Effective Date: May 14th, 2020
MoPub, a division of Twitter, Inc., provides advertising technology services that allow publishers of mobile applications (“apps”) to show ads in their apps, and for advertisers to reach audiences that may be interested in their products or services. MoPub’s suite of advertising technology includes the MoPub Software Development Kit (“MoPub SDK”) and application programming interfaces (“APIs”), the MoPub advertising exchanges, and the MoPub websites (collectively, the “MoPub Services”).
We work with a variety of partners (collectively, “MoPub Partners”) in order to provide the MoPub Services:
- Advertising Demand Partners: Advertisers, demand side platforms, advertising networks, or other advertising demand sources that bid on ad inventory through the MoPub advertising exchange and serve ads. Advertising networks that are Advertising Demand Partners may also be Supported Advertising Mediation Partners, as described below.
- Data Partners: Companies that create audience segments, including demographic and interest segments, based on device identifiers, location data, and other personal data in order to help Advertising Demand Partners reach the right audience.
- Fraud and Measurement Partners: Companies that help with anti-fraud, quality, and security efforts to ensure the safety, security, privacy, and accuracy of the MoPub Services, including detecting whether clicks on ads are fraudulent and whether ads are viewable within an app.
- Publisher Partners: Companies that develop apps that integrate the MoPub SDK and APIs in order to show advertising in their apps.
- Supported Advertising Mediation Partners: Companies that Publisher Partners work with directly in order to serve ads in their apps. The MoPub Services support the technical integration of these Supported Advertising Mediation Partners’ services in our Publisher Partners’ apps through MoPub's mediation and real-time bidding products, such as advanced bidding. Supported Advertising Mediation Partners may constitute Advertising Demand Partners when advanced bidding.
Unless otherwise noted in our partner list, MoPub Partners are each independent controllers of your data. You can view a list of MoPub Partners with whom we share your data here, current as of the date listed at the top of that page. We allow Publisher Partners to use MoPub to mediate unsupported networks in a manner similar to what is described above with respect to Supported Advertising Mediation Partners.
- Section 1 describes how we process personal data about you when you use an app that has integrated the MoPub SDK and APIs, and how you can exercise control over our processing of your personal data.
- Section 2 describes how we process personal data about you if you visit MoPub.com.
- Section 3 describes how we process personal data about you if you are a Publisher Partner or Advertising Demand Partner that uses the MoPub Services.
Section 1: Personal Data We Process
1.1 Personal Data We Collect About You Through Apps
When you use an app that has integrated the MoPub SDK and APIs, we may collect personal data about you. The MoPub Services do not intentionally collect information like your name, address, or email address, but the personal data we may collect may enable us to recognize your device over time and across apps. Depending on where you live and your privacy choices, the personal data we may collect includes:
- Device identifiers, including your IP address, iOS Identifier for Advertising (IDFA), Android Advertising ID, and a MoPub-specific identifier.
- Your precise geo-location, when location services have been enabled for an app on your device that has integrated the MoPub SDK and APIs. Note that when location services have not been enabled in any of your apps that have integrated the MoPub SDK and APIs, we will still infer data about your location based on other information, including your IP address.
- Information that a Publisher Partner has collected about you and/or shared with MoPub, including demographic information (e.g., your age or gender) or information about your interests, to help make the ads served to you more relevant.
- Information about your device, including the type and model, manufacturer, operating system (e.g., iOS or Android), carrier name, mobile browser (e.g., Chrome, Safari), and screen size.
- Information about your app usage, including the apps on your device that use the MoPub SDK and APIs and the version of such apps, the app on your device that is requesting an ad, the start/stop time of your app session, your current time zone, and your network connection type (e.g., WiFi, cellular).
- Information about ads served, viewed, or clicked on, including the type of ad, where the ad was served, whether you clicked on it, and whether you visited the advertiser’s website or downloaded the advertiser’s app.
1.2 How We Use the Personal Data We Collect About You Through Apps
We use the personal data we collect about you through apps that have integrated the MoPub SDK and APIs for the following purposes:
- Serving Ads: Allowing Publisher Partners to offer advertising inventory in their apps, and Advertising Demand Partners to bid on and fill that inventory with ads.
- Personalized Advertising: Allowing Data Partners and Advertising Demand Partners to infer what you may be interested in/what ads you are most likely to engage with and to serve ads to you based on these inferred interests/likelihood of engagement. Depending on your location, MoPub may also directly create a profile about you in order to help our Advertising Demand Partners serve the best ads to you. MoPub’s policies prohibit MoPub Partners from sending, or targeting advertisements based on, information that we consider sensitive or are prohibited by law, including race, religion, politics, sex life, or health.
- Geo-Targeting: Allowing Advertising Demand Partners to serve ads based on your current or prior location, including through location-based targeting segments created by Data Partners.
- Ad Reporting and Conversions: Reporting to Advertising Demand Partners information about when and how you have been exposed to their ads or clicked on their ads, and reporting to Publisher Partners information about when and how ads were shown on their properties and were clicked on.
- Frequency Capping: Preventing you from seeing the same ad or type of ad too many times.
- Fraud Detection and Prevention: Identifying invalid clicks (or ad queries) and protecting MoPub and Advertising Demand Partners from fraudulent behavior.
- Providing and Operating Our Services: Auditing, researching, and analyzing data in order to maintain, protect, and improve MoPub Services, and to ensure that our technologies function properly.
1.3 How We Share the Personal Data We Collect About You Through Apps
We share personal data that we collect about you through apps that have integrated the MoPub SDK and APIs for the following purposes:
- We share personal data with Advertising Demand Partners for use in furtherance of their business purposes, including use of personal data to decide whether to bid on ad inventory or serve an advertisement and choose the best ad for you on our mobile advertising exchange and across the broader advertising ecosystem. For example, Advertising Demand Partners may use personal data we share with them to create audience segments, including demographic and interest segments, improve their bidding algorithms and machine learning for use on and off of MoPub, and measure the effectiveness of advertising. Advertising Demand Partners are obligated to use the information they receive in compliance with applicable laws and regulations.
- We share personal data with Data Partners so that they can create audience segments, including demographic and interest segments, to help Advertising Demand Partners choose the best ad for you on our mobile advertising exchange and across the broader advertising ecosystem.
- We share personal data with Fraud and Measurement Partners in order to help with anti-fraud, quality, and security efforts to ensure the safety, security, privacy, and accuracy of the MoPub Services and the broader advertising ecosystem.
- We share aggregate information with Advertising Demand Partners and Publisher Partners to help them measure the effectiveness and value of MoPub Services. For example, we provide Advertising Demand Partners with reports showing how many users viewed or clicked on their ads. We also provide Publisher Partners with reports about the types of ads served to their apps.
- We share personal data with MoPub Partners so that they can build and improve their products and services for use on MoPub and across the broader advertising ecosystem.
1.4 Controlling the Processing of Your Personal Data for Personalized Advertising
We give you control over how we process personal data from you for personalized advertising. If you are a California consumer, for more information about your privacy rights, please see the MoPub California Consumer Privacy Statement.
1.4.1 The European Union, EFTA, and United Kingdom
Consent: If you are located in the EU, an EFTA state, or the United Kingdom, Publisher Partners who would like us to serve you personalized ads must first obtain your consent so that MoPub and MoPub Partners can process your personal data for this purpose. Some Publisher Partners may choose to obtain your consent for this purpose even if you are located outside of these regions. If you provide your consent, we will collect, use, share, and otherwise process all of the personal data described above for the purpose of serving you personalized advertising that MoPub and MoPub Partners believe is most relevant to you.
Withdrawal of Consent: You can withdraw your consent to MoPub’s personalized advertising experience at any time.
Publisher Partners may provide a way for you to withdraw your consent directly from within an app. If you withdraw your consent from within an app, we will no longer collect, use, share, or otherwise process personal data from that app to personalize your advertising experience.
In addition, you can use your device settings to let us know that you wish to withdraw your consent to MoPub’s personalized advertising experience across all of your apps on that device.
- On iOS, you may withdraw your consent by enabling the “Limit Ad Tracking” setting in your iOS settings (precise directions may be different on different iOS versions).
- On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by toggling the “Opt out of Ads Personalization” switch on (precise directions may be different on different Android versions and OEM Android variants).
The next time you use an app that has integrated the MoPub SDK and APIs on that device, we will honor your choice, and will no longer collect, use, share, or otherwise process personal data from that device to personalize your advertising experience. Further, if you use your device settings to withdraw your consent to MoPub's personalized advertising experience, the next time you use an app that has integrated the MoPub SDK and APIs on that device, we will communicate a signal indicating your choice to relevant MoPub Partners so that they, as independent controllers of your personal data, can also respect your choice.
Even if you do not consent to a personalized advertising experience, or you later withdraw such consent, we may still process your personal data when necessary to comply with our legal obligations or to support our legitimate interests, as described below.
Legal Necessity: We may process personal data as necessary to comply with our legal obligations. For example, when we collect your IP address in order to perform a lookup of your country, so that we know whether you are located in the EU, an EFTA state, or the United Kingdom, we will truncate the last octet of your IP address before we process it for this purpose, and we will not share your full IP address or retain it internally. Similarly, if you consent to our personalized advertising experience, but later withdraw such consent, we will continue to retain a record of the iOS Identifier for Advertising or Android Advertising ID of your device for the purpose of recording when you consented and withdrew consent from our processing of your personal data. As part of your withdrawal of consent request, we may also make available the iOS Identifier for Advertising or Android Advertising ID of your device to our current MoPub Partners so that they, as independent controllers of your personal data, can also respect your choice to withdraw consent.
Legitimate Interests: We may process personal data as necessary to support our legitimate interests. For example, even if you do not consent to a personalized advertising experience, we may still:
- Generate, collect, and use a short-lived MoPub-specific identifier for the purpose of frequency capping -- to prevent you from seeing the same contextual ad too many times. In order to protect your privacy, we will reset this identifier every 24 hours, and we will not share it with MoPub Partners or any other third parties.
- Enable our service providers to receive your IP address for purposes of detecting invalid clicks and other fraudulent activity. In order to protect your privacy, we contractually prohibit our fraudulent activity detection service providers from using this data for any purpose other than fraud detection on and off of MoPub.
1.4.2 United States and Other Countries
Opt Out: If you are located in the United States or another country outside the EU, an EFTA state, and the United Kingdom, you can opt out of receiving personalized advertising by using your applicable device settings:
- On iOS, you may opt out by enabling the “Limit Ad Tracking” setting in your iOS settings (precise directions may be different on different iOS versions).
- On Android devices, you may opt out in the Google Ads settings within your Android settings by toggling the “Opt out of Ads Personalization” switch on (precise directions may be different on different Android versions and OEM Android variants).
If you opt out through your device settings, MoPub will send your opt-out preference with each request for an advertisement sent to our Advertising Demand Partners. MoPub requires that our Advertising Demand Partners honor opt-out preferences expressed using these controls by only serving contextual advertisements in response to such ad requests, and prohibits the use of any data contained in such ad requests to serve personalized advertising or to create a personalized advertising profile of the user or device.
1.5 Access to Personal Data We Collect About You Through Apps
Due to the nature of the personal data MoPub collects, we do not have sufficient information available to provide secure, authenticated access to the personal data that we store about you or to confirm that specific personal data relates to you. However, as noted above, you can exercise control over how we process your personal data for personalized advertising as explained above. You can also contact us using the details below.
Unless we have another legal basis for storing your personal data, if you are located in the EU, an EFTA state, or the United Kingdom, we will delete or de-identify the personal data we have stored about if you withdraw your consent.
1.7 Privacy Practices of MoPub Partners
MoPub requires MoPub Partners to comply with all applicable laws and regulations. In addition, MoPub requires Publisher Partners and Advertising Demand Partners, who are each independent controllers of your personal data, to comply with the MoPub Policies for Publisher Partners and MoPub Policies for Advertising Demand Partners, respectively, and to provide you with sufficient notice of their processing of your personal data.
When you consent to MoPub’s processing of your personal data, you are also consenting to MoPub’s sharing of your personal data with MoPub Partners in order to show you advertising that we believe is more relevant to you. If you use your device settings to no longer receive MoPub’s personalized advertising experience, the next time you use an app that has integrated the MoPub SDK and APIs on that device, we will communicate a signal indicating your choice to relevant MoPub Partners so that they, as independent controllers of your personal data, can also respect your choice. MoPub Partners may also have separate legal bases for collecting, using, retaining, and sharing your personal data. For example, some Publisher Partners and Supported Advertising Mediation Partners may mutually agree to process your personal data for personalized advertising purposes on the basis of legitimate interests. While MoPub is not involved in the processing of your personal data in these cases, our policies require MoPub Partners to provide visible notice when they choose to process your personal data in this manner.
We encourage you to read MoPub Partners’ policies to understand their privacy practices, the legal bases for their processing of your personal data, and any additional options that they provide for exercising control over such processing.
MoPub does not permit the MoPub Services to be used to collect information from apps directed to children under the age of 13 for purposes of personalized advertising. MoPub may collect information from apps directed to children for other purposes, including serving advertisements based on contextual information, like the content or type of app you are using (for example, serving an ad for a video game to a gaming app).
In addition, you must be old enough to consent to MoPub’s personalized advertising experience in your country (in some countries we may allow your parent or guardian to do so on your behalf). MoPub does not collect or otherwise process personal data from individuals whom it knows to be under the legal age of consent in their country, except to comply with law or to support our legitimate interests as described above.
Section 2: Personal Data We Process If You Visit MoPub.com
2.1 Personal Data We Collect When You Visit MoPub.com
When you visit MoPub.com, our servers automatically record certain personal data in our log files. This web log data includes information like your IP address, browser type, operating system, the referring web page, pages visited, and cookie information. Like many websites, we use web log information, along with cookies, pixels, and similar technologies, to operate our websites, better understand how they are used, resolve technical problems, and enhance your experience on our sites.
2.2 Personal Data We Share When You Visit MoPub.com
Section 3: Personal Data We Process If You Are a Publisher or Advertising Demand Partner
3.1 Personal Data We Collect From Publisher and Advertising Demand Partners
To become a Publisher Partner, Supported Advertising Mediation Partner, or Advertising Demand Partner, you will be asked to provide certain personal data, including your name, email address, physical address, phone number, and company name. You may be asked to provide additional personal data, including a username and password, to register for a MoPub account. This information is used to provide the MoPub Services and to send information about the MoPub Services. To opt out of receiving promotional information, please follow the unsubscribe instructions in any of our promotional emails.
If you are a Publisher Partner, you also will be asked to provide personal data through our third-party payments processor so that we can fulfill payment to you.
We will also collect web log information when you use our publisher and advertising demand portals on MoPub.com, as explained in Section 2.
3.2 Accessing or Rectifying Your Personal Data as a Publisher Partner or Advertising Demand Partner
We provide you with account tools to access, correct, or modify personal data you have provided to us in association with your Publisher Partner or Advertising Demand Partner account. You may request to delete your account by logging into the publisher or advertising demand portal on MoPub.com and following the instructions to request account deletion. Unless we have another legal basis to store your personal data, including compliance with tax or accounting laws, we will delete or de-identify the personal data we have stored about you after we receive your request to delete your account. If you are a California consumer, for more information about your privacy rights, please see the MoPub California Consumer Privacy Statement.
3.3 Personal Data We Share and Disclose About Our Publisher Partners and Advertising Demand Partners
We may disclose personal data about you when necessary to provide the MoPub Services, including for account inquiries or verification, or to enable participation in certain features of our mobile advertising exchange. We may also share information within our corporate family to provide, understand, or improve their or our services.
3.4 Other Important Information
3.4.1 Law, Harm, and the Public Interest
3.4.2 Change of Ownership
3.4.3 Additional Information or Assistance
If you live in the United States or any other country outside of the European Union, an EFTA state, or the United Kingdom, the data controller responsible for your personal data is Twitter, Inc. with an address of:
1355 Market Street, Suite 900
San Francisco, CA 94103
If you live in the European Union, an EFTA state, or the United Kingdom, the data controller is Twitter International Company, with an address of:
Twitter International Company
Attn: Data Protection Officer
One Cumberland Place, Fenian Street
Dublin 2, D02 AX07 IRELAND
You can confidentially contact Twitter’s Data Protection Officer here. If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority or Twitter International Company’s lead supervisory authority, the Irish Data Protection Commission. You can find their contact details here.
3.4.4 Our Global Operations and Privacy Shield
To bring you our services, we operate globally. Where the laws of your country allow you to do so, you authorize us to transfer, store, and use your data in the United States, Ireland, and any other country where we operate. In some of the countries to which we transfer personal data, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those of your country. Learn more about our global operations and data transfer here.
When we transfer personal data outside of the European Union, EFTA States, Switzerland, or the United Kingdom we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws, contractual obligations placed on the recipient of the data (model clauses may be requested by inquiry as described below), or EU-US and Swiss-US Privacy Shield principles.
Twitter, Inc. complies with the EU-US and Swiss-US Privacy Shield principles (the “Principles”) regarding the collection, use, sharing, and retention of personal data from the European Union, EFTA States, Switzerland, and the United Kingdom as described in our EU-US Privacy Shield certification and Swiss-US Privacy Shield certification.
If you have a Privacy Shield-related complaint, please contact us here. As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Principles, we will seek to resolve it through our internal complaint resolution process, alternatively through the independent dispute resolution body JAMS, and under certain conditions, through the Privacy Shield arbitration process.
Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, participants may be liable for the transfer of personal data from the EU, EFTA States, Switzerland, or the United Kingdom to third parties outside the EU, EFTA States, Switzerland, and the United Kingdom. Learn more about the EU-US Privacy Shield and Swiss-US Privacy Shield here.