PRIVACY POLICY

Last Updated: March 5, 2014

Overview

Flurry, Inc. takes the privacy of our customers ("Customer" or "you" or "your") and their end users ("End Users") seriously. We recognize that privacy is an important issue, so we design and operate our services with the protection of your privacy in mind. This privacy policy ("Policy") explains how your personal information and information regarding your End Users is collected, used, and disclosed by Flurry, Inc. and its subsidiaries, and any parent and affiliated companies ("Flurry", "us" or "we") with respect to the services referred to in this Policy. This Policy applies to the websites provided by Flurry (collectively the "Sites") and the Flurry services outlined below (collectively, "Flurry Services"). This Policy does not apply to websites, applications or services that display or link to different privacy statements.

How We Collect and Use Information

  • Using Flurry services:

    When you use Flurry Services, we may request information, including your first and last name, an email address and password, and your cell phone number to create your Customer account. We use such information to manage your account and to provide you with access to the Flurry Services. We may also use the information to notify you of updates to the Flurry Services and provide you with access to special promotions.

  • Via Email:

    We place email links on the Sites to allow you to contact us directly. The information you provide, which may include personal information, is used to respond directly to your questions or comments. We may also file your comments to improve the Sites and Flurry Services, or review and discard the information.

  • Via Flurry Analytics:

    Flurry Analytics provides information to you about how your End Users use their mobile applications as well as how applications are performing across different handsets. Flurry obtains this information as a result of data being sent to our servers from our software "agent" if embedded by you in an End User's mobile application. The data collected by the agent may include: agent version, platform, SDK version, timestamp, API key (identifier for application), application version, device identifier, iOS Identifier for Advertising, iOS Identifier for Vendors, Media Access Control (MAC) address, International Mobile Equipment Identity (IMEI), Model, manufacture and OS version of device, session start/stop time, device uptime, locale (specific location where a given language is spoken), mobile network code/mobile country code, time zone, network status (WiFi, etc.), memory, disk, CPU and battery usage information. We hash iOS device identifiers, MAC address and IMEI; however, we do not hash platform device identifiers such as the iOS Identifier for Advertising, ANDROID_ID and the BB_PIN. Hashing involves the transformation of these identifiers into a value or key that represents the original identifier. The device identifiers (if applicable), IMEI (if applicable), MAC address (if applicable), and platform are hashed to a Flurry ID. Flurry may use any combination of the data collected by the software agent to identify an End User's device.

    If you use the restricted version of Flurry Analytics in an application, our agent collects the same information as described above, but it restricts the use of the device identifiers to provide analytics only for that application. An application using this restricted version will not be able to use benchmark data, Personas, or age and gender estimations provided under the complete version of Flurry Analytics. In addition, your analytics information will not include any latitude and longitude data at any level from your End Users.

    If our mobile web software agent is embedded by you in your mobile web application, we may use persistent cookies in conjunction with our software agent to collect the same information as described above, with the exception of any device identifier, iOS Identifier for Advertising, iOS Identifier for Vendors, Media Access Control (MAC) address, and IMEI.

    In addition, Flurry may collect the following data if you select the option for Flurry to collect and provide such data to Flurry: User ID (for your service), latitude and longitude, gender, age, events, errors, and page views. However, if you are using the restricted version of Flurry Analytics, you may not select this option to collect and provide to Flurry any personal information (including, but not limited to, latitude and longitude). Finally, we see the IP address, device type, locale and timezone of the user through the HTTP request. Flurry uses this data to enable demographic and customer-created segment advertising targeting, create reports for you to analyze your End Users and to create reports and/or metrics against which you can compare your user base. In addition, unless you are using the restricted version of Flurry Analytics, we may provide you with the option of exporting raw Flurry data to your servers such as timestamp, platform, event, and user ID. You can also record errors that occur in your applications and receive an export of data containing the error information.

  • Flurry Analytics Reports:

    Your End User data collected via Flurry Analytics is presented to you to analyze your applications. In addition, unless you are using the restricted version of Flurry Analytics, aggregated and anonymous benchmark data that includes your End User data and all other Customers' End User data is provided as well. However, you (as well as other Customers) may opt-out of having End User data included in the benchmark data. End User data from applications using the restricted version of Flurry Analytics will not be included in the benchmark data and will have no access to benchmark data from the Flurry dataset.

  • Via Flurry User Acquisition Analytics:

    Flurry User Acquisition Analytics allows you to segment the clicks and installs of your applications and in-app events by the traffic acquisition sources, such as third-party ad networks, email campaigns, mobile web campaigns or any other traffic source that can support third-party URLs. In order to use Flurry User Acquisition Analytics, you must use the complete feature set version of Flurry Analytics. Flurry will use the End User's IP addresses, HTTP headers and device identifiers through this service to help you keep track of clicks, installs, and in-app events. Flurry may receive End User data from your advertising partners and transfer back such End User data to your advertising partners in connection with Flurry User Acquisition Analytics.

  • Via Flurry AppCircle:

    Flurry AppCircle is an ad network that uses Flurry Analytics in combination with a recommendation engine to create suggestions about applications or other products and services that may be of interest to particular End Users. We provide the device identifiers of the End Users who download applications or access services based on these recommendations to the applicable publisher. We also provide the timestamp of when the End User clicked on the ad and downloaded the application and may provide city level information regarding the End User's location. The device identifier, timestamp and location information may be collected by Flurry or received directly from third party real-time bidding exchange partners. You can retrieve recommendations created for particular End Users by creating a segment, and passing to the Flurry servers the device identifiers of the End Users within that segment. You may also provide Flurry with a list of device identifiers of your End Users for the purpose of Flurry serving a recommendation to those devices. If you participate in AppCircle Rewards, you can determine how many rewarded application installations or rewarded video clip views an End User has completed. You can pass the device identifier to Flurry and get back a list of times of the application installations or the video clip views. You may also get a list of device identifiers of all of your End Users who have completed an AppCircle rewards installation or rewards video clip view. We may provide reports to advertisers that include (i) the device identifiers of End Users that clicked on an ad, installed the application or viewed the video clip, (ii) the name of the publishing application associated with the click, installation or view and (iii) the time at which the click, installation or viewing of the video clip occurred.

    You may run a re-engagement campaign to try and engage End Users who have not used an application within a specific time frame. Flurry will internally identify End Users by their Flurry ID who have the application installed, but have not used the application within the specified time frame. Flurry may then show them a recommendation for such application.

    GetBanner is part of Flurry AppCircle and allows you to format a single Flurry AppCircle ad as a clickable HTML banner. This allows Customers who do not embed the Flurry SDK in their applications to make use of Flurry AppCircle ads manually. The data we collect in connection with GetBanner includes your API Access Code, the API key (identifier for application), End User device identifier, platform, landscape, banner orientation, reward message, end user IP address, theme identifier, and custom parameters. You must pass this data to us in the parameters of the application. We do not collect the data ourselves from the End User’s device. Flurry's InstallNotify API (application programming interface) allows advertisers who do not use Flurry's SDK to acquire users through the AppCircle network, and to confirm that those users converted through Flurry. For each install, advertisers send Flurry a single API call that may contain the iOS UDID, Android_ID, a hash of the MAC address, or a hash of the IMEI. These identifiers are used to determine if the install was driven through Flurry’s network. An advertiser may request a list of the identifiers of devices, install timestamps, and source (e.g., AppCircle) to confirm that they were converted via the Flurry network. Flurry's Get Recommendations API allows publishers who do not use Flurry's SDK to host Flurry ad units and monetize through an API feed. Publishers make a request to the Flurry GetRecommendations API with a call that may contain the iOS UDID, Android_ID, a hash of the MAC address, or a hash of the IMEI. These identifiers are used to determine the set of ads that will be returned to the publisher.

  • Via Flurry Real-Time Bidding Marketplace & Exchange Partners

    The Flurry Real-Time Bidding Marketplace (“Flurry RTB Service”) is an automated real-time auction service that enables media buyers to bid on and purchase inventory from publishers for the placement of advertisements, whether for themselves or on behalf of third party advertisers. The Flurry RTB Service enables media buyers to deliver ads through the Flurry RTB Service by responding to ad requests delivered through Flurry’s real-time bidding application programming interface. If you have received consent from your End Users, you may submit ad requests which may include device identifiers (including iOS Identifier for Advertising, iOS UDID, Android_ID, MAC address or IMEI), age ranges, gender, device type, OS, language, Personas, latitude and longitude, and customer key values for the purpose of selling your inventory through the Flurry RTB Marketplace. Such data may be used by media buyers to optimize their bids on impressions and focus their advertising purchases, and for retargeting ads to End Users.

  • Via Flurry AppSpot:

    Flurry AppSpot is an advertising service that allows a publisher to sell advertising space to advertisers in order to place such advertisements within their applications, including advertisements served by Flurry AppCircle. Flurry AppSpot must be used in conjunction with Flurry Analytics and may be used with Flurry AppCircle. Age ranges, gender, device type, OS, language, analytics segments created by you, Personas (as described below) and custom key values can be used by you to provide focused advertising to End Users. For example, you can create campaigns to run on your applications focusing on segments created by you within Flurry Analytics. Key values allow you to pass a specific key value pair to AppSpot as part of the ad request and then focus direct-sold campaigns or network campaigns to those values. An advertiser may request a list of the device identifiers of End Users, install timestamps, and the names of the publisher applications associated with clicks, completed views or installs. If you are showing video ad clips to End Users of your application, you may elect to pre-cache these video clips on the End User's device.

  • Via Flurry AppCloud:

    Flurry AppCloud is a collection of mobile application development services for use in building and improving mobile applications. Data provided through the Flurry AppCloud service will be stored on servers at Cloudant. Through the Flurry AppCloud service, Flurry will provide metrics on a number of items, such as how push notifications affect End User use of your application. In addition, Flurry AppCloud will allow you to access some of the Flurry Analytics metrics through the AppCloud service. Such metrics may include Personas, Customer created-segments and other anonymous application usage characteristics of the End User.

  • Personas:

    Personas are groups of End Users that share a similar interest. Flurry uses aggregated data provided by Flurry Analytics across multiple applications to build Personas. Based on an End User's application usage (session length, creation or interaction with an application event, or frequency), End Users may be classified into one or more Personas. Flurry categorizes its Customer's applications under the Personas. If an End User uses a number of applications categorized under a Persona, e.g., travel applications under a Business Traveler Persona, Flurry may place that End User within the Business Traveler Persona. Advertisers can offer ads using this Persona. In addition, Flurry Analytics will show you metrics on the different Personas. For example, you can see what percentage of your End Users are Avid Travelers and Sports Fanatics and the actual number of End Users that are in a Persona for each of your applications.

  • Customer Use of Data:

    Flurry is not responsible for any use by Customers of any data about their End Users. End Users should review the Customers' policies to understand their use of End User data.

  • Consents:

    You are responsible for obtaining all applicable End User consents to Flurry's collection and use of the End User information.

Other Uses of Personal Information

Flurry may also use personal information collected from you for the following general purposes: (1) to fulfill your requests for Flurry Services; (2) to improve our Sites and Flurry Services; (3) to contact you to resolve problems; (4) to send you information about Flurry Services including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; (5) to communicate with you about products and services offered by Flurry and our selected partners; (6) to conduct research; and (7) to make the Sites easier to use by reducing the need for you to enter information.

Cookies and Web Beacons

  • Cookies

    In order to provide you with personalized service, Flurry uses "cookies" to keep and occasionally track information about your visits to the Sites. A cookie is a small text file that is stored on a user's computer or mobile device for record-keeping purposes.

    We use both session ID cookies and persistent cookies on the Sites. We use session cookies to make it easier for you to navigate the Sites. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive or mobile device for an extended period of time. When using the Site, we set a persistent cookie to store your password if you choose "auto login", so you don't have to enter it more than once. We also store your display resolution and whether JavaScript is enabled in your browser to enhance the experience on the Sites. Most Web browsers (including mobile Web browsers) are set to accept first party cookies by default. However, some Web browsers (including mobile Web browers) are set to not accept third party cookies by default. You can typically remove or reject cookies by following directions provided in your Internet browser's help file or in the "Settings" of your mobile device. However, removing cookies may not allow you to take full advantage of all features on the Sites.

    In the case of our mobile web software agent, Flurry uses persistent cookies in conjunction with the software agent to collect the information as described in this policy and to provide our Flurry Analytics and advertising services. Flurry also uses persistent cookies to effect Flurry's mobile Web application opt-out by an End User as described below. Removing or rejecting cookies via the "Settings" on your browser may affect an End User's mobile Web application opt-out as described below.

  • Web Beacons

    We may collect information using Web beacons. Web beacons or "gifs", are electronic images that may be used on our Site, in our Services, or in our emails. We use Web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon.

Third Party Tools/Analytics on Sites

The Sites may also contain third party tracking tools from third party service providers, which may enable these third parties to analyze our Customers' information. While these third parties may have access to your personal information in connection with the performance of services for Flurry, they will not be permitted to use such information for any purpose other than providing their services.

End User Opt-Out of Flurry Services

  • For Mobile Native Applications

    Your End Users of your mobile native applications can opt out of Flurry Analytics tracking and personalized ads/recommendations from Flurry by clicking here. You must include this link in your privacy policy and/or describe Flurry's opt-out to your End Users in such a manner that they can easily find it. Your End Users can type in the device identifier and/or MAC address and select their phone type. If an End User opts out of Flurry Analytics tracking for mobile native applications, Flurry will stop tracking data for the device identified by the provided MAC address and/or device identifier going forward. The Flurry Analytics tracking of that End User's device will stop across all mobile native applications within the Flurry network. In addition, Flurry will stop providing personalized recommendations to the device identifier and/or MAC address across all native application publishers within the Flurry network.

  • For Mobile Web Applications

    Your End Users of your mobile Web applications can opt out of Flurry Analytics tracking and personalized ads/recommendations. Because a Web-based application utilizing the Flurry Analytics software agent accessed via a mobile Web browser requires the use of persistent cookies instead of device identifiers, your End Users of your mobile Web application must (a) ensure that their mobile Web browser permits the use of third party cookies, and (b) opt out of Flurry's mobile Web software agent by clicking here. If you use this mobile Web software agent, you must include this link in your privacy policy and/or describe Flurry's mobile Web opt-out to your End Users in such a manner that they can easily find it. If an End User opts out of Flurry Analytics tracking for mobile Web applications, Flurry will stop tracking data for the mobile Web browser in which the End User opted out going forward. The Flurry Analytics tracking of that End User's mobile Web browser will stop across all mobile Web applications within the Flurry network. In addition, Flurry will stop providing personalized recommendations to the mobile Web browser across all mobile Web application publishers within the Flurry network. This opt-out mechanism is effected by Flurry placing a persistent third party cookie on the End User's mobile Web browser. If your End User removes existing cookies on a particular browser, and continues to use your mobile Web application containing Flurry Analytics, the cookie that enabled the opt-out will be deleted and tracking by Flurry Analytics will resume until the End User opts out of Flurry's Mobile Web tracking again by following the instructions above.

The opt-outs described here are specific to Flurry activities and do not affect the activities of other ad networks or analytics providers that you use. An End User's opt-out of Flurry tracking in a native application is separate from an opt-out of Flurry tracking in a mobile Web application. Also, if an End User enables third party cookies on a mobile Web browser, parties other than Flurry may also place cookies for their tracking or advertising purposes.

How We Disclose or Share Information with Others

Except as described in this policy, Flurry does not rent, sell, or share personally identifiable information collected on the Sites or through the Flurry Services with other people or nonaffiliated companies unless we have your consent, or under the following circumstances:

  1. with third party vendors, consultants and other service providers who work for us and need access to your information to do that work;
  2. to comply with laws or to respond to lawful requests and legal process;
  3. to protect the rights and property of Flurry, our agents, customers, users, and others including to enforce our agreements, policies and terms of use;
  4. in an emergency to protect the personal safety of Flurry, its customers, or any person;
  5. in connection with or during negotiation of any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.

We may also share aggregated or anonymized information in a form that does not directly identify you or your End Users with any third parties.

Updating Your Information and Contact Preferences

We provide you the mechanism to review and update your information through the Sites. If you wish to review or update your information, please visit www.flurry.com and login using the user name and password you created. Next, please select "your profile," which can be found in the upper right corner of the screen. You have the ability to opt-out of receiving email communications from Flurry via your preference settings on your profile page. In addition, you can opt-out of receiving promotional emails from us by following the instructions in those emails. If you opt-out, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations.

Under California law, California residents who have an established business relationship with us may choose to opt-out of the disclosure of personal information about them to third parties for such third parties' direct marketing purposes. As detailed above, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt- out at any time after granting approval, email privacy@flurry.com.

How We Protect Your Personal Information

Flurry uses reasonable efforts to help protect your personal information against unauthorized access and unauthorized alteration, disclosure or destruction. However, we cannot guarantee that your personal information will be absolutely protected. For example, your personal information may be affected by actions outside of our control, such as computer "hacking" and physical theft. You acknowledge that you provide your personal information at your own risk.

Our Policy Regarding Children

We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register on the Sites or for the Flurry Services. If you are under 13, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal information to us. In the event that we learn that we have collected personal information from a child under age 13 we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us at privacy@flurry.com.

Our Customers may not use the Flurry Services in connection with any application labeled or described as a "Kids" or "Children" application and may not use the Flurry Services a) in connection with any application, advertisement or service directed towards children or b) to collect any personal information from children.

Notwithstanding the foregoing, you may use the restricted version of Flurry Analytics in connection with an application labeled or described as a "Kids" or "Children" application or in connection with an application or service directed towards children.

International Transfer

We may, in the process of providing services to you, transfer information that we collect about you or your End Users, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you or your End Users are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information and permitting the transfer of information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you and your End Users, including personal information, as described in this Privacy Policy.

Changes to this Privacy Policy

We may change this Privacy Policy at any time. We will post all changes to this Privacy Policy on this page and will indicate at the top of the page the modified policy's effective date.

Contact Us

If you have any questions or suggestions regarding this Privacy Policy, please contact us at privacy@flurry.com.

Flurry, Inc., 360 3rd St. Ste. 750, San Francisco, CA 94107