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Last modified: February 1, 2014

Fiksu, Inc. ("Fiksu") is a marketing service company focusing on the mobile application marketplace. We are committed to maintaining the privacy of your information when you visit our website, and when we provide products that optimize the mobile marketplace inclusive of ads and app download environments, on behalf of our mobile application provider clients ("Clients"). This Privacy Policy describes how we treat the personal information received about you on this website, www.fiksu.com (our "Website"), and when providing marketing services to our application publisher Clients (our "Services").

Safe Harbor Privacy Principles
We comply with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. We have certified that Fiksu adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit http://www.export.gov/safeharbor/.


Fiksu Website
When you use certain features of our Website, we may collect personally identifiable information from you that may include your email address and mobile phone number. We automatically collect non-personally identifiable information such as IP addresses and website usage information from you when you visit our Website. Except as specifically set forth in this Privacy Policy, we will not share your personally identifiable information outside of Fiksu.

We may disclose and use personally identifiable information to resolve disputes, troubleshoot problems, enforce our Terms of Service (for example, when necessary to protect our or a third party's intellectual property or proprietary rights), or to alert you to changes in our policies or agreements that may affect your use of our Website. We may also disclose personally identifiable information when we, in our sole discretion, believe it is necessary or appropriate, in connection with a sale or transfer of some or all of our assets in the Website, or when we, in good faith, believe that the law requires us to do so.

Fiksu Application Marketing Service
Fiksu buys mobile advertising space on behalf of our Clients which are generally mobile application providers and companies looking to advertise via mobile applications. When you click on a Client ad or application link delivered by Fiksu, Fiksu servers receive and store a mobile identifier ("Mobile ID") which is a pseudonymous number that is associated with your mobile device. Fiksu cannot use the Mobile ID to identify you personally, but it does enable us to deliver relevant advertising to each mobile device. In addition to the Mobile ID, we collect information about the kind of mobile device you use (e.g., iPhone, Samsung), the operating system for your mobile device (e.g., Android, Apple O/S), IP address, the applications you download from Fiksu Clients, when, how, and how often you use those applications.

We use your device's Mobile ID and other information about Client applications you download to help our clients understand which ads are most effective at generating downloads of our Client's applications. We also use your Mobile ID and the information associated with your device Mobile ID over time (e.g., the applications you download, when and how you use those applications, and any publisher-provided demographic data) to enhance our services and to select Fiksu Client ads that are most likely to be of interest to you.

Fiksu may use agents and contractors in order to provide our services to Clients. If such agents and contractors have access to your Mobile ID and/or the information associated with your Mobile ID, they are required to protect this information in a manner that is consistent with this Privacy Policy by, for example, not using the information for any purpose other than to carry out the services they are performing for Fiksu.

Information Sharing, Onward Transfer
We disclose the information in our systems, including your Mobile ID and/or the information associated with your Mobile ID over time for the following purposes:

  • To Fiksu Clients when you click on their ad and/or download their application;
  • In response to legal process (for example, a court order, search warrant or subpoena);
  • When we, in our sole discretion, believe it is necessary or appropriate, in connection with a sale or transfer of some or all of our assets, or when we, in good faith, believe that the law requires us to do so.
  • In other circumstances when necessary either to protect the rights or property of Fiksu, Fiksu Clients, and third parties.
  • We may transfer information to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If Fiksu is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personally identifiable information, as well as any choices you may have regarding your information.

Choice Mechanism, Opt-out
We don't collect personally identifiable information unless you provide it to us. You may send requests to understand what personally identifiable information we have on you by emailing info@fiksu.com.

If you'd like to opt-out from Fiksu, please click here. By opting out of Fiksu, you will continue to see advertising, although it will not be tailored to your interests by data provided by Fiksu.

Cookies
Some of the advertisers and Web analytics firms used on our Website may place "tracking cookies" on your computer. These are small text files that can tell such companies what you are doing online, even though they usually don't record your name or other personally identifiable information. These cookies are used by these companies to try and match ads to a user's interests. They are used all over the Web. Fiksu may place cookies on your computer, in addition to any placed by advertisers.

Data Integrity
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

Security
The security of your information is important to us, including but not limited to the personally identifiable information collected via the website. Fiksu has implemented reasonable security measures to protect the information, both during transmission and once it is received. This includes but is not limited to the use of firewalls and encryption. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while the company strives to use commercially acceptable means to protect your information, it cannot guarantee absolute security. If you have any questions about these security practices, please email info@fiksu.com.

Links to Other Content
We frequently make content or services from other websites available to you from links located on our websites. These other websites are not subject to this Privacy Policy, and Fiksu has no control over how such websites may use the personally identifiable information collected on those sites. We recommend that you review the privacy policy at each such website to determine how that site protects your privacy.

Transfer to the U.S. or Other Countries
Your information may be stored and processed in the United States or any other country where Fiksu has facilities.

Changes to This Privacy Policy
When we make a material change to this Privacy Policy, we will inform you by posting a notice on the home page of this site that the policy has been updated and by changing the date on this page noting when the policy was last updated.

Contact Fiksu
If you have any questions or concerns regarding this Privacy Policy, please email us at info@fiksu.com. We will make every effort to resolve your concerns. Alternatively, you may contact us at the address below:

Fiksu, Inc.
Attn: Privacy Officer
31 St. James Ave. Suite 1150,
Boston, MA 02116

Enforcement
We encourage interested persons to raise any concerns using the contact information provided below and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.

Privacy Complaints by European Union and Swiss Citizens
In compliance with the U.S.-EU and U.S.-Swiss Safe Harbor Principles, Fiksu commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Fiksu at info@fiksu.com.

Fiksu has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by the Privacy Officer at Fiksu, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint:

Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor
3033 Wilson Boulevard, Suite 600
Arlington, VA 22201
U.S.A.

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