TMC End User Data & Privacy Policy

Last Updated: April 20, 2018

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, and In-App Marketing. It does not state the use practices or policies of our clients, of the websites or apps on which ads are shown, or of other parties.

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”.

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

For the HasOffers privacy policy, CLICK HERE.

For information on TUNE’s approach to and preparation for GDPR, please 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 compares the Unique Advertising Identifier at install with the click or conversion to determine appropriate attribution. Statistical Identifiers may be used if a Unique Advertising Identifier is not available.

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. End User Data collected by Advertisers must comply with all applicable laws, including notice and consent data privacy obligations.

Geographic Location Data is geographic data that determines an End User’s non-precise geographic location using an IP address 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 HTTPS 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 may 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 functions of TMC.

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?
Pursuant to the TUNE Data Pledge, Advertisers determine the data that they provide to and collect through the TMC. Advertisers’ collection, exportation, or any other use of End User data, including the use of TUNE products and services, 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 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.

Specific fields that likely contain personal data, such as email or IP address, may be hashed upon receipt. Additional information on how we categorize and treat data is available here.

FOR WHAT PURPOSES CAN ADVERTISERS USE AND SHARE DATA COLLECTED THROUGH THE TMC?
Advertisers, as data controllers, 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.
    • Audiences: Creating segments of End Users based on behavior and other characteristics to understand total End User value based on the user’s interaction with a marketing campaign.
    • 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
  • In-App Marketing
    • Engaging End Users through push notifications and in-app messages, and Audiences (see above).
    • A/B testing of push notifications, messaging, features, and navigation flow to optimize the End User experience.

    Advertisers (as data controllers) may share the data collected through the TMC with its Partners via Postback, data exports, and/or API calls. At the direction of TUNE’s data controllers, TUNE may process personal data for those certain legitimate business purposes listed above. TUNE respects rights of end users who object to this processing.

    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 only uses this information to service Advertisers’ accounts, bill Advertisers accordingly, provide account support, 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 disclose End User Data in the event we reasonably suspect fraudulent, malicious, invalid traffic, or other unlawful activity, or believe that we are legally required to do so. TUNE may also share anonymous 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 VALID END USER REQUESTS?

Further details are available at optoutmobile.com. 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. End users should also note that TUNE collects information on behalf of its Advertiser clients. To opt out, please see optoutmobile.com or contact the Advertiser directly. We will actively work with our Advertisers to fulfill such requests as reasonable and required by law.

HOW DOES TUNE ADHERE TO GDPR PRINCIPLES?
TUNE serves as a data processor under the GDPR, and adheres to the principles and rules of the GDPR. Specifically, TUNE: implements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, allows for appropriate third party audits, ensures data is only transferred internationally with a lawful basis, only contracts with subprocessors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners.

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 we have 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.

Contact Information
If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us at [email protected] or by mail at:

TUNE, Inc.
2200 Western Ave., Suite 200
Seattle WA, 98121

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