associate specifically to you.

We will give you choices about the ways we use and share Personal Data related to you, and we will respect the choices you make.

We collect and receive Personal Data related to you that we need for the purposes described in this policy. You can stop using the Service at any time, thereafter we will stop collecting Personal Data related to you. However, we will store and continue to use or make available certain Personal Data related to you as detailed above.

You may request that Personal Data related to you be deleted by contacting us.

You may request a copy of the Personal Data that we store about you by contacting us. You may also request that we transfer Personal Data related to you to a third-party, or that we provide you with copies of such Personal Data to enable its transfer to a third-party.

When we delete Personal Data related to you that we have collected from or about you, it will be deleted from our active databases, but we will keep a reasonable number of copies in our archives. We will continue to retain the Personal Data related to you for legitimate business purposes as set forth above.

You may also control what Personal Data we collect from your device by changing the permissions settings on your mobile device.

If you wish to exercise any of your rights in relation to Personal Data related to you, including exercising your choices or opt-out rights, please send us an email to privacy@DigitalTurbine.com.

If EU data protection laws apply to the processing of the Personal Data related to you by Digital Turbine, then the following terms apply:

Where we process personal data related to you as a data controller, the processing is based on the following lawful grounds:

• All processing of Personal Data related to you which are not based on the lawful grounds indicated below, are based on your consent.
• We will process Personal Data related to you to comply with a legal obligation and to protect your and others’ vital interests.
• We will further rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes:
  • Communications with you where you contact us through our digital assets, for example if you send us a data deletion or access request.
  • Cyber security.
  • Support, customer relations, and service operations.
  • Enhancements and improvements to the user experience of our Service, and for training of our personnel.
  • Fraud detection and misuse of the Service.

In addition to your rights under other sections in this policy, you have the following rights:

• At any time, contact us if you want to withdraw your consent to the processing of personal data related to you. Note however that exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
• Request to delete or restrict access to Personal Data related to you. We will review your request and use our judgment, pursuant to the provisions of applicable law, to reach a decision about your request.
• If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third-parties that hold personal data related to you, in accordance with this policy, act accordingly.
• You may ask to transfer personal data related to you in accordance with your right to data portability.
• We do not process Personal Data related to you for the purpose of making decisions based solely on automated processing which produces legal effects concerning you or similarly significantly affecting you.
• You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the GDPR.

A summary and further details about your rights under EU data protection laws, is available on the EU Commission’s  n available at: Rights for citizens | European Commission (europa.eu).

Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will further ask your questions to understand the nature and scope of your request.

If we need to delete personal data related to you following your request, it will take some time until we completely delete residual copies of personal data related to you from our active servers and from our backup systems.

If you have any concerns about the way we process personal data related to you, you are welcome to contact our privacy team at: privacy@digital turbine.com. We will look into your inquiry and make good-faith efforts to respond promptly.

This section applies solely to users who reside in the State of California and other applicable US States. This chapter supersedes any contradicting provisions under the other sections of this policy. When used under this chapter, the term Personal Data will also mean Personal Information, as such term is defined under the California Privacy Rights Act of 2020 (CPRA).

We have collected the Personal Data related to you which is described above under the section “The Personal Data that We Collect and Store” of this Policy. Such Information consists of the following categories:

• Identifiers and Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
• Commercial information, including services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, and app installations.
• Internet or other similar network activity.
• Inferences drawn from any of the above-mentioned information.

We obtain the categories of Personal Data related to you listed above from the following categories of sources:

• Directly and indirectly from you and your activity on the Service.
• Third parties such as reliable service providers.

We use the Personal Data related to you that we collect or receive for the purposes mentioned under the section “How We Use Your Personal Information?” of this Policy.

We disclose Personal Data related to you to third parties for business purposes as described above under the section titled “Information Sharing and Disclosure?”.

The Service is not intended to collect Sensitive Personal Information (as defined under the CPRA). We do not knowingly collect Sensitive Personal Information, and we require you not to provide us with any such information.

Selling and Sharing Personal Information

We do not sell or share Personal Data. However, we may engage third parties to provide us with services such as analytics, marketing automation and user experience and, for these purposes only, we may allow them to collect Personal Data on our Service.

We do not knowingly sell or share the Personal Data of children, as such term is defined under applicable privacy laws.

The categories of Personal Data collected by these third parties in the preceding 12 months include identifiers, online activities and inferences drawn from such activities.

These third parties do not pay us for collecting such information, but the right granted to them to collect Personal Data may be considered as disclosure for the purpose of sale or share for cross-context behavioral advertising. At any time, you can opt-out of the collection of Personal Data by our service providers by contacting us.

Your rights as a California Resident

You are entitled to the following specific rights under the CPRA, and other applicable US state consumer privacy acts, in relation to Personal Information:

• Access to specific Personal Data and data portability rights – you have the right to request that we will disclose certain information to you about our collection and use of Personal Data related to you over the past 12 months. Upon verification of your request, we will disclose to you:
  • The categories of Personal Data we collected about you;
  • The categories of sources for the Personal Data we collected about you;
  • Our business or commercial purpose for collecting that Personal Data;
  • The categories of Personal Data that we disclosed for a business purpose, and the categories of third parties with whom we disclosed that particular category of Personal Data;
  • The specific pieces of Personal Data that we collected about you;
  • If we disclosed Personal Data related to you for a business purpose, we will provide you with a list which will identify the Personal Data categories that each category of recipient obtained.
• Deletion rights – you have the right to request that we delete any of Personal Data related to you. Upon confirmation of your request, we will delete Personal Data related to you from our records, unless an exception under the CPRA applies.
• Non-discrimination – you also have a right not to be discriminated against for exercising your rights under the CPRA.

Exercising Your Rights

To exercise the access, data portability, and deletion rights described above, please submit your request to us by sending an email message to: privacy@digitalturbine.com. Only you or a person authorized to act on your behalf, may make a request related to Personal Data related to you. A request for access can be made by you only twice within a 12-month period.

The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with the requested Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Data related to you. We will only use the Personal Data provided in your request to verify your identity or authority to make the request.

We will do our best to respond to your request within 30 days of its receipt. If we require more time (up to additional 30 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before completing your request.

We retain different types of Personal Data related to you for different periods, depending on the purposes for processing the information, our legitimate business purposes, and pursuant to legal requirements under applicable law.

We may maintain your contact details, to help us stay in contact with you, in case such information was provided to us by you. At any time, you can contact our privacy team at: privacy@digitalturbine.com and request to delete your contact details. Note that we will keep your details without using them if necessary, and for the necessary period of time, for legal requirements and proceedings.

We may retain Personal Data related to you after you have terminated your use of the Service, if retention is reasonably necessary to resolve disputes between our users, to prevent fraud and abuse, or to enforce this policy. We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.

In any case, we will keep information about you for as long as you use the Service, unless applicable law requires us to delete it, or if we decide to remove it at our discretion, according to the terms of this policy.

We store and process information, including Personal Data, either directly or by using third parties such as data hosting service providers, in the United States. The laws of the United States may differ from the laws of the jurisdiction in which you live.

If you are a resident in a jurisdiction where transfer of Personal Data related to you to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer.

If you are located in the European Economic Area (EEA), note that we will transfer personal data related to you to other jurisdictions, which are not deemed to provide an adequate level of data protection. In such case, we will use appropriate safeguards, in particular, by way of entering into the European Union (EU) Standard Contractual Clauses as amended from time to time with the relevant recipients, or by adhering to equivalent data transfer regulations to protect the security and confidentiality of such Personal Data. You can obtain a copy of the suitable safeguards that we use when transferring Personal Data as described above or receive further information about data transfer by contacting us at: privacy@digitalturbine.com.

We make sure that our third-party service providers, provide us with adequate confidentiality and security commitments and we will take all steps reasonably necessary to ensure that Personal Data related to you is treated securely and in accordance with this policy.

Digital Turbine is committed to ensuring the security of Personal Data. We and our hosting services implement systems, applications, and procedures to secure Personal Data related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry standard security.

However, please understand that no security system is impenetrable, and although we make efforts to protect your privacy, we cannot guarantee that the Service will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this policy, to update the policy when we believe that we need to, and to verify that we display the policy properly and in an accessible manner. If you have any concerns about the way we process Personal Data related to you, you are welcome to contact our privacy team at: privacy@digitalturbine.com, or write to us.

We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you.

From time to time, we will update this policy. If the updates have minor if any consequences, they will take effect 14 days after we post a notice on the Service. Substantial changes will be effective 30 days after we initially posted the notice.

Until the new policy takes effect, if it materially reduces the protection of your privacy under the then-existing policy you can choose not to accept it and terminate your use of the Service. Continuing to use the Service after the new policy takes effect means that you agree to the new policy. Note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required by law.

Contact Us

Please contact us at: privacy@digitalturbine.com

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