Privacy
Policy

Ogury Product Privacy Statement

Last updated: 17 April 2019

Ogury Limited (“Ogury”, “we” or “us”) cares about its users’ privacy and is committed to clearly describing and disclosing its data practices.

Welcome to Ogury

Ogury is a mobile advertising technology company. We develop and maintain software code that mobile app publishers and developers ("Publishers") integrate into their apps ("Apps") to show ads which are placed by advertisers and advertising agencies (together “Partner(s)”). Ogury’s suite of solutions for Publishers include Active Insights and Intelligent Monetization – in this Privacy Statement, we call these solutions the “Ogury Product”.

Once the Ogury Product has been integrated into an App, after receiving user consent, Ogury collects certain data ("User Data") relating to the user of the tablet, mobile or handheld device (“Device”) on which the App is installed. The User Data we collect is described in this Privacy Statement (see the heading "What is User Data?"), and we only collect User Data with consent from the relevant Device user. Your consent applies across to all Apps you have installed (or may in future install) that contain Ogury’s technology.

This Ogury Product Privacy Statement explains how Ogury collects, stores, uses, and shares User Data (including personal information) from users who have installed Apps on their Devices.

For details of how the advertisement mediation services forming part of the Ogury Intelligent Monetization product (operated by Purple Brain SAS, an affiliate of Ogury Ltd, formerly trading as Adincube) will collect, store, use, and share data about you in connection with its ad mediation services please visit its separate Privacy Notice available here.

What Is User Data?

Through the Ogury Product integrated into Apps, Ogury collects User Data, however, we do this only where Users have consented to this collection. The User Data we collect comprises the following categories of information:

Usage Data

We collect data about how Users use their Devices, together with the applications and systems on those Devices – this information includes:

What websites Users have bookmarked in their mobile browser.

Which websites Users have visited.

What applications are installed on the Users’ Device.

Users’ usage levels of these applications.

The Usage Data collected by the Ogury Product is not limited to Usage Data that directly relates to the App in which the Ogury Product is integrated. Rather, the Ogury Product collects Usage Data from all applications and systems on the Device on which an App is installed.

Technical Information

We collect technical Information relating to Users' Devices, that includes:

The type of Device being used (including manufacturer and model).

The version number of the Ogury Product used by the App.

A User’s network status (limited to connection type; gsm, 3G, 4G/wifi etc).

Identifiers

Ogury links the Usage Data and Technical Information it collects listed above to certain device and user identifiers it collects from Users and their Devices, which include:

the User's email address & other mobile advertising identifiers on the Device (Ogury collects this information only where a User’s Device allows it through the Publisher Apps in order to derive insights such as gender and then we delete or anonymise the email addresses after 3 days).

your Device’s unique Advertising ID, such as Google AAID or Apple IDFA.

IP Address.

All User Data we collect is associated with these Identifiers.

Ad engagement information

To enable Ogury and its Partners to provide more personalised Ogury ads to Users (as described in the "How is User Data used?" section below) and to report ad engagement metrics back to our Partners, we collect information on how Users engage with Ogury ads that are displayed to them, including:

What each Ogury Ad is about.

The format of each Ogury Ad (e.g., text, image, or video).

Where the Ogury Ad is displayed within the App.

User interaction with the Ad (for example, clicks and how long the Ad was displayed for).

In addition, we combine this Ad Engagement Information with Usage Data collected about Users to determine what Users do when interacting with or after viewing each Ogury Ad – for example, to identify whether a User proceeded to buy the product or services that were displayed to them in an Ogury Ad.

Crash reporting information

To enable Ogury and its Partners to help to improve the Ogury Product and resolve technical problems, we collect information in cases where the App has crashed, including: date and time of the crash, Advertising ID, API key, app package name and version, phone model, phone android version and a crash message.

Other information

User Data includes any other information (including personal data) that may be submitted to us directly (for example, through a User submitted form or survey response).

Our policy towards children

In accordance with applicable European Union guidance on the practice, we do not knowingly collect User Data from children or use any User Data to target adverts to children. Accordingly, we do not collect or use User Data to target Ogury ads to children under 16 years old. If you believe we have inadvertently collected User Data from or about a child, please contact us using the details provided under the heading "Contact Us" below.

How is User Data used?

In simple terms – User Data is used by Ogury and its Partners to select and serve to Users adverts for products and services they actually want to see based on how they use their Device.

Adverts of this nature are commonly referred to as “interest-based advertisements” or “behavioural advertising”. For more information on interest-based advertising, how it works, and information on choices about how Users can interact with it, Users can go to http://www.youronlinechoices.com/uk/. This is a helpful guide made available by the European Interactive Digital Advertising Alliance a cross-industry coalition of European-level associations with an interest in delivering a responsible European Self-Regulatory Programme for Online Behavioural Advertising, which benefits internet users with greater transparency, choice and control.

Collecting User Data also allows us to effectively cap the number of times that Users see an Ogury Ad, so they do not see the same one too many times or too frequently.

We may also use User Data to create aggregated compilations of Users which are “deidentified” for the purposes of reporting to Partners; in a manner which prevents that User Data from being associated with, or capable of being associated with, any particular Device, Partner or App (“Aggregated Data”).

In addition, Ogury also uses User Data for its internal purposes which may include:

performing analysis and research aimed at improving the Ogury Product and the services and products Ogury provides to its Partners; and

ensuring we get paid properly by advertisers for the Ogury ads we deliver, and that we pay Publishers properly for the Ogury ads displayed in their Apps; and

security and fraud detection (e.g. protecting against click-fraud and similar unlawful activities).

Our approach to consent

We respect your right to privacy. That's why we ask Users to give their consent before Ogury starts to collect any User Data from them. In addition, Users may opt-out of such collection at any time by following the instructions outlined at the section titled “Opting Out of Ogury Interestbased Advertising”.

Accordingly, when Users use a version of an App which contains the Ogury Product, a page is displayed which notifies them that, with their consent, certain User Data will be collected by the Ogury Product unless and until they subsequently opt-out from such collection. So that Users are fully and properly informed about our data usage practices and how their User Data is collected, stored, used and shared, they are also provided with a link to this Privacy Statement.

If Users do not give consent, Ogury will not collect their User Data and will not deliver them targeted Ogury ads. However, Users will still see advertisements in their App, but the advertisements they see will not be tailored to them based on their User Data. We also keep records of the Advertising ID to allow us to identify which Users have opted out.

Ogury is a member of the IAB Transparency and Consent Framework and we may share your consent preferences with other IAB approved members in order to meet transparency and user choice requirements. The full vendor list is available here: http://advertisingconsent.eu/vendor-list/

Opting Out of Ogury Interest-based Ads

Users can opt out of receiving targeted Ogury ads (and from having their User Data collected by Ogury) and request the deletion of their User Data by following the below link and entering their Google Advertising ID (AAID) or Apple advertising ID (IDFA) in the resulting form: https://consent.ogury.co.

When Users notify us of their desire to opt-out of receiving interest-based Ogury ads, we will promptly stop collecting their User Data. If they opt-out, Users will still see advertisements in their App, but the advertisements they see will not be tailored to them based on their User Data.

In addition, we will promptly anonymise or delete from our systems any User Data that we have already collected.

In addition to the opt-out process described above, if their Device permits, Users may be able to opt out of interest based advertising by changing the settings of their Device as follows:

Google Advertising ID (AAID)

You can change your Google Advertising ID settings by following these instructions: open Settings on your Device and go to Google > Ads > Opt out of Ads Personalisation. Users should be aware that clicking this opt-out button will disable interest based ads from all advertising networks that use Google Advertising IDs, although Users will still see untargeted advertisements.

Apple iOS Advertising ID (IDFA)

You can change your Apple Advertising ID settings by following these instructions: open Settings on your device and go to Privacy > Advertising > Limit Ad Tracking. Users should be aware that clicking this opt-out button will disable personalised ads from all advertising networks that use Apple Advertising IDs, although Users will still see untargeted advertisements.

How Ogury shares User Data

We share the User Data that we collect in the following ways and with the following parties below. You can also view our current list of partners with whom we may share some User Data here.

Publishers and advertiser

We may share User Data with our Partners to aid in their understanding of how Users are using Apps and engaging with Ogury ads.

Aggregated data

We may share or sell compilations of Aggregated Data or Aggregated pseudonymous data with Partners and third parties, where we are lawfully entitled to do so.

Service Providers

We may share User Data with the service providers who perform services on our behalf, such as providers of analytics, payment processing, product fulfilment, technical infrastructure, data services, engineering and other technical support, and email and customer support.

Business transactions

We may share User Data in connection with any merger, reorganisation, a sale of some or all Ogury assets, or a financing or acquisition of all or a portion of our business by another company. In these circumstances, Ogury will instruct the parties with whom User Data is shared to protect the User Data they receive in accordance with this Privacy Statement.

Legal purposes

We may share User Data for the following purposes:

To comply with laws or to allow us to enforce the terms of this Privacy Statement.

To respond to lawful requests and legal processes.

To protect the rights and property of Ogury, our agents, customers, and others.

To protect the safety of our employees and agents, our Partners or any other person.

Ogury affiliates

We may share User Data with other companies within the Ogury group of companies, and require these Ogury companies only to process the User Data for the purposes described in (and subject to the protections described in) this Privacy Statement.

Data Management Platforms

We may share or sell User Data to data management platforms that are used by participants in the advertising industry as sources of data (“Data Management Platforms”). The User Data we may share or sell may include any or all of the User Data outlined above.

Data Management Platforms use the data Ogury and many other participants in the advertising industry, sell to them to inform advertising targeting and the purchase of advertising space.

Your data protection rights

You have the following data protection rights:

If you wish to access, correct, update or request deletion of your User Data, you can do so at any time by contacting us using the contact details provided under the “Contact Us” heading below.

You can also object to processing of your User Data, ask us to restrict processing of your User Data or request portability of your User Data. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact Us” heading below.

Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. To opt-out of interest-based advertising based on your User Data, please see the heading "Opting Out of Ogury Interest-based Ads" above.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

General

International Data Transfer

User Data, including any personal data therein, may be transferred to, stored at and processed by third parties in a country outside the EEA.

Users should be aware that the data protection and privacy regulations that apply in countries outside the EEA may not offer the same level of protection as provided for inside the EEA.

When we transfer User Data outside of the European Economic Area, we will ensure that there are appropriate safeguards in place for the User Data by:

transferring the User Data to countries which have been deemed to provide an adequate level of protection by the European Commission; or

implementing other appropriate safeguards, such as: (i) the Standard Contractual Clauses adopted by the European Commission for transfers of personal information outside of the EEA, which are available on the European Commission's website here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en; and (ii) transferring User Data to recipients in the United States of America who have certified their compliance with the EU-US Privacy Shield administered by the US Department of Commerce.

If you have any questions about our international transfers of User Data, please contact us using the contact details provided below.

Data security

We seek to use appropriate organisational, technical and administrative measures to protect User Data within our organisation. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If a User has any reason to believe that their interaction with us is no longer secure, they should notify us of this problem immediately by contacting us at privacy@ogury.co

Data retention

We retain User Data we collect from you where we have your consent to do so. If you withdraw your consent, we will either delete or anonymise your User Data. Our retention period for User Data is 3 years, after this 3-year period all data is automatically deleted.

Customer support

If, while using one of our Apps, a User recognises a problem with an Ogury Ad, they can notify us of the problem by contacting us via email at privacy@ogury.co. We will ask for their email address and other contact information so that they can receive a response.

Third party websites

If Users follow a link to any of third party websites via an Ogury Ad, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. The links to third party websites or locations are for convenience only and do not signify our endorsement of such third parties or their products, content, or websites. Ogury does not control the privacy policies of third parties.

Legal basis for processing personal information

In general, we collect, use and share the personal information contained in User Data where we have your consent to do so and you can withdraw consent at any time, as explained above under the headings "Our approach to consent" and "Opting Out of Ogury Interest-based Ads".

Updates to this Privacy Statement

We may update this Privacy Statement from time to time in response to changing legal, technical or business developments. When we update our Privacy Statement, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Statement changes if and where this is required by applicable data protection laws.

You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Privacy Statement.

Contact us

If you have any questions or concerns regarding our data usage practices or this Privacy Statement, please send us a message at DPO@ogury.co. Our data protection officer can also be contacted at this e-mail address.

The data controller of any personal information contained within User Data is Ogury Limited, whose address is 24 Highbury Grove, London, N5 2EA.