TMC End User Data & Privacy Policy

Last Updated: September 14, 2016

TUNE, Inc. provides solutions for mobile and performance marketers.

This Privacy Policy is provided to help you understand how TUNE processes End User data on behalf of Advertisers who use the TUNE Marketing Console, or “TMC”, for Attribution Analytics, App Store Analytics, Audiences, and In-App Marketing.

TUNE and our clients care about how End User data is collected, used, and shared. We are a “data processor” that collects and analyzes End User data at the specific request of our client Advertisers, the “data controllers”.
We abide by the following Data Pledge to all our clients:

“With TUNE products, your data always belongs to you. We do not leverage your data for unauthorized purposes, take a cut of your ad spend or revenue, or share your data without your permission.”

For information regarding our corporate website privacy practices, please CLICK HERE.
For the HasOffers privacy policy, CLICK HERE.

DEFINITIONS

Advertiser is any person or company that promotes their product or a component of their product using the TMC.

App Store is a digital distribution platform where End Users of smartphones and other mobile devices can browse, purchase, and download applications or apps.

App Store Data is data available from an App Store, including but not limited to rankings, keywords, and geographic location data (country).

App Store Analytics formerly known as “MDHQ” or “MobileDevHQ” is a back-end technology that is part of the TMC and that allows Advertisers to use App Store Data or Client Data to optimize rankings for their mobile applications or apps.

Attribution is a general term used to describe how user interactions within apps and around the advertising ecosystem are measured. Clicking on an advertisement, downloading an app, or making an in-app purchase are examples of events that can be attributed. Within the TMC, attribution happens as follows: once an End User clicks on an advertisement, and subsequently installs and opens an app, the TMC redirects links to collect the Unique Advertising Identifier, to perform attribution. Statistical Identifiers may be used if a Unique Advertising Identifier is not available. Additional information on the main methodologies for attribution in the TMC is available here.

Attribution Analytics formerly known as “MAT” or “MobileAppTracking,” is a back-end technology that is part of the TMC and that provides unique attribution matching using advertising identifiers and/or statistical identifiers to measure the performance of a mobile advertising campaign.

Audiences is a back-end technology that is part of the TMC and is used to provide Advertisers the ability to segment groups of End Users for advertising. Advertisers can export these segments to Partners for re-engagement purposes.

Daily Active User is a user that engages with an app at least once in any given day.

End User is an End User of the Advertiser’s products and services.

End User Data is data about an End User, or derived from an End User’s mobile device, for use by Advertisers in the TMC. In all cases, Advertisers must pseudonymize or otherwise secure data that is considered personal under the laws of the relevant jurisdiction. See the TUNE MSA for more details.

Geographic Location Data is geographic data that determines an End User’s non-precise geographic location using an IP address, GPS coordinates and/or Wi-Fi signals obtained from the End User’s device and gives Advertisers deeper insight into the performance of their advertising campaigns.

Keyword Data is publicly available data that the TMC optimizes to determine the volume and popularity of keyword searches at any given time.

In-App Marketing is a back-end technology that is part of the TMC and is used to provide Advertisers with the ability to send push notifications, in-app messaging, and A/B testing, to personalize the End User experience. In-App Marketing collects End User Data to enable these features.

Partners are third parties that Advertisers work with to promote applications, networks, offers, and/or advertisements. Partners may include the following types of entities: ad networks, publishers, Advertisers, affiliates, analytics providers, and data providers.

Postbacks are server-to-server communications that Advertisers configure to share data with Partners.

Statistical Identifiers are used to provide Attribution when Unique Advertising Identifiers are unavailable through the creation of a “device fingerprint.” This involves the collection of publicly-available HTTP headers collected from the End User’s device to probabilistically determine whether the device is responsible for the Attribution. On click, and then again on install, the TUNE SDK will pull the following data points from the End User’s device: country code, device brand, device model, device carrier, IP address, language preference, operating system name, operating system version, and timestamp. Since these data points degrade over time, statistical identifiers are only used for attribution within a 24-hour window. This window cannot be changed. Additional information on how the TMC handles attribution using Statistical Identifiers to create a “device fingerprint” is available here.

TMC is the TUNE Marketing Console, which includes the following solutions: Attribution Analytics, App Store Analytics, Audiences, and In-App Marketing.

TUNE SDK is computer code inserted into an Advertiser’s mobile app to enable the following functions: attribution, marketing intelligence, End User messaging (in-app and push notifications), A/B testing and user segmentation.

Unique Advertising Identifiers are user-specific, unique character strings for advertising that can be reset by the user and are provided by mobile platforms to track an End User’s device for advertising purposes. Examples of Unique Advertising Identifiers include IDFA (developed by Apple for the iPhone), Google Ad ID (developed by Google for Android), and Windows advertising ID (developed by Microsoft for the Windows Phone). Additional information on the main methodologies for attribution in the TMC is available here.

WHO OWNS THE DATA THAT IS COLLECTED AND PROCESSED BY THE TMC?
Unless otherwise specified, and pursuant to the TUNE Data Pledge, Advertisers own the data that they provide to and collect through the TMC. When Advertisers remove or export their data from the TMC, their use of End User data is governed by their own privacy policies and applicable laws, rules, or regulations.

WHAT DATA DO ADVERTISERS COLLECT FROM END USERS WITH THE TMC?
The TMC is designed to collect and use data such as Unique Advertising Identifiers, Statistical Identifiers, Geographic Location Data, Email Addresses, and other data provided by the Advertiser for attribution, app store optimization, and in-app marketing. Advertisers are able to view and measure data provided by TUNE, as well as third-party Partners that the Advertiser selects, in the TMC. For instance, an Advertiser can compare the results of advertising campaigns conducted with different Partners in the TMC. Advertisers and Partners may also send information to the TMC via Postback.

The TMC does not primarily rely on data that is considered “personal” in other jurisdictions for Attribution and App Store Optimization. The TMC does support automatic hashing in cases where the Advertiser chooses to upload “personal” data into the TMC to ensure that the TMC does not process such data in raw form. Additional information on how we categorize data into anonymous, personal and pseudonymous, as well as the “Importance of Securing Data in the TMC,” is available here.

FOR WHAT PURPOSES CAN ADVERTISERS USE & SHARE DATA COLLECTED THROUGH THE TMC?
Advertisers can share all data collected through the TMC with Partners via Postback, data exports, and/or API calls.
Advertisers may use information collected by the TMC for the following purposes.

  • Attribution
    • Measuring the performance of the Advertiser’s ad campaigns through customized reporting and business intelligence.
    • Measuring the performance of the Advertiser’s campaign with a specific Partner(s).
    • Determining when End Users respond to ads.
    • Cross-device attribution. For more details on how the TMC measures cross device attribution, click here.
  • App Store Analytics
    • Measuring the performance of keyword campaigns e.g. comparing how different keywords affect app store rankings.
    • Measuring rankings for various search terms.
    • Competitive analysis
    • A/B Testing
  • Audiences
    • Creating segments of End Users based on behavioral and demographic profiling to understand total End User value based on the user’s interaction with an app.
    • Creating segments of End Users based on behavioral and demographic profiling to share with Partners for re-engagement.
    • Advertisers are responsible for notice and consent from End Users for these types of communications under the TUNE Master Services Agreement.
    • To learn how to opt out of an Audiences segment, visit TUNE’s opt out site at: www.optoutmobile.com.
  • In-App Marketing
    • Engaging End Users through push notifications and in-app messages.
    • A/B testing of push notifications, messaging, features, and navigation flow to optimize the End User experience.
    • Advertisers are responsible for notice and consent from End Users for these types of communications under the TUNE Master Services Agreement.
    • The TMC honors opt-outs from push notifications. To learn more, visit TUNE’s opt out site at: www.optoutmobile.com

WHAT DATA DOES TUNE COLLECT FROM ADVERTISERS?
Advertisers must submit their full name, mailing and/or billing address, email address, company name, and website URL to TUNE. TUNE uses this information to service Advertisers’ accounts and respond to inquiries. We hold all such information in strict confidence.

IN WHICH INSTANCES DOES TUNE SHARE END USER DATA WITH THIRD PARTIES?
TUNE may provide, or enable others to collect, End User Data for purposes of detecting and preventing malicious activity or invalid traffic. TUNE may disclose End User Data in the event we reasonably suspect malicious activity or invalid traffic, or believe that we are legally required to do so. TUNE may also share aggregated End User Data derived from the TMC Platform, including, for example, statistics about Platform activity. Finally, TUNE may transfer End User Data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.

DOES THE TMC RESPECT END USER OPT-OUT CONTROLS LIKE LIMIT AD TRACKING?
Yes, the TMC respects End User opt outs in three different ways:

  • For Audiences, we respect the Limit Ad Tracking flag. For attribution, TUNE is able to pass the limit ad tracking flag to the Advertiser for End Users who have enabled Limit Ad Tracking on their device. We will also ensure that End Users who have enabled this flag aren’t targeted for advertising.
  • For Audiences, we also honor opt-outs provided to us by the Advertiser (through the TUNE SDK or Measurement API).
  • For In-App Marketing, we honor push notification opt outs configured by the End User on their device, per mobile platform rules.

Further details are available at www.optoutmobile.com.

End Users should note that opting out of the TMC will not stop those users from receiving interest-based advertisements from Advertisers or other publishers or ad networks. End Users who want to opt out of a particular ad network, publisher, or Advertiser’s ads must contact those companies directly to opt out.

DOES THE TMC COMPLY WITH AD TARGETING STANDARDS SUCH AS THE DAA OBA GUIDELINES?
Yes. The TMC provides data to companies that engage in online behavioral advertising or “OBA” and therefore, falls under the DAA’s self regulatory requirements. We provide notice of how we support our client’s OBA activities in this TMC privacy policy, and also provide enhanced notice and instructions on how to opt out of the TMC’s ad targeting features at www.optoutmobile.com.

EU TO US TRANSFERS
TUNE has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. See TUNE’s Privacy Shield Statement here. To learn more about Privacy Shield, please visit www.privacyshield.gov.

SECURITY
TUNE uses commercially reasonable efforts including a variety of security technologies and procedures to secure client and End User Data from unauthorized access, use or disclosure.

WHAT HAPPENS IF THIS PRIVACY STATEMENT IS CHANGED?
TUNE may find it necessary to update this Privacy Policy from time to time. Please check this Privacy Policy, as any changes will be posted on this site.

QUESTIONS ABOUT THIS PRIVACY POLICY?
If you have an unresolved privacy or data use concern that a TUNE client or TUNE has not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

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