Last modified: October 7, 2014
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/.
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.
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 email@example.com.
The World Wide Web Consortium (W3C) is attempting to develop a Do Not Track (DNT) standard. Currently, the standards regarding the DNT signals and appropriate responses are not defined. Accordingly, we do not assign a meaning to DNT signals. 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.
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.
We have implemented a third-party analytics features that will collect data on our Website. You can opt-out of these analytics features by clicking here.
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.
Fiksu adheres to the Children’s Online Privacy Protection Act. We do not create nor use any behavioral advertising segments of children under 13 as part of our Services. Our Site is not directed at children under the age of 13. If we are made aware that we have received personally identifiable information from someone under 13, we will use reasonable efforts to remove that information from our records.
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 firstname.lastname@example.org.
Links to Other Content
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.
Attn: Privacy Officer
31 St. James Ave. Suite 1150,
Boston, MA 02116
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
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