VDOPIA PRIVACY POLICY

Updated and effective as of: May 21, 2018

This Privacy Policy explains how Vdopia Inc. and its subsidiaries, including, as of the date of this Privacy Policy, Vdopia Media and Software Solutions Pvt. Ltd., Vdopia Media and Software Solutions Pte. Ltd. and Vdopia Media and Software Solutions Pty. Ltd. (“Chocolate”, “we”, “us”, “our”) collect, use, and share information and the options available to you. If you have any questions, you may contact us. See the “Contacting Us” section below.  We may change this Privacy Policy from time to time. Please consult this Privacy Policy regularly for updates. See “Changes to this Privacy Policy” below for more information.  You acknowledge that you accept the practices described in this Privacy Policy by visiting and/or using our Services.

Chocolate provides an advertising platform that enables website and mobile website and application publishers and advertising partners to market, purchase and sell digital and mobile advertising and advertising inventory.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers the information that we may collect or receive through all digital formats, including the Internet and mobile: (1) from users who: use our software applications, use our social media pages such as LinkedIn and Twitter, receive email messages from us, and visit www.chocolateplatform.com and other websites owned and operated by us, including our career pages and our client and user interfaces (collectively, the “Chocolate Pages”); and (2) through our technology and platform used by our clients and third parties (collectively with the Chocolate Pages, the “Services”).

This Privacy Policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties (except as required by applicable law), such as our publisher clients, our advertising clients such as demand side platforms, any third party data management providers, any third party ad servers, and any service providers. See “Third Parties” below for more information.

Choice and Opting Out: see “Choices” below for information about your choices regarding opting out of email marketing communications, opting out of interest-based advertising from cookies and in mobile applications, opting out of cross-device targeting, and opting out of use of precise location.

Access and Rights: see “Access and Rights regarding Personal Information” below for information about how to review, correct, update, suppress, or delete the personal information that Chocolate maintains about you.

COLLECTION OF INFORMATION

We and our third party service providers may collect personal information from you from the Chocolate Pages, including your name, user name, email address, phone number, SKYPE (or equivalent) name, and physical address. For example, we collect your personal information when you request information about the Services, you sign up to use the Services through our client log in and user interfaces, you request access to our resources, or you apply for a job at Chocolate through our Career pages. The decision to provide this information is optional, however, if you elect not to provide such information, you will not be able to access the information you had requested to access or use.

We and our third party service providers may also collect other information that is linked or reasonably linked to a particular computer or device. This information includes the following:

  • browser information, including browser type;
  • device information, including screen dimensions, device brand and model;
  • time spent on the Services and your activities on the Services, date and time an ad was served, clicks on ads, ad reporting (e.g., size and type of ad), ad impressions, location and format of ads, information about interactions with ads, pages and URLs visited, apps visited, and other anonymous traffic data;
  • your location data as derived from IP address;
  • your precise location as derived from the client publisher providing it or from a user’s GPS;
  • unique identification numbers, including IP address and mobile device identifier;
  • demographic information (e.g., age, gender, marital status) as provided by the client publisher;
  • information provided by you; and
  • aggregated information.

We and our third party service providers may collect this information in a variety of ways, including through: your browser or device; your mobile device identifier; your use of our applications; the use of pixel tags and other similar technologies; your IP address; the aggregation of information; and cookies (see Cookies and Similar Technologies below).

Our publisher clients may also collect information about you that they choose to pass to us either directly or through our Services. The information such publisher clients may share includes network type of a user’s device, year of birth, ethnicity (where permitted by law), gender, and precise geo location (where permitted by law). Some clients may provide precise geo location information collected on certain platforms.

Collection of Job Applicant Data

We may collect the following information from you in connection with your job application:

  • name, address, telephone number, e-mail address, and other contact information;
  • username and password;
  • work authorization status;
  • CV, résumé, cover letter, previous work experience and education information;
  • skills;
  • professional and other work-related licenses, permits and certifications held;
  • information relating to references;
  • background information through background checks; and
  • any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards or professional memberships).

We ask that you avoid submitting the following sensitive information, except where such information is legally required: race, color, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status, genetic information, or trade union membership information.

To the extent the personal information you provide contains details of your: racial or ethnic origin; political opinions or beliefs; religious beliefs; membership in a trade union or political party; physical or mental health or condition; sexual orientation; commission (or alleged commission) of an offence or related proceedings; job evaluations or educational records, you expressly authorize Chocolate to handle such details for the purposes of your job application.

Any information you submit through the career pages of the Chocolate Pages (including any pages hosted by a third party service provider) must be true, complete and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

We may also obtain information about you from your references or from a background check report in connection with your application, as permitted by applicable law.

USE OF INFORMATION

We and our third-party service providers may use personal information (such as name, phone number and email address) collected from the Chocolate Pages:

  • to respond to your inquiries and fulfill your requests,
  • to send administrative information to you,
  • to send you communications that we believe may be of interest to you, including any communications for marketing purposes related to the Services,
  • for our business purposes, such as data analysis, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, and determining the effectiveness of our campaigns,
  • with respect to job applicants: to process your employment application; to assess your capabilities and qualifications for a job; to conduct reference checks; to respond to your inquiries and communicate with you about your application, and to send you information regarding the career pages and changes to our terms and policies; to comply with or monitor compliance with any applicable law or regulation; and to conduct background checks if we offer you a position, as permitted by applicable law, and
  • as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.


We and our third party service providers may use other information from the Services that is linked or reasonably linked to a particular computer or device:

  • to operate, improve, analyze and manage the Services,
  • to ensure the Services function properly,
  • for advertising purposes, such as using an identifier for ad delivery and reporting across websites, online services, and apps over time, including optimization of location of ad placement, ad performance, reach and frequency metrics, fraud prevention, ad effectiveness measurements, and logging the number and type of ads served on a particular day on a device,
  • to provide you with personalized location-based services and content through the use of your device’s physical location (where permitted by law),
  • to track your use of the Services to improve the design and functionality of the Services,
  • to supplement your other information with additional information we receive from third parties such as advertising segments to allow us to target ads to you that may be of interest to you,
  • to measure and report on the success of marketing campaigns,
  • to diagnose server problems and administer the Services via your IP Address (a number automatically assigned to the computer or device that you are using by your internet service provider), and
  • as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

We may partner with certain third parties to collect other information to engage in analysis, research, and reporting, as well as to deliver advertising that we believe may interest you based on your activity on our website and other websites over time. These third parties may set and access cookies on your computer or other devices and may also use web logs or web beacons. See “Cookies and Similar Technologies.”

In some instances, we may combine information from the Services that is linked or reasonably linked to a particular computer or device with personal information. If we combine such information with personal information, the combined information will be treated by us as personal information as long as it is combined.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies in connection with our Services. A cookie is a small data file that we store on your computer’s or mobile device's memory. Cookies help us better understand the effectiveness of an ad (for example, by tracking the way in which you respond to, select and interact with an Ad or any content provided therein, or the location and context in which you view an Ad, and for managing the frequency in which you see particular ads). Some cookies help you navigate our Services, including setting a cookie to remember your login details. Other cookies collect information about how you use our Services, which highlights areas we can improve, including navigation. If you submit an inquiry through our website and provide your name and email and similar information, that personal information will not be tied back to you for interest-based advertising purposes across websites and applications, however, you may receive email marketing communications from us.  To opt out of marketing communications, see “Choices.”

We may also use "pixel tags," "web beacons", "clear GIFs" or similar means (individually or collectively "Pixel Tags") to analyze usage patterns of consumers. A Pixel Tag is an electronic image, often a single pixel, which is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a webpage or in a mobile application and may be associated with cookies on your hard drive. Some Pixel Tags are used to drop cookies on users’ devices. Pixel Tags allow us to count users who have visited certain websites and applications of our publishers, and pages within such websites and applications, and to help determine the effectiveness of promotional or advertising campaigns.

Cookies and Pixel Tags also help us operate and improve our Services, including to verify legitimacy of traffic, and to help us send you personalized, targeted Ads that you see because of information collected through such Pixel Tags and stored within your cookie embedded on your device(s).  To opt out of interest-based advertising see “Choices.”

Third parties may also use cookies or similar technologies on visitors of our websites to serve  interest-based advertisements to such visitors when they visit other websites and mobile applications, including advertisements promoting our Services.

Publishers, advertisers and advertising partners that participate in the Services may also utilize cookies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through cookies or similar technologies by such third parties will be governed by their own privacy policies and principles, which Chocolate does not control.

Your browser may offer tools to enable or disable cookies by modifying the settings in your browser. However, please note that certain features of the Chocolate Pages may not work if you delete or disable cookies. Moreover, if you delete cookies after previously opting out of Chocolate’s platform practices, you may need to renew your opt-out choice.

To read more about cookies and your choices with regard to Chocolate’s and third parties’ uses of cookies in our Services, please see “Choices.”

INFORMATION SHARING

Your personal information (such as name, phone number and email address) collected from the Chocolate Pages may be shared:

  • among our affiliates for the purposes described in this Privacy Policy (Vdopia Inc. is the party responsible for the management of the information jointly used by it and its affiliates),
  • with our third-party service providers who provide services such as email management, event management, campaign measurement, and marketing analytics and other services,
  • with our third-party service providers who provide services relating to our career pages, recruiting, background check processing and similar services,
  • directly by you on profile pages and blogs and other services to which you are able to post information and materials yourself (including, without limitation, our social media pages),
  • with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), and
  • as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

We and our third party service providers may share other information from the Services that is linked or reasonably linked to a particular computer or device:

  • among our affiliates for the purposes described in this Privacy Policy (Vdopia Inc. is the party responsible for the management of the information jointly used by it and its affiliates),
  • with our publisher clients to allow them to analyze the effectiveness and performance of our Services,
  • with our advertising clients to allow them to make decisions regarding buying advertising inventory on our publisher clients’ websites, other websites, and applications, and to analyze the effectiveness and performance of their advertising campaigns via our Services, including sharing your device’s physical information to enable our clients to provide you with more personalized advertising content and to study the effectiveness of advertising campaigns,
  • with our third-party service providers who provide services that enhance our Services, including ad and content analytics vendors, vendors providing viewability, fraud-free, and brand-safe ad services, data management services, and cloud storage vendors,
  • with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), and
  • as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

We may also share and disclose other information that we collect, including aggregate information, as we consider necessary to develop and provide our Services, including in the ways described above in this section “Information Sharing.”

We ask our service providers to confirm that their privacy and security practices are consistent with ours, we provide our service providers with only the information necessary for them to perform the services we request, and we ask our service providers not to use such information for any purpose other than as specified by Chocolate.

Chocolate may offer online resources that facilitate communications among the Chocolate client community and others. Whenever you voluntarily post information to any public forum offered by Chocolate, such information along with your user name can be accessed by other users of the forum, including members of the public if the forum is open to the public.

LEGAL BASIS RELIED ON FOR PROCESSING PERSONAL INFORMATION OF EUROPEAN ECONOMIC AREA INDIVIDUALS

Chocolate is a data processor with respect to personal data collected or received by us when we receive such information from our publisher clients (the data controllers) that make their data available for use via our Services.  Where we operate as a data processor, we are processing the data on behalf of our clients (the data controller(s) of the data) based on their instructions, and it is the responsibility of the data controller to establish an appropriate legal basis for the processing of the data. For example, we may process data when the individual has consented to such processing.  On certain occasions we may rely on legitimate interest as a basis for processing, when it is in our clients’ and our legitimate interests to do so and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include performing our obligations with respect to providing the Services and improving our Services.

Chocolate is a data controller with respect to any personal data collected or received by us when we receive personal information (such as name, phone number, SKYPE name, and email address) through our Chocolate Pages.  In this case, the data controller is Vdopia Inc. Where Chocolate operates as a data controller, we rely on legitimate interests to process personal data to provide our Services. On certain occasions, we may also rely on the consent of the individual to process personal information (for example, in some jurisdictions, when the user inputs personal information into the Chocolate Pages and consents to receive marketing communications). On other occasions, we may process personal information when we need to do this to fulfill a contract or where we are required to do so by law.

RETENTION

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, or an individual requests deletion in accordance with applicable law.  See “Access and Rights regarding Personal Information.”

CHOICES

Commitment to Industry Self-Regulation:  Chocolate adheres to the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles in the US.

Opting Out of Marketing

We give you choices regarding our use and disclosure of your personal information for marketing purposes.

You may opt-out from receiving electronic communications from us (or opt in, if required by applicable law). If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing related emails by contacting us at privacy@chocolateplatform.com or by clicking on the opt-out link within the email message that you receive from us.

Please also note that if you do opt-out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to the Services from time to time.

Opting Out of Chocolate’s cookies

You may disable cookies, including Chocolate’s cookies, by modifying the settings in your browser.  However, please note that certain features of the Chocolate Pages may not work if you delete or disable cookies. Moreover, if you delete cookies after previously opting out of Chocolate’s platform practices, you may need to renew your opt-out choice.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

Opting Out of Interest-Based Advertising from Cookies

To opt out of receiving interest-based advertising (including retargeting) from Chocolate’s services through the use of cookies in your current browser and for more information on what it means to opt-out, please go to https://chocolateplatform.com/opt-out/. When you opt out of receiving interest-based advertising from Chocolate, note that the opt out only applies to the applicable browser in which you set it. Note that the Chocolate opt out tool is cookie-based. This means that, if you have cookies blocked, you will not be able to use it. Note also that if you delete cookies entirely then you will need to opt out again. Finally, note that once the opt-out has been completed, you will still receive advertisements, but such advertisements will not be interest-based ads targeted by Chocolate.

Some of our publisher clients and advertising partners have their own opt-out mechanisms that are linked from their websites or their online-posted privacy policies. You should review the privacy policies of those companies for these opt-out links if you no longer wish to receive targeted advertising from a particular company, or multiple companies.

Some third parties who use cookies when you visit our websites, also have opt out mechanisms either directly from their website or through an industry-developed web page. If you go to optout.aboutads.info or www.aboutads.info/choices, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

Opting Out of Interest-Based Advertising in Mobile Applications

To opt out of Vdopia’s interest-based advertising that takes place through mobile applications, please see the following instructions on utilizing your mobile device operating system’s opt-out settings.

For iPhone/iOS users: For instructions on how to “Limit Ad Tracking” on the iOS, please visit this link or see the instructions below:

  1. Go to “Settings” > “Privacy” > “Advertising.”
  2. Turn on “Limit Ad Tracking.”

         For Android users: For instructions on how to opt out of interest-based ads in the Android OS, please visit this link or see the instructions below:

  1. Open Google settings on your device (may be an app called Google Settings or an entry in your phone’s Settings menu, depending on your device)
  2. Tap “Ads”
  3. Switch on “Opt out of interest-based ads” or “Opt out of Ads Personalization.”

Opting Out of Cross-Device Targeting

We and our publisher clients, ad partners and third parties may combine and use information from websites or applications on your current browser or device with information from your other browsers or devices for advertising purposes. To opt out of such practices, please follow the instructions above for opting out on each of your browsers and on each of your mobile devices, including: “Opting Out of Interest-Based Advertising from Cookies” and “Opting Out of Interest-Based Advertising in Mobile Applications.”

Please note that you will need to opt out separately on (1) each of your browsers and (2) each of your mobile devices to ensure that information collected on a particular browser or device is not used on another browser or device.

Opting Out of Use of Precise Location

To disable the collection of precise location information from your mobile device through mobile applications, you can access your mobile device settings and choose to limit that collection.

Android: For Android 6.0 and above: you can modify privacy settings in Settings > Applications > App Permissions > Location and tap the on/off toggle switch next to Location for each app which has permission to use your location data. For earlier versions of Android: you can modify privacy settings in Settings > More > Permission and tap the on/off toggle switch next to Location to turn location functions off for your device. Alternatively, you may uninstall the relevant program(s).

iOS:   In iOS you can modify privacy settings in Settings > Privacy. You can select location data from this list to see which apps have asked for permission to use your location data.

ACCESS AND RIGHTS REGARDING PERSONAL INFORMATION

If you reside outside the European Economic Area and Switzerland, and you would like to review, correct, update, suppress, or delete the personal information that Chocolate maintains about you, or you would like to request a copy of your personal information held by us, you may contact us at privacy@chocolateplatform.com.

If you are a resident of the European Economic Area, including Switzerland, you have the right to access the personal information that Chocolate maintains about you, and you may be able to review, correct, update, suppress, or delete that information or the processing of that information. To exercise these rights as a resident of the European Economic Area, including Switzerland, email privacy@chocolateplatform.com or see [add link to data subject form to make requests].

To opt out of receiving marketing communications from us, please see “Choices.”

To opt out of interest-based advertising from cookies, see “Choices.”

To opt out of interest-based advertising in mobile applications, see “Choices.”

To opt out of cross-device targeting, see “Choices.”

To opt out of the use of precise location, see “Choices.”

THIRD PARTIES

This Privacy Policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties (except as required by applicable law), including any third parties operating any site or service to which our Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. These third parties are bound by their own privacy policies.

We are also not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of our publisher clients, our advertising clients such as demand side platforms, data management platforms, app developers, app providers, ad servers, social media platform providers, operating system providers, wireless service providers or device manufacturers (except as required by applicable law), including any Personal Information you disclose to other organizations through or in connection with the Services.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose to us, any sensitive information (e.g., social security numbers or other government identifiers, information related to racial or ethnic origin, political opinions, religion or other beliefs, medical or health conditions, criminal background, trade union membership, or sexual orientation) on or through the Services or otherwise to us, except where such information is legally required.

SECURITY

Information that we collect is stored using procedures and practices reasonably designed to help protect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information transmitted, stored or otherwise processed by us.

USE OF SERVICES BY MINORS

Our Services are not intended for, nor directed to, individuals under the age of thirteen (13), and we request that these individuals, and any other individual considered a minor under applicable law, do not provide personal information through any of the Services.

INTERNATIONAL INFORMATION TRANSFERS

Please be aware that the information we collect, may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. Please be advised that we process and store information in any country where we have facilities and/or employees, including the United States and India, or in which we engage service providers. Your consent to this Privacy Policy or your use of any of the Services or your submission of your information to us or any of our publisher clients, represents your consent to such transfer, storage and processing outside of your country of residence, including the United States and India, which may have different data protection rules than those of your country of residence.

EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD COMPLIANCE AND STATUS

If we transfer personal information from the European Economic Area (including Switzerland) to the United States, Vdopia Inc. complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, as applicable, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Economic Area (including Switzerland) to the United States.  Vdopia Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Vdopia Inc. is accountable for information that it receives under the Privacy Shield and subsequently transfers to a third party. Vdopia Inc. may transfer personal information collected from the Chocolate Pages as described above in this Privacy Policy. Vdopia Inc. may also transfer other information which meet the definition of “personal data” in the Privacy Shield Framework to service providers and to its clients such as publishers, ad partners, and ad agencies including for interest-based advertising as described above. If we share personal data of European Economic Area individuals (including Switzerland) with a third-party service provider that processes the data solely on Vdopia Inc.’s behalf, then Vdopia Inc. will be liable for that third party's processing of such data in violation of the Privacy Shield Principles, unless Vdopia Inc. can prove that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Vdopia Inc. commits to resolve complaints about our collection or use of your personal information of European Economic Area individuals (including Switzerland).  Such individuals who have inquiries or complaints under the Privacy Shield Frameworks should first contact Vdopia Inc. at privacy@chocolateplatform.com or:

Vdopia Inc., c/o Chocolate Platform
Attention: Privacy
442 Post Street
San Francisco, CA 94102
USA

Vdopia Inc. has further committed to refer unresolved Privacy Shield complaints to the ICDR (the international division of the American Arbitration Association), an international alternative dispute resolution provider. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact the ICDR or visit http://go.adr.org/privacyshield.html for more information or to file a complaint.  The services of the ICDR are provided at no cost to you.

Under certain conditions, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

See  https://www.privacyshield.gov/article?id=ANNEX-I-introduction for more information.

The Federal Trade Commission has jurisdiction over Vdopia Inc.’s compliance with the Privacy Shield Framework.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to make changes to our Privacy Policy. Please look at the date at the top of this page to see when this Privacy Policy was last revised. Where required by law, we will obtain your consent to make these changes.

CONTACTING US

For any questions about this Privacy Policy or Chocolate’s privacy practices, please contact us by email at privacy@chocolateplatform.com, or by mail at:

Vdopia Inc., c/o Chocolate Platform
Attention: Privacy
442 Post Street
San Francisco, CA 94102
USA

CHOCOLATE Network Privacy Policy

Chocolate provides an advertising platform for mobile media and related services to connect advertisers that are part of the Chocolate's network ("Advertisers") with publishers of mobile applications and mobile websites ("Publishers"), by facilitating the sending of advertisements through such platform ("Ads"). This Privacy Policy is made available on our website at https://chocolateplatform.com/ (the "Site"), and provides information on our policies and procedures regarding the collection, use and disclosure of personal information we receive from consumers who view and/or interact with Ads ("Consumers"). We will notify you of any material changes by posting the new Privacy Policy on the Site. You are advised to consult this Privacy Policy regularly for any changes.

As used in this Privacy Policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

Consumer Information: Collection, Use, and Sharing

This section of the Privacy Policy applies to information that Chocolate may collect, access and/or obtain about Consumers who view Ads while using or accessing a Publisher's mobile application or mobile site (collectively, "Mobile Media").

Our primary goals in collecting, accessing or obtaining information are to deliver tailored Ads based on the inferred interests of Consumers, and measure their effectiveness with Consumers. We do this by utilizing the non-identifying information that we collect access or obtain through cookies and Pixel Tags (defined below) embedded on a Mobile Media on which you view Ads, in conjunction with the information about you that is provided by you or provided to us by our Publishers, to personalize the content of Ads that you see. You can opt-out of receiving targeted Ads as described below.

  • Our Publishers allow us to serve Ads on their Mobile Media. We use technology to send, directly to your browser or mobile application, the advertisements and links that appear on the Mobile Media. If you use a Mobile Media, we automatically receive your IP address and mobile device ID when this happens, and we use other technologies (such as cookies and Pixel Tags, as described below) to measure the effectiveness of the Ads and to personalize the advertising content that you see on the Mobile Media. We also collect, access or obtain other non-identifying information in conjunction with your IP address and/or device ID; these non-identifying details include, but are not limited to, the website you are logged onto or the application you are using, the geographic location of the IP address you are using to access the Internet, the type of browser used, which and how many web pages have been viewed by you, which applications you have used, search terms used, referring/exit pages, platform type and date/time information. We do not collect, access or obtain personally identifiable information (such as name, username, address, phone number or email address) from you when you view or interact with Ads.
  • We may also receive from Publishers additional, non-identifying information that they collect about you, such as location information or demographic information. We encourage you to read the privacy policies or statements of the Mobile Media you visit. Chocolate's Privacy Policy does not apply to, and we cannot control the activities of, Advertisers, Publishers or other websites.
  • The information we collect access or obtain about you does not personally identify you. This information is used by Chocolate for the purpose of delivering Ads and measuring their effectiveness with Consumers. We aggregate this information and use it to analyze trends, identify the audience most likely to respond to an Ad and to tailor Ad placement for members of our advertising network accordingly. This aggregated information may be shared with our affiliates, Advertisers, employees, customers and Publishers. In addition, we may share with such entities any device IDs and associated demographic data. Any information shared in this context will not contain your personally identifiable information. We reserve the right to track IP addresses for the purposes of fraud prevention, and we reserve the right to release IP addresses to legal authorities.

Cookies

We use cookies in connection with Ads served through our platform. A cookie is a small data file that we transfer to your mobile device's memory for record-keeping purposes when you are served an Ad. Cookies help us better understand the effectiveness of an Ad (for example, by tracking the way in which you respond to, select and interact with an Ad or any content provided therein, or the location and context in which you view an Ad). Our cookies do not contain any personally identifiable information and they can help control the number of times you view an Ad.

Pixel Tags

We may also use "pixel tags" "web beacons", "clear GIFs" or similar means (individually or collectively "Pixel Tags") to analyze usage patterns of Consumers and to serve Ads to you that are tailored based on our analysis. A Pixel Tag is an electronic image, often a single pixel, which is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a webpage or in a mobile application and may be associated with cookies on your hard drive. Pixel Tags allow us to count users who have visited certain Mobile Media and pages within Mobile Media, to personalize the Ads, and to help determine the effectiveness of promotional or advertising campaigns.

Opt-Out

If you prefer that Chocolate not use any cookies for the purpose of sending targeting Ads to you, you can click the "Opt Out Now" button at https://www.chocolateplatform.com/w3c/optout.php?portal=i Note that the Chocolate opt-out tool is cookie-based. This means that, if you have cookies blocked, you will not be able to use it. Furthermore, if you delete your cookies, the opt-out cookie will also be deleted, and you will need to opt-out again. Finally, note that once the opt-out has been completed, you will still receive Ads, but such Ads will not be targeted.

Advertisement Links

The Ads may contain links to other websites, including those of Advertisers and Publishers. Such websites may use cookies and/or other data collection tools. Chocolate is not responsible for the privacy practices, policies or the content of such websites. Chocolate encourages you to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. Chocolate has no control over the use of your personally identifiable information by third party websites, and you should exercise caution when deciding to disclose any personally identifiable information. Additionally, Chocolate does not have access to, or control of, the cookies and/or other data collection tools that may be placed on any advertisement by a third party, including those of our Chocolate Customers, and this Privacy Policy does not cover the use of cookies and/or other data collection tools by any third party.
Information Sharing and Disclosure

Service Providers: We may employ third party companies and individuals to facilitate our advertising platform and to provide our advertising platform on our behalf (e.g., without limitation, maintenance services, database management, web analytics and improvement of our advertising platform's features). These third parties have access to information collected under this Privacy Policy, only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement: Chocolate cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Chocolate or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

Business Transfers: Chocolate may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Security

Chocolate is very concerned with safeguarding the information that we collect. We employ reasonable physical, technological, and administrative security measures. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect the information that we collect, we cannot guarantee its absolute security.

International Transfer

Your information may be transferred to -- and maintained on -- computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Chocolate transfers personally identifiable information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information, or your submission of such information to us or one of our Publishers represents your agreement to such transfer.

Our Policy Toward Children

Our services are not directed to children under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at mobile-privacy@vdopia.com If we become aware that a child under 13 has provided us with personally identifiable information, we will delete such information from our files.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at mobile-privacy@vdopia.com