Privacy Policy

Onaffi Media is an affiliate advertising company that provides advertisers with a platform to deliver more targeted advertising to their consumers. Our technology enables our partners to show there service/offers to users more relevant advertising that is based on users’ interests and behaviors. In order to provide these services, we collect and use certain information about user activity and preferences.

Onaffi recognizes the importance of consumer privacy and we take this issue very seriously. To this end, we have designed the Onaffi Privacy Policy (this “Policy”) in a format that is easy to navigate and read so that you can clearly understand our privacy practices. We are committed to treating your personal information with care and respect.

Effective Date: August 30, 2016

This Policy describes the treatment of information provided or collected on or through (i) our website, which is currently located at www.onaffi.com (the “Site”); (ii) the network of application publishers and publishers; and (iii) our other online services.

The Policy covers the following topics:

  1. Types of Information We Collect
  2. Information We Collect From Business Partners
  3. Information We Collect From Consumers
  4. How We Collect Information
  5. Use of Your Information by Onaffi
  6. Sharing Your Information with Other Companies
  7. Your Choices and Controls
  8. Data Security, Integrity and Retention

If you have any questions about this Policy or our privacy practices, please do not hesitate to Contact Us.

1. Types of Information We Collect

We collect two main types of information through the Services - personal information and anonymous information and we may also generate a third type of information, aggregate information, as set forth in more detail below. Descriptions of these terms are available in the Definitions section of the Policy.

Please note that we may collect different categories of personal, anonymous and aggregate information from you depending on the nature of your interaction with the Services.

2. Information We Collect From Business Partners

If you are one of our Business Partner, we may collect the following categories of information from you:

  • Registration information that you provide when you create an Onaffi account. For example, in order to register for the Services we require all Business Partners to create a username and password, and provide us with basic contact information (such as Name, email address, Contact number and company name).
  • Transaction information that you provide when you request information from Onaffi, submit a payment to us in connection with your use of the Services, or receive a payment from us in connection with your use of the Services. Examples of transaction information may include basic contact information, bank or financial account information, credit card or debit card numbers and similar details required to process your payments or respond to your request.
  • Technical, viewing and usage information that relates to your interaction with the Site, such as your physical location, the unique identifier or Internet Protocol address (“IP Address”) of the device that you use to access the Site and the amount of time you spend viewing certain portions of the Site.

3. Information We Collect From Consumers

If you are a Consumer that uses an Onaffi Platform or otherwise interacts with the Services, we may collect the device information identified below so that we can provide our services. We may collect and transmit such device information as either raw or hashed data, depending on the sensitivity of the information in question. Onaffi does not automatically collect any personal information directly from Consumers but may obtain such personal information from its Business Partners in connection with the Services or when Consumers submit such personal information to Onaffi via the Site.

Raw Data.

The SDK may collect and transfer non-sensitive device information as raw data, such as:

  • Generic geographic location, such as the city you are located in;
  • Carrier;
  • Device make and manufacturer;
  • Operating System;
  • Name of application through which a Consumer interacts with the Services;
  • Language settings;
  • Connection speed;
  • IP Address;
  • Internet browser used to access the Services; and
  • Identifier for advertisers (IDFA).

For additional information regarding the steps we take to safeguard your information, please refer to the Data Security, Integrity and Retention section of the Policy.

4. How We Collect Information

Depending on the nature of your interaction with the Services, Onaffi may collect information from you automatically and/or when you voluntarily choose to provide us with information. We may also acquire information from other trusted sources to update or supplement the information that you voluntarily provide to us or that we collect automatically.

Business Partners.

If you are a visitor to the Site or a Business Partner, we collect information that you voluntarily provide us during your interaction with the Services. For example, you may choose to provide Onaffi with information when you directly request information or services from us, submit or receive a payment, or complete the online forms available on the Site.

We may also collect certain types of information automatically, including through the use of Cookies, Web Beacons and other similar tracking technologies. These tracking technologies allow Onaffi to personalize your experience with the Services and keep track of certain online behavior in order to help us determine the things that you find most interesting.

Consumers.

Onaffi primarily collects information from Consumers when an application Advertiser or Publisher requests Onaffi to serve an advertisement to a consumer. By downloading and using a partner Application, you grant the application Advertiser with permission to collect device information and share it with Onaffi. Onaffi may track this information over time and across multiple sources) in order to deliver advertisements through the Services. In addition, Onaffi may collect information from Consumers through use of a Cookie, Web Beacon, Scripts or similar tracking technologies if the Consumer accesses advertisements from a browser or is redirected to a browser by advertisements provided through the Services. Certain advertisements may redirect you to a browser where Onaffi may use a Cookie to track Consumer activities.

5. Use of Your Information by Onaffi

Onaffi uses the information we collect about you to provide the Services and to gain a better understanding of the products and services that may interest you. For example, we may use your information in order to:

  • Operate, manage and improve the Services;
  • Respond to your inquiries;
  • Provide you with requested services;
  • Communicate with you about your Onaffi account, your interactions with the Services or your contacts’ interactions with the Services;
  • Protect the rights or property of Onaffi or third parties; and
  • Deliver targeted advertisements on behalf of our Business Partners. You may opt-out of receiving such targeted advertisements as set forth below.

Onaffi may process and/or store personal information.

For additional information regarding choices you may have with respect to our use of your information, please refer to the Your Choices and Controls section of the Policy.

The Services may link to third party websites or other third party content. Please note that Onaffi cannot control the treatment of your information by such third parties, and that the privacy practices of third parties likely differ from those described in the Policy.

6. Sharing Your Information With Other Companies

Onaffi will not share your personal information with other companies, except under the following limited circumstances:

  • Authorized Disclosures:

    We may disclose your personal information to third parties when you consent to a particular disclosure of your personal information. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices.
  • Compelled Disclosures:

    On rare occasions, we may share your personal information when compelled to do so by government authorities or as otherwise required or permitted by applicable laws and regulations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). Onaffi may also share your personal information with third parties if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Onaffi Terms of Use, or to protect the rights, property or safety of third parties.
  • Agents / Service Providers:

    Onaffi may disclose personal information to our trusted agents and service providers so that they can perform requested services on our behalf. For example, we may share payment information with a third party service provider in order to assist us with processing credit card payments. These entities are prohibited from using your personal information for any purposes other than providing Onaffi with requested services.
  • Business Transfers:

    In the event that Onaffi is (or substantially all of its assets are) acquired by a third party pursuant to an acquisition, merger, sale, reorganization, liquidation or similar business transfer, the personal information stored in our databases may be one of the transferred assets.
  • Non-Personal Information:

    Onaffi may share aggregate or anonymous information with Business Partners and other third parties in accordance with the terms of this Policy.

7. Your Choices and Controls

Onaffi provides you with the ability to exercise certain choices and controls in connection with our treatment of your information. Depending on your relationship with Onaffi, these choices and controls may include:

  • Requesting access to the personal information about you that we hold;
  • Correcting, updating or deleting the information associated with your Onaffi account;
  • Opting-out of targeted advertising delivered by Onaffi.

If you would like additional information about the choices and controls that may be available to you, or you would like to access your personal information, please contact us.

8. Data Security, Integrity and Retention

Your privacy is very important to Onaffi and we are committed to protecting your personal information from unauthorized access, use or disclosure. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft.

In addition, we take steps to ensure that information is stored in an anonymous format through a technique known as “hashing”. When a Consumer downloads and uses an App or website that requests Onaffi to serve advertisements, we may collect and process information locally on the Consumer’s mobile device. This allows us to identify the sensitivity level of certain device information prior to transferring it to our servers for storage. Rather than sending sensitive device information as raw data that can be easily associated with the relevant Consumer, we only transfers anonymous hashed representations of certain types of information back to Onaffi. Our servers then associate the hashed representations with a unique anonymous identifier assigned to each Consumer by Onaffi. When a Consumer subsequently interacts with the Services, this process allows us targeted advertising without storing any sensitive information in a form that would be easily readable to unauthorized third parties.

Onaffi also protects Consumer privacy by seeking to minimize the amount of sensitive data that we store on our servers in the first place. You may also contact us anytime with your questions or concerns.

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