Privacy Policy

Downstream.AI. Inc. - Privacy Policy

Effective date: April 9, 2018

Downstream.AI, Inc. (“we,” “us,” “our” or “Downstream.AI”) is a mobile advertising company that provides advertisers with a platform to conduct real-time bidding. Our technology enables our advertisers to show mobile application users more relevant advertising that is based on users’ interests and behaviors. In order to provide these services, we collect and use certain information about user activity and preferences.

Downstream.AI is committed to treating your personal information with care and respect. As such, we have designed this Privacy Policy to help you understand our privacy practices.

By using our services in any manner, you acknowledge that you accept the privacy practices and policies we outline in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the ways outlined in this policy.

EU-U.S. Privacy Shield

Downstream.ai, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Downstream.ai, Inc. is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]

Downstream.ai, Inc. is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Downstream.ai, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Downstream.ai, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Downstream.ai, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Definitions

The capitalized terms listed below have the following meanings when used in this Policy:

Data Collection

Downstream.ai provides application Services that enable its Clients to deliver advertising to consumers based on their behavior and interest. If you interact with a Property or otherwise with our Services, we may collect the following information so that we can provide our Service to our Client:

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All of this information is Anonymous Information (i.e., not Personally Identifiable Information). Once we collect this Device Information, it may be encrypted or hashed depending on the sensitivity of the information in question. We may also combine your Device Information with other, similar data from other consumers to create Aggregated Information

We collect personally identifiable information (PII) when voluntarily submitted by our visitors. This information is used to fulfill specific requests and services.

The Site may use cookie and tracking technology depending on the features offered. Cookie and tracking technology are useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help customize the Site for visitors. Personal information cannot be collected via cookies and other tracking technology, however, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties.

When our Client uses our Services to request that we serve an ad to you, we collect Device Information that we use as provided in this Policy (you grant the necessary consents for such collection to occur when you download or use our Client's application). We use Device Information as follows:

Distribution of Information

We will share your information with third parties only in the ways that are described in this Policy. The information we collect is not shared, rented, or sold to any third-parties.

Personally Identifiable Information. We may provide your Personally Identifiable Information as follows:

Anonymous Information

In addition to the types of disclosures of your Personally Identifiable Information that we may make as set forth above, we may share your Anonymous Information with our Clients and other third parties as provided in this Policy. As discussed above, we may combine your Anonymous Information with similar information of other consumers to create Aggregated information, which we may share with our Clients and the general public in the course of marketing our Services use otherwise for general analytics of the Services and our Site.

Data Security

We are committed to protecting your Personally Identifiable Information from unauthorized access, use, or disclosure. Downstream.ai takes reasonable steps to protect all data in our possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction. Downstream.ai controls and physically protects media and establishes appropriate operating procedures to protect documents, computer media, input/output data and, system documentation from unauthorized disclosure, modification, removal, and destruction.

Prior to disposal, Downstream.ai checks all items of equipment containing storage media to remove or securely overwrite data and licensed software. Devices containing sensitive information are physically destroyed or the information is destroyed, deleted or overwritten.

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure all information we collect from loss, misuse, unauthorized access or disclosure, alteration, or destruction. However, no data security measures can be 100% secure. As such, we cannot guarantee the security of data in our possession or data that is on, or transmitted via, the Internet.

Data Privacy

Downstream.ai complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Downstream.ai has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Downstream.ai commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Downstream.ai at yourprivacy@downstream.ai.

http://www.downstream.ai/privacy.html

Downstream.ai has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Enforcement

We use a self-assessment approach to assure compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and consistently applied. However, if you believe we have not complied with the terms of this Policy, please feel free to contact BBB or us as provided below.

Where a complaint cannot be resolved by any of the before mentioned recourse mechanisms, individuals may have a right to invoke binding arbitration under the Privacy Shield Panel as a recourse mechanism of 'last resort'. The Federal Trade Commission (FTC) has jurisdiction over Downstream.ai compliance with the Privacy Shield.

Mobile Tracking Opt-Out

You can opt out of having your mobile advertising identifiers used for certain types of interest-based mobile advertising, including those performed by Downstream.ai, by accessing the settings on your Apple or Android mobile device, as follows:

Please note that these platforms control how these settings work, so the above instructions may change. Likewise, if your device uses other platforms not described above, please check the settings for those devices.

Desktop Cookie Opt-Out

You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.

You may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s website and the Digital Advertising Alliance’s website. Please note that these opt outs apply to interest-based advertising by participating advertisers. You may still receive other types of online advertising from participating advertisers, and the websites you visit may still collect information for other purposes. In addition, the opt-out choices you select are stored in opt-out cookies only in the browser that you use to visit the opt-out websites, so you should separately set your preferences for other browsers or Devices you may use. Deleting browser cookies can remove your opt-out preferences, so you should visit these opt-out websites periodically to review your preferences or update your preferences to apply to new participating advertisers.

Publishers and Advertisers may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the privacy policies for the Apps to learn more about the privacy practices of Publishers and Advertisers. Please note, however, that we are not responsible for the privacy practices of Publishers, Advertisers, and other third parties.

Privacy Contact Information

If you have any questions, concerns, or comments about our privacy policy you may contact us at:

Downstream.ai, Inc

yourprivacy@downstream.ai