WHAT INFORMATION DOES REVLUM COLLECT, AND FOR WHAT PURPOSE?
WHAT IS NOT COLLECTED
Revlum’s monetization platform does not automatically access, collect, or receive your name, your email address, your username, your physical address, your phone number, your credit card or other financial information.
If you opt in to engage with campaign content displayed through the Revlum monetization platform, the ad or offer may ask you for personal information. For example, an ad or offer may link to an advertiser’s website, where the advertiser may ask for your email address to join its mailing list, or your payment information if you are buying its products. A market research survey accessed through the Revlum platform may involve questions about your location (e.g., postal code), demographics, or other information. In each case, it is up to you whether to provide the information requested, and any information you choose to provide in these circumstances is considered voluntarily given. You are always free to decline to provide information in connection with a campaign, though doing so may affect whether the campaign partner considers you to have completed the action required to earn the reward.
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.
WHAT INFORMATION IS COLLECTED THROUGH REVLUM’S MONETIZATION PLATFORM?
If you are an individual who uses a mobile app, and the app’s publisher uses Revlum monetization services, we, where permitted by applicable law, receive and collect information about your device and the campaign content you access through our services, and we use this information to reward you for campaign engagement, to draw inferences about which campaign content 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 campaign content, and through your interactions with campaign content accessed through or on our monetization platform.
Under Revlum’s publisher terms of service, app publishers that integrate and use Revlum’s monetization services must notify their users of the collection and use of their data in connection with Revlum’s monetization services, as described in this policy, and obtain their consent to the extent required by applicable law.
Device identifiers (a device identifier is a string of numbers and letters unique to your smartphone or tablet assigned by the manufacturer or platform provider), such as
Advertising identifier – this is a resettable identifier for advertising use, such as Google Android Advertising ID (GAAID), for Android devices, and ID for Advertisers (IDFA), for iOS devices
Publishers of Android apps have the option of sending other identifiers, such as Google Android ID or MAC address, for use as a fallback identifier or for analytics use
The publisher’s user identifier
Information about the device itself, including:
Whether it is a smartphone or tablet
What operating system and version it uses (example: iOS, version 11.0)
Whether the device’s “opt-out” options related to advertising have been enabled
Model and manufacturer (example: Apple iPhone X, Samsung Galaxy S8)
Screen size, screen density, and other information relevant to ad formatting and display
Information about the internet connection used to access our services, including
Whether the network type is wifi or cellular
Timestamp and duration (when the device connected to our services and how long the connection lasted, for a given session)
Information about the app used to access our services and your use of it, and about our SDK, including
Which version of the app is being used, and which version of our SDK is integrated in the app
API key (identifier for application)
How frequently and for how long you use the app, and, at the publisher’s option, information about what level of the game you’re on and your in-app purchases
If the publisher uses mediation to connect with ad networks, it may opt to send or enable collection of parameters related to mediation services
Signals relating to eligibility for behavioral advertising
Location-related information – We do not request or receive precise (sometimes referred to as “lat-long”) geolocation data; we infer the perceived general location of the device based on:
The IP address used to access our services
Location-related device settings, such as the device’s country code, language setting, and time zone
Information relating to campaign content – We collect information about the campaign content you view, such as:
What the campaign content is about
What type of campaign content it is (example: video)
The reward offered in exchange for your engagement with the campaign content
Which placement is involved (meaning, where and how the campaign content is displayed in the mobile app where you accessed it)
Whether you respond to the campaign content’s “call to action” – for example, did you click through to the advertiser’s website? – or complete its requirements (examples: watching a 30-second video; making a purchase)
Market research information – Responses to market research surveys accessed through our platform are voluntary and opt-in. Responses voluntarily provided by you may include
Demographic information (such as age, household income, gender, highest education completed, household composition)
General location (such as postal code, or city and state)
Other information you voluntarily provide, which may include product preferences and opinions, employment status, marital status, veteran status, health information, race or ethnic origin, political opinions, membership information, sexual orientation, religious beliefs – in each case, subject to applicable law.
If at any time you do not wish to respond to a question, please select “Prefer not to say” or equivalent, or exit the survey
Information from our campaign partners – The campaign partners using our services may provide us with information they have separately collected about you (for example, whether you already have the app that is being advertised), so that we can improve the relevance of the campaign content we serve to you on their behalf (for example, by not showing you an ad for an app you already have).
HOW DOES REVLUM USE INFORMATION COLLECTED THROUGH THE MONETIZATION PLATFORM?
We use the information we collect through our monetization platform in the following ways;
To show you campaign content customized to what our system infers to be your interests, preferences, and locations, based on the information profile associated with your mobile device’s advertising identifier; this is referred to as behavioral or interest-based advertising
To show you campaign content based upon the context of the app you’re using (instead of based on your inferred interests); this is referred to as contextual advertising
To determine which campaign content is more or less effective
For market research purposes
To target and filter campaign content for publishers and campaign partners – for example, a campaign partner may want to reach a user audience in a specific country, or a publisher may want to exclude some categories of campaign content from its app, or a market researcher may want to target a survey to users in a specific age bracket
To avoid showing you campaign content for an app or service you already use, or the same campaign content too many times
To track the rewarded campaign content you engage with, so we can provide you with the rewards you earn
To respond to and resolve your customer support requests
In statistical and aggregate form, for analysis and research, to improve our services and to report our services’ results to our advertisers and publishers
To prevent and detect fraud, and to maintain our services’ and systems’ security
We keep this collected information as long as it remains necessary to provide the Revlum Services.
HOW DOES REVLUM SHARE INFORMATION COLLECTED THROUGH THE MONETIZATION PLATFORM?
The information we collect through our monetization platform is used internally within our platform, and shared only with authorized partners or vendors, as follows:
We provide publishers using Revlum’s analytics service with access to aggregated information about how their users interact with their apps.
We notify publishers that use Revlum’s monetization service and manage their own app currency of when their users earn rewards through our platform, so they can increase these users’ in-app virtual currency balances by the amount of the reward.
We provide campaign partners that use Revlum’s platform to advertise, or their mobile measurement providers, with the advertising device identifiers and IP addresses associated with users who view their campaign content via Revlum, so they can track campaign results and identify which users go on to engage with the campaign partner (for example, by buying the advertised product or service or downloading an advertised app), and which ad networks should receive credit for the user’s action.
We provide campaign partners using Revlum’s platform to conduct market research with the advertising device identifiers, IP addresses, and the voluntarily provided demographic information, such as postal code, gender, marital status, education, ethnicity/race, employment-related information, household size, and other responses, associated with those users who voluntarily engage with market research campaign content, so that we or the campaign partners can identify survey opportunities, support and track participation in surveys, disclose survey response data (including voluntarily provided demographic information) to clients for audience measurement services, append demographic data elements to completed surveys and deliver the appended survey data to clients for analytical or research purposes, manage and improve survey quality issues, and track and deliver rewards earned through engaging with market research campaign content.
Vendors and service providers working for Revlum, or for our campaign partners or publishers, have access to information collected via our platform as necessary for them to perform their services for us, or for the campaign partners or publishers they work for. Under our agreements with our service providers, they can use this information only as needed to perform their services; they cannot use it for their own purposes.
Business Transaction. We may share your information with another company if they merge with us or purchase our assets, or as part of due diligence for such a transaction.
Consent. We may share your information with your consent.
HOW LONG DOES REVLUM KEEP INFORMATION COLLECTED THROUGH THE MONETIZATION PLATFORM?
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. Information used to segment audiences for market research surveys, based on the users’ voluntary responses, is rotated out or refreshed every six months. Conversion data and non-production backups of production data are retained for longer due to financial records and disaster recovery requirements.
HOW CAN I OPT OUT OF INTEREST-BASED ADVERTISING?
If you prefer not to receive campaign content 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 or opt-out flags if passed by the publisher of the app you are using. As of the date of this policy, you can use your device’s native settings to adjust your advertising preferences as follows:
in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking
in Android, visit Settings > Google > Ads > Opt out of interest-based ads
Opting out of interest-based advertising does not mean opting out of advertising altogether. There may still be campaign content in the app you use, but it will not be targeted based on your inferred interests.
CUSTOMER SUPPORT INFORMATION
To submit a request for Revlum customer support (for example, for help with a missing Revlum 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. We may request additional pertinent information, such as the device advertising identifier, the ad offer and publisher involved, and so on. 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 campaign partner and publisher whose campaign and app are involved.
WEBSITE AND DASHBOARD USER INFORMATION
Our campaign partners and publishers have access to a Revlum dashboard. Our dashboard is a business-to-business service that allows Revlum’s commercial partners to manage their use of our platform and 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 this information to provide our commercial partners with Revlum services and support. If you invite other users to your Revlum 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.
REVLUM WEBSITE AND SOCIAL MEDIA
Our corporate website, www.revlum.com, provides general information about Revlum 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 Revlum 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.
COOKIES AND RELATED TRACKING TECHNOLOGIES
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:
Device and usage information. When you interact with our website or dashboard, we may collect information such as
a) IP addresses, unique device identifiers, and other information about your device(s), browser types, browser language, operating system, the state or country from which you accessed the services; and
(b) information related to the ways in which you interact with our website, such as: referring and exit pages and URLs, platform type, the number of clicks, internal Revlum subdomain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the services, error logs, and other similar information. As described in Online Analytics below, we may use third party analytics providers and technologies, including cookies and similar tools, to assist us in understanding how the Revlum Web Services are used.
Location information. We may market to you based on your location, inferred from the IP address you use to reach our website or dashboard.
Cookies and other technologies. When you use the Revlum website or dashboard, we use persistent and session cookies and other similar technologies to perform various tasks, such as:
(a) storing your dashboard account username and password;
(b) analyzing the usage of our website and dashboard; and
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.
HOW REVLUM USES INFORMATION COLLECTED THROUGH OUR WEBSITE AND DASHBOARD
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 campaign partner account, to do business with you as a publisher or campaign partner (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 the user bases and usage patterns for our website and dashboard, 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.
HOW DOES REVLUM SHARE INFORMATION COLLECTED THROUGH THE WEBSITE AND DASHBOARD?
We don’t buy, sell, or trade-in information collected through our website and dashboard. We share only as described here:
Vendors and service providers working for Revlum, or for our campaign partners or publishers, have access to information collected via our ad platform as necessary for them to perform their services we engaged them to do. Unless we tell you otherwise, under our agreements with our service providers, they can use this information only as needed to perform their services; they cannot use it for their own purposes. These service providers include analytics providers, payment processors, product fulfillment providers, providers of technical infrastructure, technical support, email providers, and customer support vendors.
We may share your information in connection with any merger, reorganization, a sale of some or all Revlum assets, or a financing or acquisition of all or a portion of our business by another company (including in the course of due diligence for any such transaction).
We may share your information with your consent.
WHAT CHOICES DO I HAVE ABOUT USE OF INFORMATION RELATED TO REVLUM’S WEBSITE OR DASHBOARD?
Commercial Marketing. We will comply with applicable marketing laws; for example, where applicable law requires prior consent, Revlum will only send you marketing email if you have opted in. To opt out of receiving marketing emails or other commercial communications from us, use the “unsubscribe” option in a commercial email from us or send us an email at firstname.lastname@example.org. It may take several days for us to process your request, consistent with applicable law.
Publisher and Campaign Partner Accounts. If you have access to a publisher or campaign partner dashboard account and do not want your email address used, please contact your account manager or contact us at email@example.com.
Dashboard Account Deactivation. To request deactivation of your dashboard account, email your account manager or contact us at firstname.lastname@example.org. Some information may remain in our records after deactivation of your account based on business needs. After deactivation, we may continue to use any information constituting financial records, as well as aggregated data derived from or incorporating your personal information but not identifying you personally.
GENERAL PRIVACY PRACTICES
HOW DOES REVLUM SECURE PERSONAL INFORMATION?
Revlum processes personal information only as relevant or necessary to provide our services. We use physical, technical, and administrative procedures designed to safeguard your information and data security, and to prevent unauthorized access. 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 access 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 at all times from all unauthorized access.
CHILD AND YOUTH USERS
If you are under the locally applicable minimum age of consent to data use, please do not sign up as a Revlum campaign partner or publisher, engage with any offer-based campaign content, or send us any information about yourself. Publishers who target their apps toward audiences that include young users, in part or in full, 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 Revlum services. Please inform us by emailing email@example.com if you learn that we have been provided with personal information from a child under the applicable minimum age without exclusion flagging or verified parental consent, so that we may take appropriate steps to delete that personal information.
THIRD-PARTY SITES AND SERVICES
FEEDBACK ABOUT REVLUM
If you submit feedback or suggestions about our services, we may use your feedback or suggestions without obligation to you.
NOTICE OF COLLECTION
As described above at, What information is collected through Revlum’s monetization platform? and Website and dashboard user information, Revlum discloses personal information to third parties for commercial purposes, including your mobile device advertising identifier and IP address with campaign partners whose campaign content you access, for tracking purposes, and with the publisher of your app, for delivery of rewards earned by you; if you opt in to respond to a market researcher’s survey, Revlum shares your survey responses, device advertising identifier, and IP address with the market researcher, who may share the information with its client. Revlum uses the information collected through our monetization platform to infer your interests and target campaign content displayed to you based on those inferred interests. Market research campaigns may include questions intended to help Revlum or our market research campaign partners or their clients identify audience segments to target based on criteria set by the market researcher or its clients. We partner with service providers and vendors to assist with our daily operations and manage our Service. Please review, “How does Revlum share information collected through the monetization platform?” and “How does Revlum share information collected through the website and dashboard?”, above, for more detail.
RIGHT TO OPT-OUT
You have the ability to opt-out of the use of your personal information for behavioral advertising at any time.Please review the section above titled, How can I opt-out of interest-based advertising?.
Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them.
As described above, app publishers use Revlum to monetize their apps, through displaying campaign content to users in the apps, provided by third-party campaign partners. Campaign partners use Revlum to access app users for their campaigns, and reward the users (in the form of in-game currency or tokens in the publisher’s app, or access to additional or premium app content) for their engagement with campaign content. Revlum is the platform supporting and enabling these interactions between users, publishers, and campaign partners. These interactions may involve in-app currency rewards or other benefits to users, which may or may not qualify as financial incentives, but any such rewards or benefits are offered by or on behalf of campaign partners and publishers, not by Revlum. In any case, your voluntary use of the Revlum platform, by engaging with campaign content to access in-app rewards, regardless of form, will be interpreted as affirmative consent to the terms of such incentive.
THE EU GDPR
The EU General Data Protection Regulation (“GDPR”), effective May 25, 2018 in the EEA countries and Switzerland, requires Revlum 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.
LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA
You provided your consent. To store and access information on your device, we rely on your consent. For this “cookie consent” (which applies not only to “cookies” but also to mobile device advertising identifiers), to fulfill our obligations under the ePrivacy Directive, we rely on the mobile app publishers that use our services and oblige them contractually to pass on only legally obtained data. In some circumstances, we may obtain your consent directly, in which case we will adhere to applicable laws relating to consent and its withdrawal.
The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing personal data to provide our and our commercial partners’ services. A legitimate interest we rely on, for instance, is the tailoring of campaign content and opportunities to obtain in-game rewards to users of mobile applications; this benefits users through a value exchange that goes beyond the original collection of mobile device advertising identifiers. Our legitimate interest also includes providing analysis of and reporting about ad campaigns. We also rely on legitimate interest when we use personal data to maintain the security of our services, including fraud detection and identifying and fixing bugs.
Contractual Relationships. Sometimes, we process personal data as necessary under a contractual relationship we have, such as our customer records and contact information.
Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.
TRANSFERS OF PERSONAL DATA
We are based in the EEA, 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.
PERSONAL DATA RETENTION
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 and personal data used for market research audience segmentation and targeting on a 180-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 Revlum campaign partner 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.
EXERCISING YOUR RIGHTS
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).
RIGHT TO OBJECT TO PROCESSING OR TO WITHDRAW CONSENT
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 or opt-out flags if passed by the publisher of the app you are using. For instructions and more detail, please see above at, How can I opt out of interest-based advertising? Please note that opting out does not mean opting out of advertising or campaign content altogether; there may still be campaign content in the app, but it will not be targeted based on your inferred interests.
RIGHT TO ERASURE
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 submitting a request to firstname.lastname@example.org 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.
REVLUM: A DATA CONTROLLER AND A DATA PROCESSOR
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.
Revlum 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.
QUESTIONS OR CONCERNS
To opt-out of Revlum services or access your personal information, please contact us at email@example.com
If you have any questions or concerns regarding our privacy policies, please send us a message to firstname.lastname@example.org.
Please visit https://revlum.com/contact/ to access our customer support center for help with customer support questions or concerns.