Tapjoy, Inc. operates a platform that enables advertisers to reach mobile in-app ad inventory, mobile app users to be compensated for their attention, and mobile app publishers to receive revenue from the ad space in their applications.
Tapjoy is a member of the Interactive Advertising Bureau (IAB). More information about the IAB may be found here [http://www.iab.net/public_policy/codeofconduct].
Publishers use Tapjoy by adding our SDK to their apps; this allows us to display ads on behalf of our advertisers in ad space within the app (our advertising and monetization service). (“SDK” is short for “software development kit”, meaning software that an app publisher can include in its app to enable Tapjoy Services in the app.)
Advertisers use Tapjoy by placing orders for our ad services, and in turn, we pay publishers for the right to show ads in their apps.
Users use Tapjoy through engaging with ad offers we display through our ad placements in a participating publisher’s app. Tapjoy ad placements include offerwall, which allows a user to choose from a page of various rewarded ad offers (“rewarded” meaning that the user receives a reward in the form of virtual currency for the app they’re using); video, which offers the user virtual currency reward in exchange for engaging with a video offer; and interstitial, which rewards the user with virtual currency or access to premium content in exchange for a short commercial break.
To further support our publishers, we also offer related optional services, such as analytics, which helps publishers understand how their users use their apps, and virtual currency management services, which helps publishers manage in-app virtual currency.
We provide customer support for users who did not receive an expected in-app reward; this involves working with the advertiser, the user, and the publisher to identify and resolve the issue.
That depends on how you interact with Tapjoy. Read on to learn about the following categories:
It may be helpful to know what information is not collected about you or your device: Tapjoy’s ad platform does not access, collect, or receive your name, your email address, your username, your physical address, your phone number, your credit card or other financial information.
(One exception: In connection with customer support, you may provide us with additional information, such as your email address or Twitter handle, and which we use to respond to your request; see Customer support information, below.)
If you are an individual who uses a mobile app, and the app’s publisher uses Tapjoy Services, we receive and collect information about your device and the Tapjoy ad offers that you view, and we use this information to reward you for offer engagement, to draw inferences about which offers may be more or less interesting to you, and to provide publishers with information about how their apps are used. This information is collected through our SDK, as integrated into the app you use to access Tapjoy ad placements, and through your interactions with ads on our ad platforms.
Here are the types of information that we collect:
We use the information we collect through our ad platform in the following ways;
We keep this collected information as long as it remains necessary to provide the Tapjoy Services.
Tapjoy does not buy, sell, or trade information with unrelated third parties. We collect the information we use through our ad platform, and we use it internally within our ad platform. This information is shared in only with authorized partners or vendors, as follows:
We keep information as long as necessary to provide our services, generally speaking. Information used for interest-based ad targeting is rotated out on a 90-day basis. Conversion data and non-production backups of production data are retained for longer due to financial records and disaster recovery requirements.
If you prefer not to receive ads and offers that are tailored to your perceived interests, you can enable device-based “opt-out” options in your device’s settings. If you do so, we will cease processing your personal data for such purposes. We collect these opt-out signals ourselves, and will also respect consent flags if passed by the publisher of the app you are using. To adjust your advertising preferences in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads. You can also request an opt-out specific to Tapjoy by visiting the Data & Privacy Requests page and following the directions we provide you.
Opting out of interest-based advertising does not mean opting out of advertising altogether. You will still receive advertising, but it will not be targeted based on your inferred interests.
To submit a request for Tapjoy customer support (for example, for help with a missing Tapjoy ad offer reward), you must submit a working email address; this is required for us to be able to communicate with you about investigating and resolving your support issue. Emails and other information submitted for support purposes are used only for support purposes; depending on the circumstances, this may require us to share your information with the advertiser and publisher whose advertisement and app are involved.
Our advertisers and publishers have access to a Tapjoy dashboard, which allows them to manage their use of Tapjoy Services and review their results. When you create a dashboard account, you provide information such as your name, the name of your company, your username and password, your email address, postal address, phone number, and payment information, as well as any required financial information (e.g., tax ID, VAT, or sales tax registration number). We use Stripe to process Advertiser credit card payments. We use this information to provide you with Tapjoy Services and support. If you invite other users to your Tapjoy dashboard account, we will collect the email address of the employee or other individual you wish to add and use it to send them a one-time email informing them they have been added. If they are not your employee, you must have their consent before providing us with their email address to invite them to join your dashboard account.
Our corporate website, www.tapjoy.com, provides general information about Tapjoy and our products and services; we also maintain a blog and various social media channels. If you post information through one of these channels, you understand that we cannot control what other users do with any content (including without limitation images, ratings, captions, and comments) you voluntarily post. You should not post any sensitive personal data, such as details of your ethnicity, health or political preferences or photos of yourself to any Tapjoy board, blog, social media channel, or forum, nor should you allow other users to have access to your content if you do not wish them to make your content publicly available to be collected and used by others, or to be redistributed through the Internet and other media channels.
When you use our website and dashboard, we may place and read cookies or access information on your device to obtain information about the performance of our site, enable you to move around the site, to record your preferences and to serve you with advertising that is relevant to your interests. This information may, where permitted by applicable law, then be combined with other information we hold about you. Information and technologies we may use include:
To help understand your use of our website and dashboard, we use third-party web analytics providers, such as Google Analytics, which in turn use the technology described above at Cookies and related tracking technologies. Our service providers collect and use this information to evaluate how websites are used. To opt out of tracking via Google Analytics, you may install the Google Analytics Opt-Out Browser Add-on.
We use the information we collect through your use of our corporate website and our dashboard to provide our services, to manage your publisher or advertiser account, to do business with you as a publisher or advertiser (including taking orders, reporting results, and so on), to communicate with you (including responding to your inquiries, informing you about products and services based on your marketing preferences, and notifying you of new features), to analyze our user base and usage patterns, and to provide and improve our services. We also use this information to improve our corporate website content and to personalize the dashboard for you. We keep the information we collect for so long as we continue to provide our website, dashboard, and services.
We don’t buy, sell, or trade in information collected through our website and dashboard. We share it only as described here:
We no longer collect information from or about users of our legacy apps (TapDefense, TapOut, Coloroid, TapColors, Void Walker) and legacy app-discovery and currency-management services (MyTapjoy). We are no longer maintaining, updating, or supporting these apps and services; continued use is at the sole option and risk of the user.
Tapjoy processes personal information only as relevant or necessary to provide our services. We use physical, electronic, and managerial procedures designed to safeguard your information and data security, and to prevent unauthorized access to. These safeguards take into account the sensitivity of the information that we collect, process, and store and the current state of technology. Although we take such measures to safeguard against unauthorized disclosures of information, the Internet and the services are not 100% secure so we cannot assure you that all information we collect or store will be protected from all unauthorized access.
If you are under the locally applicable minimum age of consent to data use, please do not register for any Tapjoy service or send us any information about yourself. (In the US, your minimum age is 13; in the EEA and Switzerland, it is age 16 unless your country has adopted a lower age.) Publishers of apps with mixed audiences may choose to offer users below the minimum age the ability to access advertising content through our platform and services; as a condition for doing so, the publisher is required to flag the users’ devices and associated data for exclusion from behavioral targeting, and contextual advertising is provided instead. Users below the minimum age are not otherwise eligible to interact with Tapjoy Services; please inform us by emailing firstname.lastname@example.org if you learn that we have been otherwise provided with personal information from a child under the applicable minimum age without verified parental consent, so that we may take appropriate steps to delete that personal information.
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. As explained above, we do not sell or share your personal information (as that term is defined under California law) with third parties for use for their own marketing purposes.
You may, under applicable European law, have the right to access, correct, update or delete personal information Tapjoy holds about you. Please see Exercising your rights as an app user below for more information about those rights.
If you have a Tapjoy publisher or advertiser dashboard account, you may use your account settings to access and update your account information. You may also email us at email@example.com to request access to or removal of personal information we have about you. In some cases, we may not be able to remove your personal information (e.g., for legal reasons), in which case we will let you know if we are unable to do so and why.
The EU General Data Protection Regulation (“GDPR”), effective May 25, 2018 in the EEA countries and Switzerland, requires Tapjoy and the publishers and advertisers using our services to provide app users with information about the processing of personal data. (“Personal data”, as used in the GDPR, means information relating to an identified or identifiable natural person, including name, address, cookie identifiers, mobile device identifiers, and more; “app user” here means the person involved; and “processing” of data includes collection, storage, and use.)
This section provides representations and information in compliance with our GDPR obligations, for the benefit of our users located in the EEA countries and Switzerland only.
We are based in the United States with offices around the world, and work with other global companies and technologies. As a result, we may need to transfer your personal data outside of its country of origin. For instance, we may transfer your personal data to commercial partners or service providers located in jurisdictions outside the EEA and Switzerland, which have data protection laws less strict than those in Europe.
When Tapjoy receives personal data that is transferred from the EEA or Switzerland to Tapjoy in the US, we take steps to make sure that appropriate safeguards are in place to protect it; we use European standard contractual clauses, data processing agreements where required by European Data Protection Law, and EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. Our Privacy Shield certification is available at https://www.privacyshield.
As a general matter, we retain your personal data for as long as necessary to provide our services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. We generally rotate through personal data used for ad personalization on a 90-day timetable, provided that we may retain data if we have a legal or significant operational need to do so, such as for auditing, corporate record-keeping, compliance, accounting or bug-fixes.
If you are a Tapjoy advertiser or publisher, we retain your information as long as your account is active and for as long as necessary for legal or operational purposes, such as auditing, corporate record-keeping, compliance, or accounting, after its closure.
As an individual covered by the GDPR, you have certain rights about the personal data that data controllers hold about you, including right of access, right to request correction, right to be forgotten (i.e., deletion), and right to object to processing (including profiling for online ad targeting).
If you are a consumer and wish to exercise your right to access personal data we process as a data controller, you may do so by visiting the Data & Privacy Requests page and following the instructions we provide you to authenticate your request and obtain access. We will assess requests to exercise data access rights on a case-by-case basis, factoring in the difficulty of verifying whether a mobile device identifier, and the data we have linked to it, truly and solely belongs to the person making the request, as well as the potential risk of harm through disclosure of personal data to the wrong individual. Because improper disclosure would likely harm the privacy rights and freedoms of the person involved, we may limit the personal data we make available. We only grant requests where we are the data controller, as explained further, below. Where we act as a processor for one of our advertisers or publishers, we will refer your request to that company; if your request involves an advertiser or publisher, please identify them (if possible) to simplify this process.
If you have a Tapjoy publisher or advertiser dashboard account, you may use your account settings to access and update or delete account information. You may also visit the Data & Privacy Requests page .
If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below.
By enabling device-based “opt-out” options in your device’s settings, you may withdraw consent for processing where we rely on consent. If you do so, we will cease processing your personal data for such purposes within 30 days. We collect these opt-out signals ourselves, and will also respect consent flags if passed by the publisher of the app you are using. To adjust your advertising preferences in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads. You can also request an opt-out specific to Tapjoy by visiting the Data & Privacy Requests page and following the directions we provide you.
You also have the right to request erasure of personal data that we hold as a controller. The above opt-out process satisfies this right, because when a user opts-out (whether through device settings or by visiting the Data & Privacy Requests page and following our instructions), we stop using your personal data to provide our services to you; the data is permanently rendered disconnected to your device and will be automatically deleted from our production system. We may retain copies of some personal data for our own internal and necessary purposes, such as auditing, accounting and billing, legal, bug-detection, backups, and (if applicable) to ensure that you receive and that we are able to track the rewards you have received.
We encourage you to contact us at the contact information below should you have a Privacy Shield-related (or general privacy-related) complaint. If you are a resident of the European Union and are dissatisfied with the manner in which we have addressed your concerns about our privacy practices, you may seek further assistance, at no cost to you, from our designated Privacy Shield independent recourse mechanism, JAMS, on their website at https://www.jamsadr.com/eu-us-privacy-shield. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. Prior to initiating such arbitration, you must: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from our designated independent recourse mechanism; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. Each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the individual. Tapjoy is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
EU data protection law makes a distinction between organizations that process personal data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your personal data is handled, we encourage you to direct your inquiry to the relevant data controller, since data controllers have primary responsibility for your personal data.
Tapjoy may act as either a data controller or a data processor in handling your personal data, depending on the precise circumstances. For instance, for personal data that we use internally to create our data-related services, such as interest-based ad targeting, and for personal data that we collect about our publisher and advertiser customers for use in marketing to them, we are a data controller. But when we handle personal data strictly on behalf of our customers to provide our services to them (for example, if they provide us with a list of device identifiers to use for targeting or suppression), we are a data processor. If you have questions about data that is used primarily on behalf of one of our publishers or advertisers, you should contact them.
To opt-out of Tapjoy Services, visit the Data & Privacy Requests page and follow the provided instructions.
To access your personal information, visit the Data & Privacy Requests page and follow the provided instructions.
If you have any questions or concerns regarding our privacy policies, please send us a message to firstname.lastname@example.org, or mail us at Tapjoy, Inc., 353 Sacramento Street, 6th Floor, San Francisco, CA 94111, U.S., Attn: Privacy, or call us at +1 415-766-6900.
Our representative in the EU may be reached by writing to Tapjoy Limited, International Buildings, 5th floor, 71 Kingsway, London WC2B 6ST, UK.
Please note, these communication channels do not support customer support matters. Please visit http://tapjoy.force.com/ to address any customer support questions or concerns.
Effective Date: September 20, 2019