Last Updated: January 28, 2016
TapCommerce LLC is a wholly owned subsidiary of Twitter, Inc. that provides advertising technology services ("TapCommerce Services" or "Services"). Our Services allow advertisers to run advertising campaigns in mobile applications ("apps") to reach audiences that may be interested in their products or services. This Privacy Policy explains how TapCommerce collects and uses information about users of its website and the TapCommerce Services, their agents, and their service providers (collectively, "TapCommerce Customers"); as well as end users of apps and websites of advertisers that use the Services and on which TapCommerce runs advertising campaigns (collectively, "End Users").
If you have additional questions or would like further information, please email us at tapcommerceprivacy@twitter.com.
What Data Does TapCommerce Collect?
From TapCommerce Customers:
If you are a TapCommerce Customer who wishes to advertise through the Services, we may ask you for certain personal information, including your name, email address, physical address, phone number, or company name. We may also ask you to create login credentials, and for campaign-related content such as campaign goals, names, budgets, and creatives.
When you visit our website, our servers may automatically record certain information in our log files, such as IP address, browser type, operating system, the referring web page, pages visited, and cookie information. Cookies are small files that websites place on your computer as you browse the web. A pixel is a small amount of code on a web page and is often used in connection with cookies. Most web browsers automatically accept cookies. You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. However, some sites may not function properly if you disable cookies.
From End Users:
If you are an End User who visits or interacts with an app that contains TapCommerce advertising, we may collect information about your device and the ads you view or click. When you download, visit, or interact with the website or app of a TapCommerce Customer, we may collect information in connection with that activity.
Our Services are designed to avoid collecting information that identifies you personally, such as your name, address, or email address, but the information we collect does enable us to recognize your device over time. The information we collect includes, but is not limited to:
- Information about your device, such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, IP address, mobile browser (e.g. Chrome, Safari), and unique device identifiers such as iOS Identifier for Advertising (IDFA) or Android Advertising ID, or unique device identifier (a number uniquely allocated to your device by your device manufacturer).
- Log information, including the app or website visited, session start/stop time, time zone, and network connection type (e.g., WiFi, cellular), and cookie information.
- The geo-location of your device (using GPS or other signals), when location services have been enabled for the mobile app or website.
- Information about TapCommerce ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether you clicked on it, the cost of the ad, and whether you visited the advertiser's website or purchased the product or service advertised.
- Information TapCommerce Customers have collected and share with TapCommerce about your activity in their sites and apps, including the content you view or searches you made, the language you prefer, your actions in the site or app (such as registrations or purchases), or non-personally identifying demographic information, to help make the ads served to you more relevant.
We may receive this information directly from End Users or TapCommerce Customers, through their service providers, or from other third parties such as the companies through which we bid on and purchase advertising inventory
How Does TapCommerce Use The Data?
We use the information we collect to provide and improve TapCommerce Services, including for the following purposes:
- Running Ad Campaigns: Designing and implementing advertising campaigns of TapCommerce Customers, such as by determining the best parameters and creatives for those campaigns, and by bidding on and purchasing advertising inventory in mobile apps.
- Ad Reporting and Conversions: Reporting to advertisers the number of users who were exposed to their ads as well as number of users who clicked on their ads or visited or used their website or app.
- Frequency Capping: Preventing users from seeing the same ad too many times.
- Fraud Detection and Prevention: Identifying invalid clicks (or ad queries) and protecting TapCommerce and TapCommerce Customers from fraudulent behavior.
- Interest-Based Advertising: Allowing TapCommerce and TapCommerce Customers to infer interests and purchase ads to display to users based on their app and website activity and inferred interests.
- Geo-Targeting: Where permitted by the user's device, allowing TapCommerce and TapCommerce Customers to serve ads based on a user's location.
- Providing and Improving Our Services: Auditing, researching, and analyzing data in order to maintain, protect, operate, and improve our Services and develop new services, and to resolve technical problems and ensure that our technologies function properly.
- Billing and Promotional Information: We may use the information we collect from TapCommerce Customers to facilitate payment for our services, and to send promotional information about the Services. To opt out of any email newsletter, please follow the unsubscribe instructions in that email.
TapCommerce will not combine the information collected from End Users with personally-identifying information without express consent.
How Does TapCommerce Share or Disclose Data?
We share the information we collect to provide and improve TapCommerce Services, as follows:
- We share with TapCommerce Customers information that we use and receive when purchasing ads on their behalf through the Services, interactions with those ads, and how their campaigns performed.
- We share information with third parties such as advertising exchanges in order to bid on and purchase advertising inventory in mobile apps on behalf of TapCommerce Customers.
- We share information with third parties at an aggregated level for sales, marketing or other business purposes.
- We share information that does not identify you personally with our corporate affiliates, such as our parent company Twitter, subject to confidentiality obligations consistent with this Privacy Policy. Our affiliates may use this information, for example, to help provide, analyze, and improve our services and their own services.
- We engage service providers to perform functions and provide services to us in the United States and abroad. We may share the information we collect with such service providers subject to confidentiality obligations consistent with this Privacy Policy, and on the condition that the third parties use your information only on our behalf and pursuant to our instructions.
- Notwithstanding anything to the contrary in this Privacy Policy, we may disclose information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect TapCommerce's rights or property.
- We share information when we have your consent to do so.
What Else Should I Know about TapCommerce?
Choice
Your iOS mobile device may provide a "Limit Ad Tracking" setting. On Android devices, your settings may allow you to "Opt out of Interest-Based Ads." When you have opted out using either of methods on a device, TapCommerce will not use information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests. Your mobile web browser may also provide a "Do Not Track" browser setting. When you have enabled this setting in your browser, TapCommerce will not use mobile web browsing information from that browser to infer your interests or serve ads to that device that are targeting based on your inferred interests. TapCommerce requires its advertising customers to honor opt-out preferences expressed using these controls.
Identification
All interest-based ads will be identified with a TapCommerce privacy opt-out icon, which will take you to a landing page with more information on how to opt-out from these types of interest based ads.
To learn more about how to opt-out from these type of interest based ads, please check http://tapcommerce.com/opt-out.html
Children
TapCommerce does not knowingly allow the Services to be used to create interest-based profiles of, or serve ads to, users under 13 years of age.
Information Collected by Others
Please be advised that we do not control and are not responsible for the privacy practices of any third party, including, but not limited to, TapCommerce Customers and any website or service that links to or from our website or the TapCommerce Services. We require TapCommerce Customers to maintain a privacy policy that fully and accurately discloses their data collection practices, but we cannot control the actions of TapCommerce Customers, so please be sure to review the privacy policies of any websites and applications that you may use. Also, this site may contain links to other sites. TapCommerce is not responsible for the privacy practices or content of these other sites. When you leave our site or view a portion of a third party's site through our site, we encourage you to read the privacy policies of each such site. This Privacy Policy applies solely to information collected by TapCommerce.
Confidentiality and Security
TapCommerce has implemented reasonable security measures in order to protect both personal and non-personal information from loss, misuse and unauthorized access, disclosure, alteration or destruction.
Privacy Practices of TapCommerce Customers
TapCommerce requires TapCommerce Customers to comply with all applicable laws and regulations, including those that require providing End Users with sufficient notice of the collection and use of data. We encourage all users to review the privacy policies of sites and apps they visit for information about those sites' and apps' data collection and use practices.
Please be advised that we do not control and are not responsible for the privacy practices of any third party, including but not limited to TapCommerce Customers, the apps or companies through which TapCommerce purchases advertising inventory, and any website or service that links to or from our website or the TapCommerce Services. We require TapCommerce Customers to maintain a privacy policy to disclose their data collection practices, but we cannot control the actions of TapCommerce Customers, so please be sure to review the privacy policies of any websites and applications that you may use.
This site may contain links to other sites. TapCommerce is not responsible for the privacy practices or content of these other sites. When you leave our site or view a portion of a third party's site through our site, we encourage you to read the privacy policies of each such site. This Privacy Policy applies solely to information collected by TapCommerce.
Changes to This Privacy Policy
We may amend this privacy policy from time to time. If we make a change to this policy that, in our sole discretion, is material, we will notify you by posting notice of these changes on our website home page and in this Privacy Policy.
Changes in Corporate Structure
In the event that TapCommerce is involved in a bankruptcy, merger, acquisition, reorganization, sale of assets or other similar business transaction, your information may be sold or transferred as part of that transaction. The promises in this Privacy Policy will apply to your information as transferred to the new entity.
Consent to Data Processing
When using any of the TapCommerce Services you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Irrespective of which country you live in, you authorize us to use your information in, and as a result to transfer it to and store it in, the United States and any other country where we, our service providers, and our TapCommerce Customers operate. Privacy and data protection laws in some of these countries may vary from the laws in the country where you live.