Legal
Privacy Policy
This Privacy Policy ("Privacy Policy") is posted by Influence Mobile, Inc. ("Influence Mobile" or "we" or "us"), registered at 1916 Pike Place, Suite 12 #1363, Seattle, WA 98101. The Privacy Policy describes how and when we may collect, use, secure, store, share and otherwise "process" information collected in connection with our mobile apps ("App(s)"), websites, content, products, any type of digital destination we may operate and any related services (collectively the "Services"), and your choices regarding that information.
As used herein, the term "App(s)" refers collectively to any application where this Privacy Policy is posted, including without limitation Rewarded Play. Likewise, the "websites" referenced above include any website where this Privacy Policy is posted, including without limitation influencemobile.com. As used herein, "Affiliates" refers collectively to Influence Mobile Exchangeco Inc., Influence Mobile Canada Inc., and Blind Ferret Entertainment Inc.
This Privacy Policy is incorporated into and forms a part of the Influence Mobile Terms of Use, which constitutes a binding agreement between you and Influence Mobile. Please read this Privacy Policy carefully. We may update it from time to time by posting a new version with an updated date. If we make material changes, we will notify you, prior to the changes becoming effective, through the Services.
Information we may collect and how we collect it
We may collect various types of information, including information you provide or make available to us directly, information collected from your devices (including web and mobile), and information collected from other sources, like social networking sites and gaming partners.
Some of this information may be considered "personal information" or "personal data" under applicable privacy or data protection laws. As used herein, these terms generally refer to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with a particular data subject, consumer, or household.
Information you provide
You may provide personal information directly to Influence Mobile when you:
- Use or access the Services;
- Communicate with or contact others using our Services, including when you use "invite a friend" or other similar features;
- Contact us, including in writing or by telephone for customer or technical support; or
- Complete surveys offered by us or on our behalf.
In order to register an account, you must provide us with a first and last name and a phone number. Depending on how you choose to use the Services, you may also provide us with your email address, home or shipping address, and other contact information; and your age, date of birth, and gender.
If you opt in to one of our surveys (currently available to users in the US), you may choose to provide us with information about your health; race and ethnicity; employment; education; household; and/or shopping habits.
Information collected or generated when you use our Services
When you access or use our Services, we collect information from and about you and the device(s) you use. This may include:
- IP address, unique device identifiers (Device IDs), advertising identifiers (Ad IDs), device serial numbers, and similar identifiers;
- Hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, mobile network information, and in some cases browser type, Internet service provider, referring/exit pages and URLs, or clickstream data;
- App activity data, including which third-party apps you have installed and data related to the use of third-party apps installed via our Services;
- Approximate geolocation data and zip/postal code (inferred from your IP address, using publicly available data);
- Scores and achievements, points accrued, and other information as reasonably required to offer and enhance our Services; and/or
- Crash logs, diagnostics, and other app performance data.
When contacting our customer support you may be asked to provide photos, videos, voice or sound recordings to assist in troubleshooting technical issues. In that case, you give us permission to read your mobile phone's external storage.
Information collected using cookies and similar technologies
We may use cookies, beacons, software development kits, mobile analytics software, and/or similar technologies (which we refer to under the general term "cookies") for a number of purposes, including to authenticate users, prevent fraud, remember preferences and settings, analyze advertising and messaging campaigns, analyze traffic and trends, personalize content (including ads), and otherwise provide the Services.
Depending on the choices and settings available for the browser(s) you use, you may be able to disable cookies in your browser settings. Additionally, depending on your location, we may be required to seek your consent before cookies can be used, in which case we will present you with consent options when you access the Services. If you disable cookies or refuse consent, the availability and functionality of our Services may be impacted.
Information collected from other sources
We may also collect information about your approximate location (including your zip/postal code, which we infer from your IP address) from other sources, including from our third-party partners or service providers and publicly available sources. We may also receive feedback from other players or social networking sites. We may combine this information with other information in our possession, which helps us to update, enhance, and analyze our Services, and provide tailored experiences for you.
How we use information
We may use the information we collect for a number of business and commercial purposes, including to:
- Internal operations: develop, provide, maintain, and improve our Services, including troubleshooting, customer and technical support, and data analysis, testing, and research.
- Business model: support our business model, which requires us to track third-party app installations (conversions).
- Core in-app Services: award points and rewards to users based on their active usage of our third-party partner applications and enable in-app gift card redemption.
- Personalization: understand how you interact with our Services and personalize the product experience and content, including tailoring third-party app recommendations based on your location, gender and age, and operating system.
- Security and integrity: maintain the safety, security, and integrity of our Services and monitor compliance with our Terms of Use.
- Facilitation of social connections: facilitate your communication with friends and other users, and enable sharing features.
- Legal: comply with legal requirements and/or investigate or address claims or disputes relating to your use of the Services.
- Marketing: market our Services to potential and existing users, including in-app messaging, SMS, text, and push notifications.
How we share information
We may share the information we collect about you with a variety of third parties in various ways, including:
- With vendors, business partners, and other third-party service providers as necessary to carry out work on our behalf, including IT infrastructure and software, professional services (such as legal, tax and accounting), marketing or promotional strategy, and analytics tools;
- With our game-developer business partners, to establish appropriate conversion rates based on your app installations;
- With other players, to enable you to interact with them, including via "invite a friend" features and App-related data such as gift card wins and leaderboard information;
- With the general public, if you choose to share information when contributing content through a forum, blog, or social feature;
- With others who share your device, if you make your account available to them through that device;
- With specific third parties if we believe disclosure is required by applicable law, regulation, or legal process;
- With law enforcement officials or government authorities if we believe your actions are inconsistent with our terms, are fraudulent, or violate applicable law;
- In connection with a merger, consolidation, restructuring, sale of company stock and/or assets or other corporate change; and/or
- In an aggregated form or otherwise in a form that cannot reasonably be used to identify you.
In some cases, we may enable you to access third-party products or services through our Services. Those products or services are offered by people or companies not affiliated with or controlled by us, and we are not responsible for their actions, terms, use of information, or products or services. If you submit your information to a third party, that third party's treatment of your information is governed by their privacy policy, which we encourage you to review.
User verification
We use a third-party user verification service provider (Teemo Technology LTD dba ComplyCube) to handle user verification for our Services. You may be prompted to provide certain information to ComplyCube in order for us to verify that you are a legitimate user of our Services. ComplyCube's use of your personal information is governed by its own privacy policy, which may or may not contain privacy protections as protective as this Privacy Policy.
Interest-based advertising
We may work with third-party advertising partners in the event that we serve third-party advertisements within our Services. In such case, we may share information about you (including your approximate location, advertising identifiers, gender and age) with these partners to make advertising more relevant, measure its effectiveness, and help recognize your devices and serve ads.
If you prefer to opt out of having your information used for interest-based advertising, you can learn how via the Network Advertising Initiative, or if located in the EEA, UK, or Switzerland, via Your Online Choices. You may also opt out through your device settings ("Limit Ad Tracking" on iOS and "Opt Out of Ads Personalization" on Android). If you opt out, you may continue to receive generic ads that are not based on your preferences.
Your rights and choices
You can access and modify any personal and other information that is made available to you in your account or otherwise through functionality within our apps. You can manage your information as described below by contacting us, and you may also have additional rights related to that information as described elsewhere in this Privacy Policy.
Accessing, updating, or correcting your data
You are expected to maintain accurate, complete, and up-to-date information in connection with your account, and we provide you functionality to update or correct that information directly in-app.
Deleting your data
We offer you the ability to request deletion of personal information we have collected and stored about you, subject to our Data Retention policy described below. If you would like to have your personal information deleted, please contact us at 888-973-0809 or via our contact page. We will respond to your request consistent with applicable law. If you request deletion of your personal information, you may no longer be able to use or access the Services, and if you share devices with someone else who uses the Services, that person may lose their progress or related account information and access.
Communication preferences
Email, phone, and text: We may contact you (for customer support or user authentication purposes) at the email address(es) or phone number(s) provided in connection with your account. You may opt out of these messages by following the unsubscribe instructions in the message (e.g., by tapping an unsubscribe link or replying "STOP").
Push: In connection with certain Services, you may choose to opt in to receiving push notifications. If you no longer want to receive them, you can turn them off at the device level.
Cookies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you remove or reject cookies (or fail to consent to their use), this could affect the availability and functionality of our Services.
Other rights
In some cases, particularly if you are a resident of the EEA, the United Kingdom, or Switzerland, or if you are a resident of the State of California, you may have additional rights with respect to your personal data or personal information as defined under applicable laws. For more information on these rights, please refer to the additional disclosures below.
Data retention
We may retain personal information where required by law or where we have an ongoing legitimate business need to do so, for example, to provide you a service you have requested, to comply with applicable legal, tax or accounting requirements, or where necessary for fraud prevention, dispute resolution, enforcement of our contracts and terms, or for safety reasons.
To protect your privacy, if you are not an active user of any of the Influence Mobile products, within six months of your last activity we delete information that is not necessary to display your App usage history, such as your location and profile information.
Security
We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession, and only those at Influence Mobile with a legitimate business need to access your personal information are permitted to do so. We also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us.
Use by minors
We do not knowingly collect or process personal data from or about, or direct or target interest-based advertising to, anyone under the age of 16, nor do we knowingly allow such individuals to use our Services. If you believe we might have any data from or about a child under this age, please contact us. If we learn that we have inadvertently gathered such information, we will delete it.
Information for individuals in Canada
Your personal data is maintained on our servers or those of our service providers and will be accessible by authorized employees, agents and representatives who require access for the purposes described in this policy. You may request access to or correction of the personal data in our custody or control by contacting us as set forth in the "Contact Us" section. Your right to access and correct personal data is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before providing access or making corrections.
Additional information for persons located in the EEA, United Kingdom, and Switzerland
The following sections provide additional disclosures and describe the rights available to individuals located in the European Economic Area ("EEA"), the United Kingdom, and Switzerland.
Location of data processing and data transfers
Influence Mobile is a global business headquartered in the United States. When you provide personal data to us or when we otherwise collect or obtain your personal data, we process it in the United States or such other jurisdictions in which we utilize third-party service providers. The laws governing our processing of personal data in such jurisdictions may differ from those in the jurisdictions in which you are located.
With respect to personal data originating in the EEA, UK or Switzerland, we will only transfer it in or to a country that provides an adequate level of protection or by implementing appropriate safeguards, including through the use of standard contractual clauses or another lawful transfer mechanism approved by the European Commission and/or the UK or Swiss authorities (as applicable).
Rights and choices available to persons in the EEA, UK or Switzerland
If you are located in a member country of the EEA, the UK, or Switzerland, you may have the following rights with respect to any information about you that constitutes "personal data":
- Access your personal data: obtain confirmation regarding whether we process your personal data and a copy of the personal data we have collected about you.
- Rectify or correct your personal data where it contains inaccuracies.
- Request erasure (deletion) of your personal data in certain cases, for example when it is no longer necessary to fulfill the purposes for which we collected it.
- Restrict or object to processing of your personal data in certain cases.
- Request a portable copy of your personal data in a structured, commonly used and machine-readable format.
To protect the privacy of your information, Influence Mobile verifies your identity and processes all rights requests through our customer support system. If you wish to exercise any of the rights described above, please contact us at 888-973-0809 or via our contact page. You may also have the right to file a complaint with a data protection authority about our collection and use of your personal data.
Legal basis for processing personal data
If you are from the EEA, the UK, or Switzerland, our legal basis for processing your personal data will depend on the type of information, the context in which we collect it, and the purpose for which we process it. In general, we process your personal data only where we need it to perform a contract with you, or where it is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.
| Purpose of processing | Legal basis |
|---|---|
| Internal operations | Legitimate interests (proper management of our business and success of our Services); Contract (fulfillment of our contract with you) |
| Business model | Legitimate interests (tracking user conversion rates and being remunerated by our business partners, which is core to our business model) |
| Core in-app Services | Legitimate interests (providing quality Services); Consent (where necessary, for tracking third-party app usage) |
| Personalization | Legitimate interests (more engaging Services); Consent (where necessary) |
| Security and integrity | Legitimate interests (keeping our Services secure and ensuring compliance with our Terms of Use) |
| Facilitation of social connections | Legitimate interests (sharing functionality to grow our user base and enhance experiences) |
| Legal | Compliance with a legal obligation; Legitimate interests (complying with applicable laws) |
| Marketing | Legitimate interests (promoting our Services); Consent (where necessary) |
We have appointed DataRep as our data protection representative in the UK and EU; you can contact them directly in your home country. If you choose to mail DataRep, please mark your letters to "DataRep" and not "Influence Mobile," and refer clearly to Influence Mobile in your correspondence.
Points of contact
Data Controller: Influence Mobile, Inc., for general inquiries, please use our contact page.
EU Representative (DataRep): 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany; and 72 rue de Lessard, Rouen, 76100, France.
UK Representative (DataRep): 107–111 Fleet Street, London, EC4A 2AB, United Kingdom.
Additional information for residents of California, Virginia, Connecticut, Utah, or Colorado
Influence Mobile is providing the following details regarding the categories of Personal Information about California, Virginia, Connecticut, Utah, or Colorado residents that we have collected (online and offline) or disclosed within the preceding 12 months. This notice does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information relates to their role with us.
We collected the following categories of Personal Information:
- Identifiers: name, alias, postal address, unique personal identifiers, online identifier, IP address, email address, account name, device information, or other similar identifiers;
- Customer records information: name, physical characteristics or description (i.e., gender), address, telephone number or network;
- Protected classifications under California or federal law: gender identity, gender expression, age;
- Commercial information: products or services purchased, obtained, or considered, or other purchasing histories or tendencies;
- Internet or other electronic network activity: browsing history, search history, and interaction with a website, application, or advertisement;
- Geolocation data; and
- Inferences drawn from any of the above to create a profile about an individual's preferences and characteristics.
We collect this Personal Information from you as well as from our joint marketing partners, and use it to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes, including fulfilling your requests; developing and improving our services; personalizing, advertising, and marketing; conducting research and analytics; security and fraud prevention; accounting and internal functions; corporate transactions; and compliance with law.
We disclosed these categories of Personal Information to our Affiliates and trusted third-party service providers for operational business purposes.
We do not "sell" your Personal Information for money. However, our delivery of research results to our clients in exchange for a fee may constitute a "sale" under the CCPA, or in other states like Virginia may qualify as "targeted advertising" (collectively, "personalized advertising"). To opt out of the "sale" of your personal information, please visit our Personal Information page.
If you are a California, Virginia, Connecticut, Utah, or Colorado resident, you may request that we disclose the categories and specific pieces of Personal Information we collected about you (covering the preceding 12 months), the sources and business purposes, and the categories of third parties to whom we sold or disclosed it; delete Personal Information we collected from you; and no longer "sell" your information. California consumers also have the right to correct inaccurate personal information, to limit the use and disclosure of sensitive personal information, and to non-discrimination for exercising these rights.
To make a request for the disclosures or deletion described above, please contact us at 888-973-0809 or via our contact page. California residents may also designate an authorized agent to make a request on their behalf.
Contact us
If you have questions or concerns about this Privacy Policy or our data practices, please contact us at 888-973-0809 or via our contact page. You may also mail us at Influence Mobile, 1916 Pike Place Ste 12 #1363, Seattle, WA 98101. We will respond to your request consistent with applicable law.