Last Updated: 1 January 2020
Ogury Limited (“Ogury”, “we” or “us”) cares about its users’ privacy and is committed to clearly describing and disclosing its data practices.
Last Updated: 1 January 2020
Ogury Limited (“Ogury”, “we” or “us”) cares about its users’ privacy and is committed to clearly describing and disclosing its data practices.
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 manage your consent choices and show ads which are placed by advertisers and advertising agencies (together “Partner(s)”). We use this software code, together with tracking cookies, pixels and similar technologies (“Ogury Technologies”) to provide Ogury’s products for Publishers including Active Insights, Choice Manager and Intelligent Monetization and User Engagement – in this Privacy Statement, we call these solutions the “Ogury Product”.
After receiving user consent, Ogury collects certain data ("User Data") relating to the user of the tablet, mobile or handheld device (“Device”) on using the Ogury Technologies. We may also supplement User Data obtained via Ogury Technologies with further data relating to Users obtained from other companies that share User Data with us. 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 Technologies.
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.
California residents can find details about their rights and how we comply with the California Consumer Privacy Act (CCPA) here.
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.
Ogury collects User Data through the Ogury Technologies as well as obtaining additional data from third parties, however, we do this only where Users have consented to this collection. The User Data we collect comprises the following categories of information:
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/URLs Users have visited and information related to these URLs.
What applications are installed on the Users’ Device.
Users’ usage levels of these applications.
The Usage Data collected by the Ogury Technologies is not limited to Usage Data that directly relates to the App in which the Ogury Technologies are integrated. Rather, the Ogury Technologies collect Usage Data from all applications and systems on the Device on which an App is installed.
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 Technologies used by the App.
A User’s network status (limited to connection type; gsm, 3G, 4G/wifi etc).
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 anonymise the email addresses after 3 days).
your Device’s unique Advertising ID, such as Google AAID or Apple IDFA.
All User Data we collect is associated with these Identifiers.
Cross Device Linking
We also collect and infer data (either ourselves or from other companies) about the links between different Devices, such as a mobile phone and tablet, where we believe they are being used by single User. We do this using of cookies, Advertising IDs and other User Data we collect.
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 an App or elsewhere.
User interaction with the Ad (for example, clicks and how long the Ad was displayed for).
User interaction with Partner sites after clicking on an Ogury ad.
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 Technologies and 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.
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.
In simple terms – User Data is used by Ogury and its Partners to (i) manage your privacy choices relating to Ogury, Publishers and Partners use of User Data; (ii) link your Devices and browsers; and (iii) select and serve to Users adverts 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.
We also use User Data to analyse the performance of Ogury ads and how Users interact with them and Partners’ websites, 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.
User Data is also used 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 Technologies and Products 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 and other suppliers properly for the Ogury ads displayed in their Apps or websites; and
security and fraud detection (e.g. protecting against click-fraud and similar unlawful activities).
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 Interest-based Advertising”.
Accordingly, when Users use a version of an App which contains the Ogury Technologies, a page is displayed which notifies them that, with their consent, certain User Data will be collected by the Ogury Technologies 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/
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.
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 advertisers
We may share User Data with Publishers and Partners to aid in their understanding of how Users are using Apps and engaging with Ogury ads.
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.
We may share User Data with the service providers who perform services on our behalf, such as providers of analytics, fraud detection services, payment processing, product fulfilment, technical infrastructure, data services, engineering and other technical support, and email and customer support.
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.
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.
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.
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.
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: here; 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.
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 email@example.com
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.
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 firstname.lastname@example.org. We will ask for their email address and other contact information so that they can receive a response.
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.
The following section of our Product Privacy Statement sets out the rights of California residents under the California Consumer Privacy Act of 2018 (CCPA) and how Ogury will comply with the requirements of the CCPA.
Right to Know
You have the right to
know the categories of personal information Ogury has collected about you, the source of the information, and how and what information was used, disclosed or sold, and
request a copy of the specific personal information Ogury collected about you during the last 12 months.
In order to exercise your right to know you will need to provide us with your device ID (either Android Advertising ID (AAID) or Apple ID for Advertisers (IDFA)) which will allow us to locate your personal information. For help finding your AAID or IDFA please see the section Opting Out of Ogury Interest-based Ads above or contact us using one of the methods below.
We may ask you for additional information to verify that your request is legitimate, and you will be required to provide a signed declaration confirming you are the consumer to which the personal information relates.
You may exercise your right to know by
If you contact us via telephone you must also provide a contact email address for future correspondence and the provision of your personal information.
We will acknowledge receipt of your request within 10 days, informing you of how we will process your request. We will fulfil your request within 45 days of receipt. If we need more time to comply, we will inform you that your request will be delayed by a maximum of an additional 45 days.
Sale and Disclosure of your Personal Information
Ogury does not sell your personal information and has not done so in the last 12 months.
We treat you as having instructed us not to sell your personal information. If you wish to withdraw your consent to Ogury using your personal information and transferring it to any third parties completely you may do so here.
We disclose and have disclosed in the past 12 months, personal information to service providers or third parties that you have consented to us sharing it with. This personal information includes the following
Online Identifiers such as AAID and IDFA;
Information regarding your interaction with Ads; and
Approximate Geolocation data.
Requests for Deletion
You have the right to have the Personal Information Ogury has collected regarding you be deleted.
In order to exercise your right to deletion of your personal information you will need to provide us with your device ID (either Android Advertising ID (AAID) or Apple ID for Advertisers (IDFA)). This will enable us to identify you and verify your request. For help finding your AAID or IDFA please see the section Opting Out of Ogury Interest-based Ads above or contact us using one of the methods below.
You may exercise your right to request deletion of your personal information by
If you submit your request online your data will be deleted automatically within 24 hours. If you submit your request by any other means we will acknowledge receipt of your request within 10 days, informing you of how we will process your request. We will fulfil your request within 45 days of receipt. If we need more time to comply, we will inform you that your request will be delayed by a maximum of an additional 45 days.
Right to Non-Discrimination
You have the right not to receive discriminatory treatment by Ogury for the exercise of the rights conferred on you by the CCPA.
You may nominate an authorized agent (registered with the California Secretary of State) to exercise your rights on your behalf. If you choose to do so we will need to obtain from you a signed declaration that you are the consumer to which the information relates and written proof that the authorized agent is entitled to act on your behalf. We will also need you to verify your identity directly with us.
CCPA came into force on 1 January 2020. We will provide metrics regarding the exercise of rights conferred on consumers by CCPA in January 2021.
Categories of Personal Information Collected
Please see the section What is User Data? above.
How we collect your Personal Information
Please see the section What is User Data? above.
What we used your personal information for
Please see the section How is User Data used? above.
If you have any questions about your rights under CCPA please contact us at email@example.com.
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.
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 3rd Floor, Classic House, 174-180 Old Street, London EC1V 9BP.