Fyber’s Test App Privacy Policy

This privacy statement (“Privacy Policy”) explains Fyber’s privacy practices for processing personal information on its Test App. The Test App was developed and is owned by Fyber Monetization Ltd. (“Fyber”).

Using the Test App enables the app’s users (“Users”) to do the following:

• Test the app’s tools, features and functionality, as well as the way ads are rendered, presented, viewed and placated on the Test App;
• Examine, analyze and evaluate the functionality and performance of the SDK that is integrated with the app;

Fyber is committed to protect User’s privacy and will process Users’ personal information solely for the purposes that are described in this Privacy Policy.

The Test App is not directed to children 16 years of age and under and Fyber does not intentionally or knowingly collects personal Information of such users.

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1. The Personal Information that Fyber Collects and Processes when the Test App is being used

When a User interacts with the Test App, Fyber collects, via the SDK that is integrated with the app, information, which may include personal information about the User and the User device as follows:

• Information about a User’s device, such as device type and model, network provider, browser type, language.
• Information about User’s operation system, such as Android, iOS.
• Information about User’s mobile advertising identifiers, such as Apple IDFA or Google AAID.
• Information that User’s device provides, such as device IP address (only if the User provided permission for the app to collect your location information), network connection type

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2. Fyber processes User’s Personal Information?

Fyber collects personal information in order to allow Users to evaluate the performance of the SDK that is incorporated in the app and the performance of ad campaigns on the app. While not all of the Test App’s features require the processing of personal information, Users who intend to test the full spectrum of the SDK’s functionalities may provide consent for such processing within the Test App in order to do so. When a User provide such consent Fyber will process User’s personal information to demonstrate such functionalities that are available on the Test App.

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3. Sharing Personal Information with Others

Fyber shares User’s personal information for the purpose of enabling and optimizing the delivery of ads to Users on the Test App as follows:

• Fyber shares personal information with an ad monetization platform (that is also operated and owned by Fyber, the “Ad Monetization Platform”) for the sole purpose of enabling the delivery of ads to Users of the Test App. Such ads may be targeted or contextual and will be delivered to Users on the Test App by third party advertisers that are connected to the Ad Monetization Platform. The decision which ad to deliver to a particular User on the Test App will be made solely by such third-party advertisers based on the information and personal information that will be shared with them for this purpose by Fyber. To deliver quality ads to the app’s Users personal information will also be processed by the ad monetization platform and/or its third-party advertisers for optimization of the ad campaign, capping, fraud detection, reporting and analytics (collectively, the “Ad Monetization Platform Services”).
• Fyber may share or transfer User’s personal information if Fyber is involved in a merger, acquisition, or sale of all or a portion of its assets, as part of such transaction, to support to continued provision of the Services by the entity which will assume the ownership of the Test App and will continue to protect such personal information as required under applicable laws and pursuant to this Privacy Policy.
• Fyber uses the analytics tools Countly to support the Test App and may use additional or other analytics tools, from time to time. The privacy practices of these tools are subject to their own privacy policies. See Countly’s Privacy Policy at: https://count.ly/legal/privacy-policy.
• Fyber may also share User’s personal information with law enforcement agencies, courts, and other government organizations: (a) as required by law, such as to comply with a subpoena, or similar legal process; or (b) when Fyber believes in good faith that the disclosure or sharing is necessary to protect rights, protect User’s safety or the safety of others, investigate fraud, or respond to a government request.

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4. Aggregated and Analytical Information

Fyber uses anonymous, statistical or aggregated information to monitor the functionality of the Test App. Such data processing has no effect on the User’s privacy as it cannot be associated with or identifiable to any User.

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5. User’s Choice

A User can opt-out from location-based advertising, limit the use of tracking data for ad targeting, opt-out of targeted advertising.

If a User wishes to opt-out from collection and use of precise location data for advertising purpose, the User can turn location services off through the User’s device settings. The latest versions of iOS and Android allow a User to limit which particular applications can access the User’s location information.

A User also can limit the use of identifiers for ad targeting on the User’s devices. If a User turns on this setting, mobile applications are not permitted to use the advertising identifier to serve consumers targeted ads.

As an example, for iOS, the controls are available through Settings > Privacy > Advertising > Limit Ad Tracking. For Android, Google Settings > Ads > Opt Out of Interest-Based Ads.

Although this tool will limit the use of tracking data for targeting ads, companies will still be able to monitor users’ mobile application usage for other purposes, such as research, measurement, and fraud prevention.

A User can reset the identifiers on the User’s mobile device in the device settings. iOS users can do this by following Settings > Privacy > Advertising > Reset Advertising Identifier. For Android, the path is Google settings > Ads > Reset advertising ID.

Following such restart, the device is harder to be associate with past activity, but tracking can restart with a new advertising identifier.

If a User would like to opt-out from Demand Partners’ use of personal information about the User, to serve targeted advertising to the User’s mobile application, the User can download the Digital Advertising Alliance’s mobile application for each of the User’s devices and set the User’s preferences in the mobile application.

• Download AppChoices for iOS devices
• Download AppChoices for Android devices

If a User resets the mobile advertising identifiers, the User will also need to reset the User’s preferences in the AppChoices applications.

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6. GDPR and EU Data Subject Rights

Fyber is committed to fulfill data subjects’ rights under the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) as follows:

When the User is using the Test App, Fyber processes personal data as a data controller (as this term is defined in the GDPR). As a data controller, Fyber is committed to fulfill data subjects’ (i.e. Users) GDPR rights. This section applies to GDPR-covered processing of personal data of Users. Fyber’s lawful ground for processing of User’s personal data is as follows:

• All processing of personal data related to Users which are not based on the lawful ground indicated below, are based on User’s explicit consent.
• Fyber process User’s personal data to provide the User with the functionality of the Test App.
• Fyber will process personal data related to Users to comply with a legal obligation and to protect User and others’ vital interests.
• Fyber will rely on its legitimate interests, which Fyber believes are not overridden by User’s fundamental rights and freedoms, for the following purposes:
  • Cyber security;
  • Enhancements and improvements of the user experience on the Test App;
  • Detection of fraud and/or misuse of the Test App.

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Data Subject Rights:

Under the GDPR the User of the Test App has a right to:

• Request to access the personal data that Fyber keeps about the User. Fyber will need to ask the User to provide credentials to make sure that the User is who the User claims to be. If you find that the requested data is not accurate, complete or updated, then you can provide us with the necessary information to rectify it.
• Request to withdraw consent– Users should contact Fyber if they want to withdraw their consent to the processing of personal data related to the User. Exercising this right will not affect the lawfulness of processing based on consent before such withdrawal.
• Request to delete or restrict access to personal data related to you. Fyber will postpone or deny your request if personal data related to you is in current use while making the Test App available to you or due to other legitimate purposes, such as compliance with regulatory requirements associated with Fyber.

If a User exercises one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, the User can request to be informed that third parties that hold personal data related to such User, in accordance with this Policy, will act accordingly.

• Request to transfer personal data related to the User in accordance with the User’s right to data portability.
• Request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the User or similarly significantly affecting the User.
• Lodge a complaint with a data protection supervisory authority of User’s habitual residence, place of work or of an alleged infringement of the GDPR.

A summary and further details about data subjects’ rights under EU data protection laws, is available on the EU Commission’s website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

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7. The California Consumer Privacy Act (“CCPA”)

The CCPA applies to any California resident User (“Consumer”).

Fyber has been enabling the ad monetization platform (also operated and owned by Fyber) to collect from Consumers that use the Test App, via an SDK, the categories of personal information listed in Section 1 of this Privacy Policy.

Fyber uses the personal information it collects for the business purposes of providing the User with the Test App functionality.

Fyber will not collect additional categories of personal information or use the personal information collected for materially different, unrelated, or incompatible purposes without providing you notice.

Fyber discloses your personal information to third parties and/or service providers for the same business purposes as described in this Privacy Policy.

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Consumer’s Rights

The CCPA provides Consumers with the following specific rights regarding their personal information:

• Access to Specific Information and Data Portability Rights:

The right to request that Fyber disclose certain information to the User about its collection and use of the User’s personal information over the past 12 months. Upon confirmation of your request, we will disclose to you:

• The categories of personal information Fyber collected about the User;
• The categories of sources for the personal information Fyber collected about the User;
• Fyber’s business or commercial purpose for collecting that personal information;
• The categories of third parties and/or service provider with whom Fyber share that personal information;
• The specific pieces of personal information Fyber collected about the User;
• If Fyber disclosed User’s personal information for a business purpose, Fyber will provide the User with a list which will identify the personal information categories that each category of recipient obtained.

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• Deletion Request Rights: Users have the right to request that Fyber will delete any of the User personal information that we collected from you and retained. Upon confirmation of the User’s request, Fyber will delete (and direct its service providers to delete) User’s personal information from Fyber’s records, unless retaining the information is necessary for Fyber or for its service providers to complete the transaction with the User, detect security incidents, identify and repair errors, exercise free speech or another right provided by law, comply with specific laws or legal obligations, or any other internal and lawful uses.

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Exercising Access and Deletion Rights:

To exercise the access, data portability, and deletion rights described above, User needs to submit a request to Fyber by emailing us at CCPA@fyber.com.

Only the User or a person authorized to act on behalf of the User, may make a request related to the User personal information. User may also submit a request on behalf of User’s minor child. Request for access can be made by the User you only twice within a 12-month period.

Fyber will need to ask the User to provide credentials to verify the User identity or authority to make the request and confirm the personal information relates to such User. Fyber will only use the personal information provided in the User request to verify the User identity or authority to make the request.

Fyber will do its best to respond to User’s request within 45 days. If Fyber requires more time (up to additional 45 days), Fyber will inform the User of the reason and extension period in writing. Any disclosures Fyber provides will only cover the 12-month period preceding receipt of such request. The response Fyber provides will also explain the reasons Fyber cannot comply with a request, if applicable.

Fyber does not charge a fee to process or respond to any User’s request unless it is excessive, repetitive, or manifestly unfounded. If Fyber determines that the request warrants a fee, Fyber will inform the User of the reasons for such decision and provide you with a cost estimate before completing your request.

Fyber does periodical assessments of its data processing and privacy practices, to make sure that Fyber complies with this Privacy Policy, to update the policy when needed, and to verify that the policy is displayed properly and accessible.

In any question about the way Fyber processes personal information related to the Test App Users, please contact Fyber at: CCPA@fyber.com, or write to Fyber at Ha-Psagot St 4, Petah Tikva 4951447, Israel.

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8. Data Retention

Fyber retains personal information as needed to provide the Test App to Users in accordance with this Privacy Policy.

As a general practice, Fyber stores personal information related to a User for as long as required in relation to the provision of the Services, but in any case no longer than 13 months.

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9. Transfer of Data Outside User’s Territory

To provide the Test App, Fyber stores and processes personal information in various sites throughout the globe, including in sites operated and maintained by cloud-based service providers.

To the extent necessary under privacy laws and regulations, Fyber will implement data onward transfer instruments.

Fyber implements other or additional onward transfer mechanisms, as available from time to time.

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10. Information Security

Fyber implements systems, applications and procedures to secure personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

Fyber commits to safeguarding the confidentiality of personal information related to the User. Fyber and its hosting services implement systems, applications and procedures to secure personal information related to the User, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

As an example, Fyber limits access to personal information to authorized personnel on a need to know basis in order to operate, develop or improve the Test App.

While all measures provided reflect the current industry standard of security, Fyber cannot guarantee that the Test App will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

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11. Changes to this Privacy Policy

From time to time, Fyber may update this Privacy Policy. If the updates have minor or no consequences, such update will take effect 7 days after Fyber posts a notice on the Test App. Substantial changes will be effective 30 days after Fyber’s notice was initially posted.

Note that if Fyber needs to modify this Privacy Policy to comply with legal requirements, the updated policy will become effective immediately or as required by applicable law.

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12. Contact Fyber

Please contact Fyber at: GDPR@fyber.com for further information.

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Last Updated: November 12, 2020