EFFECTIVE: AUGUST 2022

INTRODUCTION

Think Digital runs a marketing platform solution which provides advertising and monetization services/products (whether owned or through its partners) to marketers and supply partners including through digital media, sites, surveys, owned or operated application(s)/widgets, exchange(s) for demand/supply, marketing automation solutions and other services, such as, fraud detection, reporting, audiences, attribution, analytics, modelling, segments, measurement (“Marketing Platform”).

2. SCOPE OF THIS PRIVACY POLICY

2.1 APPLICABILITY

This Privacy Policy explains how Think Digital collects, uses and shares information from individuals that interact with its services, offering or platforms comprising its Marketing Platform (“Marketing Platform Services”) and its website, respectively. (“Think Digital” means Think Digital Pte. Ltd. and its subsidiaries). Think Digital is the controller for the personal information we process, unless otherwise stated.

2.2 NON-APPLICABILITY

Think Digital may offer independent mobile applications, web content services, lock-screen platforms, social entertainment platform(s), widgets, and/or other software features to consumers through smart devices which may be preloaded on the devices, downloadable, hosted on web or made available through other digital media (“Consumer Offering”). This Privacy Policy does not apply to the collection by or processing practices of each of the foregoing services, respectively. If you are a consumer of any such Consumer Offering, the applicable privacy policy should be available to you through such services. Please refer to the respective privacy policies of each Consumer Offering for a description of its data collection and data use practices.

To the extent that foregoing Consumer Offering promotes any interest-based advertising using the Marketing Platform Services, the terms of this policy would apply to the data processing practices for such Marketing Platform Services. Marketing Platform Services and Consumer Offering are collectively referred to as “Services”.

3. THINK DIGITAL MARKETING PLATFORM SERVICES

Think Digital engages with third party site/app publishers and app developers to serve ads on their digital properties on behalf of its demand side advertising partners through various channels of advertising solutions including exchanges, network, off-network etc. Think Digital may also serve ads on Consumer Offerings. Think Digital also engages in campaign planning, measurement (e.g. whether an advertisement was viewed, its timestamp etc.) and attribution of advertisements, whether by itself or through third party measurement partners.

Think Digital provides Marketing Platform Services, including optimization of advertising campaigns, data analytics/enrichment, segment creation, user acquisition, re-engagement, remarketing or retargeting through various digital advertising channels. Think Digital receives data into its Marketing Platform from various sources, including end user information collected by our systems, applications/offerings, partners, data/cookie vendors or customers (“Sources”), which may include third party apps, sites and services that you use. Please refer to the privacy policies of the apps, sites, and services you use to understand how those apps, sites and services collect, use, and share data from your interactions with them. Think Digital is not responsible for how those third-party apps, sites and services collect and use data.

4. WHAT PERSONAL INFORMATION DO WE COLLECT?

When you view an advertisement distributed through Think Digital on a site, app or other digital media, we may collect information on your device and your interaction with the advertisement. This information enables us to serve advertisements to you, improve our Services including to recognize your device when you use other sites and applications that have partnered with us. Think Digital may also collect information about you when you elect to interact with our surveys or opinion-based applications. Information we may collect includes:

  1. Device identifiers. Device identifiers are alphanumeric strings that are unique to your device. These include:
    • iOS devices’ Identifier for Advertising (IDFA) and iOS Identifier for Vendors (IDFV)
    • Google Advertising ID (GAID), or Android ID for Android devices
    • Identifier for Advertising on OTT and CTV platforms
    • International mobile equipment identity (IMEI), in certain jurisdiction as permitted by applicable law
    • Cookie IDs
  2. Location information, including:
    • Geo-location or precise location of your device if you have given the app or site permission to collect your location information.
    • Location information we infer based on data collected through a WiFi identifier that your device is connected to, in accordance with applicable law and provided location access is permitted.
    • Location Information we infer from your device’s IP address, provided that we will not infer location from an IP address to a more precise than city-level of accuracy unless you have given the app or site permission to collect your location information.
  3. Network information, including:
    • Mobile carrier
    • Network provider or ISP
    • Network type (e.g., WiFi or cellular)
    • IP address
    • IDs of WiFi access points to which your device is connected
    • Date and time of connection
  4. Information about apps or sites and our Software Development Kit (SDK), including:
    • App or site name or version
    • App identifier
    • SDK version
    • API key identifier
  5. Other information about/on your device, including:
    • Device startup time and update time
    • Device name
    • Screen size
    • Memory and hard drive capacity
    • Operating system and version (e.g., iOS 14, Android, Windows, Blackberry)
    • Mobile browser used (e.g., Chrome, Safari, Firefox)
    • Language settings (including country code) and time zone
    • App usage
  6. Advertisement information. We collect information about the ad presented on your device, including:
    • The content type of the ad (the advertiser and category, e.g. games, finance, entertainment, news)
    • The ad type (e.g. whether the ad is a text, image, video or other format based)
    • Where the ad is being served (e.g. the site, digital media or app on which the ad appears)
    • Whether you viewed, clicked or otherwise interacted with the ad
  7. Survey information. We may ask users to voluntarily participate in online surveys. These surveys help brands improve their products and services offered to you. If you fill out a survey, we may collect your device information described above and information you provide, including your:
    • Age
    • Name
    • Email Address
    • Phone Number
    • Gender
    • Occupation and income range
    • Family size and other demographic information
    • Preference for brands, modes of travel, and other consumer choices.
  8. Other marketing information:

    In the context of our Marketing Platform Services, our customers, partners or vendors may also disclose to us certain personal or non-personal information they have separately collected about you during your interaction with their apps, sites or services so that we can effectively provide our Services. This may in the context of websites, including mobile websites, include cookies, other technologies, or other aggregated characteristics or other identifiers related to your device to understand your interaction with such site and to serve certain types of ads relevant to your interests.

    These parties serve you cookies in accordance with their own specific privacy/cookie policies and subject to their own applicable legal requirements. We do not use the information they provide to us for any purpose other than as permitted by such third parties or for providing or improving our Services. Notably, one of our media partners is Google. Please see the link below which describes Google's collection/use of data:

  9. How Google uses data when you use our partners' sites or apps

    We do not collect any sensitive data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric data, data concerning health. We may show targeted advertisements to fitness enthusiasts.

5. HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the information that we collect about your device to:

• Display advertisements on your device, which may include interest-based advertising customized to your interests, preferences, locations.
• For remarketing or retargeting i.e. to display relevant ads if you have previously visited/accessed/downloaded a site or mobile application that we partner with.
• For bidding to serve advertisements and to determine which ads are most effective.
• Analyze and provide our demand partners or advertisers reports on the effectiveness of advertisements and campaigns, including across different types of devices based on our determination of devices that are related to the same person. We, or third parties whom we engage to provide this service, may use cross-device data to provide interest-based advertising services and to deliver tailored ads to users across multiple mobile devices including over the top applications and smart televisions.
• Avoid showing you the same ads too many times.
• Build custom audience segments to enable our customers and partners better target their advertisements and offers.
• Improve our Services and assist our customers and partners in improving their products and services.
• Detect, deter and prevent fraud, fraudulent traffic or to protect the security of our systems.
• We may process your survey responses and share the response data with the brands who are our customers/marketers.

6. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

Think Digital may share the information we collect or receive about you as described in this Policy as follows: • Publishers and Supply Partners. We may share your information with publishers (the app or site publishers) to help them understand how users interact with their apps and sites and advertisements on their apps and sites.
• Demand Partners and Advertisers. We may share your information with demand partners, brands and advertisers who use our Marketing Platform, to allow them to understand the performance of their campaigns; and to help them better target their campaigns, products or offerings.
• Marketing Partners. We may share your information with data partners who help us with better understanding your preferences by providing data enrichment, analytics and identification services and measurement companies who help us with attribution and tracking of advertisements distributed through us (“Marketing Partners”).
• Service Providers. We may share personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include: IT and related services; fraud detection, information and services; payment processors; customer service providers; and vendors to support the provision of the Services.
• Group. We may share personal information with the Group so that the Services of Think Digital and/or the Group may be improved and otherwise to serve you and/or our customers better with all our offerings including effective content management “Group” as used in this policy, means, with respect to Think Digital, its affiliates and group entities listed here.
• Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
• Disclosures in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract
• International Data Transfers. Where applicable, we will protect information through other legally valid methods, including international data transfer agreements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.
We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.

7. HOW DO WE KEEP PERSONAL INFORMATION SECURE?

Think Digital uses reasonable technical and organizational measures to protect the information it collects about you in compliance with its legal and privacy requirements and contractual obligations. We also seek appropriate contractual protection from our partners regarding their collection, use or treatment of user data. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

Think Digital retains information collected in the context of our Marketing Platform for a period of up to thirteen (13) months, unless otherwise required by law or applicable contract.

Think Digital may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations. In case any information is provided by you in participation of a survey or opinion-based application by Think Digital, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. After the applicable retention period, Think Digital will only retain and may only use your data: (i) in an aggregated or anonymized format; (ii) to comply with its legal obligations; and (iii) to resolve disputes and enforce agreements. Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.

9. PRIVACY RIGHTS

Think Digital provides consumers with data subject or consumer rights as and when and to the extent required under such applicable laws.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “17. CONTACT US” below and provide written authorization signed by you and your designated agent.

Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include information about your device.

The privacy laws of your country may grant you the following additional privacy rights relating to their personal information: right to access, request correction, request deletion/anonymization/blocking, restrict/object to processing, withdraw your consent, request data portability, be informed about third parties with whom your data has been shared, and request review of decisions taken exclusively based on automated processing. To exercise these rights, please write to us at info@thinkdigitalonline.in.

10. INTERNATIONAL TRANSFERS

Think Digital may share your information with clients, customers, partners, the Group and other third parties described above who are based in countries outside of your country of residence (for example, if you are an EEA resident, we may share your information with our non-EEA clients or the Group), subject to any contractual or legal requirements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world.

While some countries may not have data protection laws that are equivalent to those of the country in which you reside, we will take reasonable measures to protect your information in accordance with this Privacy Policy.

12. LEAD GENERATION CAMPAIGNS

Think Digital may offer form-based advertising solutions to marketers that include the collection of voluntary information from you as part of an advertisement that contains a questionnaire. Such information may consist of personal data, non-personal information or data, or both. All the information that you voluntarily provide in response to such form or questionnaire is typically forwarded directly to the relevant marketer’s servers or their landing page and in such cases will be governed by such marketer's privacy policies in place at the time of transfer.

In the event any personal data is directly processed by Think Digital, you acknowledge that Think Digital may be required to store such information for the period during which it continues to manage the applicable lead-generation campaign for its marketer on whose behalf the information is collected. This information may be temporarily stored by Think Digital solely for running such form-based campaigns and will be used only for the purpose of optimization of such campaigns, subject to applicable legal/privacy and contractual requirements.

Think Digital has implemented internal safeguards to protect the temporary storage of this information and uses reasonable technical and organizational measures to protect the same. Think Digital has mechanisms to delete or anonymize any personal data after the said campaign is concluded or within a period thirty (30) days from the same. Pursuant to the conclusion of the applicable campaign, Think Digital may retain and use your Information only to the extent necessary for it to create reports for its client, comply with its legal obligations, resolve disputes and enforce agreements and no other purpose. Any non-personal information or data submitted by you may be used for improving our Services.

If you have any questions about Think Digital lead generation campaigns, please contact us at: info@thinkdigitalonline.in Think Digital will refer any enquiries or complaints to the relevant marketer responsible for the processing of data provided as part of lead generation campaigns.

13. COOKIES

We use cookies and beacons to help us collect some of the information we have described above. This may be done when you interact with us or our third-party partners who enable Think Digital to collect data related to your interaction with their apps or sites for the purpose of serving relevant Ads to you and/or improve our services. We may also use cookies on our and our advertiser’s websites to provide website functionality and advertising to you respectively, and to save you having to provide the information you have already given us on subsequent visits to our site.

For more detailed information about the technologies we use and your ability to control those cookies, please visit our cookie policy We recommend that you review the privacy policies of the third-party apps, services or sites that you directly interact with to learn how those third parties use cookies.

14. PRIVACY OF CHILDREN

Think Digital complies with the age-gating requirements under applicable privacy laws such as Information Technology Act, 2000 (India), Children's Online Privacy Protection Act (COPPA) and California Consumer Privacy Act (CCPA) in the U.S., Lei Geral de Proteção de Dados Pessoais (LGPD), General law of personal data protection in Brazil and GDPR in the EEA and does not knowingly collect personal data about users of sites or apps directed to children.

15. OTHER WEBSITES

Our website and the ads we service may contain links to other websites. You should be aware that we are not responsible for the privacy practices of such other websites as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these links and we shall not be responsible for any use of such websites.

16. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time. The amended Privacy Policy will be displayed on our site. If we make any material changes, we will notify you by means of a notice on this site prior to the change becoming effective. Please check our Privacy Policy regularly to ensure you have read the latest version.

17. CONTACT US

If you have any questions about this Privacy Policy, please contact us at info@thinkdigitalonline.in

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