Privacy Policy/Statement


Leadbolt Pty Limited ACN 144 039 529 (“we”, “us”, “our” and “Leadbolt”) is a mobile advertising platform with technology that enables our mobile application partners to show relevant advertising to their End Users. In order to provide relevant advertising, we collect and use certain information.

Leadbolt is deeply committed to protecting the privacy of all our users, both Clients and End Users. Therefore, the Leadbolt Privacy Policy (this “Policy”) is designed to clearly explain how we use and manage the Anonymous Information and Personal Information collected by our Services.

By using or interacting with our Services, you are agreeing to the terms of this Policy.

For Developers, Advertisers and Publishers

If you are viewing or visiting any of our websites in-order to sign up as a developer, advertiser, or publisher (“Client”), on sign-up you will be requested to enter into an agreement with Leadbolt (“Agreement”). That Agreement may contain additional privacy disclosures and obligations. If there is any inconsistency between the Agreement and this Privacy Policy, the Agreement prevails.

Information we collect from our Clients

As a Client or visitor to our Sites, we collect certain information that you voluntarily provide to us. This is collected when you interact with our Services and provide us with information by filling out a form or signing up to a Service. This may include your name, contact details such as e-mail address and payment details where relevant.

We also use Cookies, Web Beacons and other technologies to store and retrieve information to optimize your experience of the Services and more effectively run our Services.

Information we collect from End Users

As an End User of an App that utilizes Leadbolt’s Services, we may collect or receive Anonymous Information via SDKs or other means in order to effectively run our services. The type of information we collect may include: geographic location, device identifiers for advertising, operating system versions, mobile applications names, language settings, device type information, mobile network settings, IP addresses, internet browser types where used to access the Services, and details of any interactions with our Services.

Where our SDK is embedded in our Client’s App, which the End User has consented to use, any information received through our SDK shall be governed by the terms entered into between our Client and the End User.

We may also collect and store information locally on your device using mechanisms such as local storage identifiers. These local storage identifiers in no way damage your system or files and we primarily uses these identifiers to optimize our Services and to limit the number of ads you see and deliver more relevant ads to you.

We may receive Anonymous Information or aggregated information from our Clients or other third parties. This information may include device information or other information related to the ads we serve.

In countries where the Anonymous Information we collect is considered to be Personal Information, we will only collect this information with consent.

The Services may link to third party content. These parties are not within the control of Leadbolt and are governed by those parties’ respective privacy policies.

Use of Your Information

Leadbolt uses the information we collect about you to provide the Services and to optimize the Services to provide a better user experience to our Clients and End Users. For example, we may use your information in order to:

  • operate, manage and improve the Services
  • communicate with you to respond to your enquiries
  • provide you with information about our Services
  • provide you with more relevant ads and limit the number of advertisements you see
  • do any other things that are related to your interactions with us and to facilitate our business operations.

Disclosure and Transfer of Information

Leadbolt will not share your Personal Information except under any of the following circumstances:

  • With Consent
    We may share your Personal Information to third parties when you have consented to such disclosure.
  • Disclosure to Law Enforcement Agencies
    Leadbolt may be required to share information collected with law enforcement agencies. We will only do so to authorised government agencies where we are compelled to by law or if we believe we are acting in good faith and disclosure is necessary to comply with the law or to protect the interests of Leadbolt, its Affiliates, Clients or End Users.
  • Disclosure to Affiliates
    Leadbolt is based in Australia and may disclose your personal information to our personnel, agents, related companies, licensors, contractors, service providers and business partners (“Affiliates”). Some of our Affiliates may be overseas. Leadbolt obligates all its Affiliates to ensure that they comply with all relevant privacy laws and regulations, and that they shall treat your Personal Information lawfully, fairly, and transparently.

Leadbolt may also share Anonymous Information with our Clients or other third parties in accordance with this privacy policy.

Security & Storage

Leadbolt takes reasonable steps to protect all information which we hold from misuse, loss, unauthorised access, modification or disclosure. All personal information is kept on secure servers. Leadbolt minimizes the amount of time we store sensitive data on our servers and other data is only stored for as long as necessary in order to provide our services, but in no event longer than six (6) months. In individual cases, we may be required to store limited information for longer periods where we have a legal requirement to do so.

Children’s Privacy

We do not knowingly collect Personal Information from children under 13, or up to 16 where relevant legislation applies. If we learn that we have collected the personal information of a child under 13, or under 16 where relevant legislation applies, we will take steps to delete the information as soon as practically possible.

Opting Out

In line with best practice in our industry, we respect End User’s rights to opt-out of receiving Interest Based Advertising. iOS devices include Apple’s advertising control features which can limit ad tracking using the “Limit Ad Tracking” setting. For example, you can do this by going to “Settings” from the device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking”. In Android devices, End Users can activate the “Opt out of interest-based ads” setting. For example, you can do this by going to “Settings” on the device; select “Google Settings”; select “Ads”; and check the box labelled “Opt-Out of Interest-Based Ads”. Please note that even if you opt-out, you will still receive advertising but these ads will not feature interest-based ads that may be more relevant to you.

Additionally, you can opt out of Leadbolt’s Interest Based Advertising by following the method outlined here: https://www.leadbolt.com/optout.

An End User may click below for the Network Advertising Initiative (“NAI”) and Digital Advertising Alliance (“DAA”) opt-out tools to learn more about targeted or interest based advertising and to opt out of certain targeting programs not associated with Leadbolt.

http://www.networkadvertising.org/choices

http://www.aboutads.info/choices/

Information for Individuals Located in the EU

This section applies to information collected from the EU.

Leadbolt respects individual’s rights regarding the processing of their personal data. If you have any questions or concerns regarding our use of your personal data, including if you wish to have your personal information deleted by Leadbolt in accordance with the EU’s General Data Protection Regulation, please contact the Leadbolt Data Protection Officer at dataprotectionofficer@leadbolt.com.

If you would like more information regarding your rights concerning the use of your personal information, please visit the relevant governmental authority below:
Australia: https://www.oaic.gov.au/
EU: https://edps.europa.eu/
United States: https://www.ftc.gov/

Lawful Basis for Processing

Where Leadbolt is a Data Controller
Where Leadbolt is controlling data, such as data of our direct publisher, advertisers who are individuals or visitors to our website, Leadbolt will use that data when it is required in order to perform our obligations under a contract to which you are a party and to provide services to you.

Leadbolt may also collect browser information and use Cookies for visitors to our website. This information will only be used for as described above under “Use of Your Information”.

Where Leadbolt is a Data Processor
We also may process your Personal Information as a result of your request for information relating to Leadbolt’s Services.

Additionally, we may process your personal data:

  • In order to fulfil a legal obligation
  • Where processing is necessary to perform a task carried out in the public interest
  • To protect your interests or the interests of a third party

Leadbolt may also process personal data when necessary for billing purposes, fraud monitoring and prevention, for internal systems improvements, or on behalf of third parties who have a legal right to do so. Leadbolt shall not process any personal data, where such processing would be overridden by your data protection rights.

Changes to the Policy

We reserve the right to amend this policy at any time. The policy, as modified, shall appear on our website; https://www.leadbolt.com/privacy. Your continued use of and/or interaction with our Services is acknowledgement of your acceptance of these changes.

Access to Information

You are entitled to gain access to the Personal Information we hold about you. To do so, or if you have any questions or comments regarding this Policy, please contact us at:
Attention: Data Protection Officer
Email: dataprotectionofficer@leadbolt.com

Definitions

Anonymous Information is information that does not identify a user. It is sometimes referred to as Non-Personally Identifiable Information.

App or Application is a program downloaded onto a mobile device.

Clients are developers, advertiser, publisher or other parties who have entered into an agreement with us to use the Services.

Cookies are small pieces of data sent from a website that are stored in a user’s web browser while the user is browsing that website. When a user revisits the website, the stored cookie data is available to the website.

End Users are users who interact with an App that is utilising the Services.

Interest Based Advertising means the collection of data from apps owned or operated by different entities for the purpose of delivering advertising based on preferences or interests known or inferred from the data collected from those apps.

Personal Information (also referred to as Personally Identifiable Information) is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. It also includes information from which the person’s identity is reasonably ascertainable.

SDK or Software Development Kit is software which our Clients integrate into their Apps and allows them, through a connection to the Services, to provide their End Users with advertising. By downloading and using the App, End Users have granted the App developer, under their respective terms, with permission to collect and share with Leadbolt such information as detailed in this policy.

Services includes our websites (www.leadbolt.com and related sites); the connection to our network of application publishers, developers and mobile advertisers; the ad serving platform and SDK and other online services.

Web Beacons are objects that are embedded in a web page and are usually invisible to the user and provides statistics around website usage.

Updated: May 2018

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