INTRODUCTION
NetSee provides attribution and marketing analytics services (“Services“) that enable advertisers
and developers (collectively, “Customer(s)“) to: (i) measure and analyze the effectiveness of their
marketing campaigns by understanding which marketing campaigns contributed to the download/installation of
their mobile applications (“Applications“) or such other conversion metric (e.g. relaunch of
Application); and (ii) measure and analyze certain events and actions within their Application, such as
in-app purchases made by End Users (as defined below). The Services also help our Customers identify and
protect against fraudulent behavior related to their marketing campaigns.
This Services Privacy Policy describes NetSee’s privacy practices in relation to the information
collected from Customers and End Users and received by NetSee when Customers use our Services. NetSee and
its Customers have entered into an agreement that governs the provision of Services by NetSee and their
use by Customers (“Agreement(s)“). Such Agreements may contain additional obligations on the
parties with respect to the handling of information. Nothing in this Services Privacy Policy derogates
from such additional obligations.
For the purpose of this Services Privacy Policy: (i) any reference to “End User(s)” means end
users who have interacted with, or viewed, Customer’s advertising and marketing materials, or use or have
used Customer’s Applications, products and services; and (ii) any reference to “NetSee”,
“we, “us” or “our” shall means NetSee Ltd. and its affiliates.
END USER DATA RECEIVED AND PROCESSED BY METRIX
When a Customer uses the Services, the following End User information may be received and processed by
NetSee (collectively, “End User Data”).
- “Technical Information”: this refers to technical information related to an End User’s mobile
device or computer, such as: browser type, device type and model, CPU, system language, memory, OS
version, Wi-Fi status, time stamp and zone, device motion parameters and carrier.
- “Technical Identifiers”: this refers to various unique identifiers that generally only identify
a computer, device, browser or Application. For example, IP address (which may also provide general
location information), User agent, IDFA (identifier for advertisers), Android ID (in Android devices);
Google Advertiser ID, Customer issued user ID and other similar unique identifiers.
- “Engagement Information”: this refers to information relating to the Customer’s ad campaigns
and End User actions, such as: clicks on Customer ads, ad impressions viewed, audiences or segments to
which an ad campaign is attributed, the type of ads and the webpage or Application from which such ads
were displayed, the webpages on Customer’s website visited by an End User, the URL from the referring
website, downloads and installations of Applications, and other interactions, events and actions
Customers choose to measure and analyze within their Application or website (e.g. add to cart, in-app
purchases made, clicks, engagement time etc.).
- While End User Data does not generally contain any information that directly identifies an individual,
such as names, addresses, credit cards or other similarly regulated financial information, health
information, or any other type of sensitive personal information (“PII“), we acknowledge that
under certain jurisdictions the End User Data we do receive when a Customer uses the Services may be
deemed personal data and therefore, where applicable, will be treated as such. Within the scope of the
engagement between Customers and NetSee, Customers are contractually prohibited from collecting PII,
unless otherwise agreed by NetSee. However, Customers have sole control over their properties (including
their Application) and configuration of the Services and thus Customers have the technical ability to
configure the Services to collect PII. This includes, for example, a Customer using an End User’s email
address as a Customer issued user ID Technical Identifier. If a Customer has configured the Services to
collect PII then we may receive and process such data.
REGISTRATION INFORMATION RECEIVED AND PROCESSED BY METRIX
When a Customer registers to use the Services, we may collect certain information related to such
Customer (“Registration Information” and together with the End User Data, “Customer Data”),
including Customer name and Customer details, billing information and names and contact details of
Customer employees and representatives who are using the Services (e.g. email, phone number and address).
When a Customer uses the Services, NetSee may also collect certain log data, such as IP address from which
a Customer is connecting to the Services, information related to the device being used to connect to the
Services (e.g. browser type, device type, OS version) and the features and functions of the Services used
by the Customer (“Log Data”).
HOW DATA IS COLLECTED
Customer Data may be collected through various methods, including:
- When provided voluntarily (e.g. Customer’s Registration Information).
- When the Customer integrates NetSee’s SDK’s, API’s, pixels, redirect links, JavaScript tags, cookies
or similar data collection technologies into their Applications, websites and/or ads (“Collection
Technologies”).
- From the various advertising networks and third parties that are used by the Customer in connection
with the measurement and analysis of Customer’s marketing campaigns and that have partnered with NetSee
(“Partners”).
HOW DATA IS USED BY METRIX
- When NetSee receives End User Data from a Customer, it uses such End User Data as follows:
- to provide such Customer with the Services they have subscribed for. Such services may include,
without limitation, attribution, analytics and ad fraud protection services. Please visit here for more information regarding the Services.
- to establish: (i) matches between devices used by an End User; and (ii) to detect fraud (such
matched data and fraud data, collectively, the, “Platform Data”) in order to ensure more
accurate attribution measurement and ad fraud protection for Customers using the Services. Platform
Data does not contain PII such as End User names, physical addresses, phone numbers or other similar
personal data that can directly identify an individual.
- With regards to Registration Information and Log Data, we use such information to authenticate login
to the Services, to communicate with Customer and to process any payments in connection with the
Services. Additionally, we may use: (i) Registration Information to inform Customer of any updates to
the Services, including new features and functionalities; and (ii) Log Data to understand how Customers
are using the Services so that we may efficiently audit, maintain and improve the Services provided to
Customers.
- NetSee may use information derived from the aggregation of End User Data and/or Log Data with other
data for research and analytics purposes and improvement and marketing of the Services (“Aggregated
Data”). Aggregated Data shall be anonymous and in no way reveal the identity of the Customer or
any End User.
SHARING DATA
NetSee does not share or disclose Customer Data with any third party, except: Upon our Customer’s
request– (e.g. to Partners);
- To our subsidiaries and global branches as necessary to help us support and maintain the Services
provided to Customers;
- To our service providers who help to support our Services – such as data hosting providers and payment
processors; Transfers to subsequent third parties are covered by the service agreements with our
Customers. These companies are authorized to use your personal information only as necessary to provide
these services to us.
- When legally required (e.g. court orders or other lawful requests by public authorities), including to
meet national security or law enforcement requirements;
- To respond to, or prevent, fraud or to protect the safety of NetSee, its Customers, End Users or the
public;
- As part of any merger or acquisition of NetSee, in which case End User Data may be transferred to the
surviving or acquiring entity.
PROTECTING DATA AND RETENTION
NetSee implements appropriate technical and organizational measures designed to protect against
unauthorized access, accidental loss, destruction or damage of Customer Data. If you have questions about
the security of your personal information, or if you have reason to believe that the personal information
that we hold about you is no longer secure, please contact us immediately as described in this Services
Privacy Policy.
NetSee will not retain: (i) End User Data for more than twenty-four months except where otherwise
directed by Customers or required or allowed by law; and (ii) Registration Information, Log Data or
Platform Data for more time than is needed to serve the legitimate business need for which it was
collected.
RELATIONSHIP, LAWFUL BASIS AND END USER CHOICES
Under the laws of certain jurisdictions, when processing End User Data in connection with the provision
of Services to a Customer, NetSee is deemed a ‘data processor’ while its Customers are deemed ‘data
controllers’.
Therefore, End Users should closely review the Privacy Policies of the Applications they use in order to
learn about the privacy practices of our Customers.
Where NetSee may be deemed a data controller under the laws of certain jurisdictions (e.g. in connection
with its processing of Log Data or Registration Information), NetSee shall comply with all applicable laws
related to its status as a data controller and shall only use the data as described in this Services
Privacy Policy. With regards to Registration Information and Log Data, the lawful basis NetSee relies on
is its need to perform its obligations under the Agreement between NetSee and Customer and on its
legitimate interests to maintain, analyze and improve the Services.
The laws of certain jurisdictions may provide End Users with various rights in connection with the
processing of End User Data, including:
- The right to withdraw any previously provided consent;
- The right to access certain information about you that we process;
- The right to have us correct or update any Personal Information;
- The right to have certain Information erased;
- The right to have us temporarily block our processing of certain Information;
- The right to have Information exported into common machine-readable format;
- The right to object to our processing of Information in cases of direct marketing, or when we rely on
legitimate interests as our lawful basis to process your information;
- The right to lodge a complaint with the appropriate data protection authority.
Where NetSee is deemed a data processor, End Users should contact our Customers to pursue any such legal
data subject rights. NetSee will cooperate with its Customers to support and comply with any such data
subject rights requests.
Where NetSee is deemed a data controller, End Users may exercise their rights by contacting NetSee at: [email protected]. We will respond to
your requests within a reasonable timeframe. Please note these rights may be limited in certain
circumstances as provided by applicable law. In any event, NetSee provides End Users with the ability to
opt-out of being measured by the Services by emailing a request to [email protected].
UPDATES AND QUESTIONS
We may update this Services Privacy Policy from time to time. Any material changes will be notified to
the Customer either through the Services, email or as otherwise agreed by the parties in the Agreement. We
will also indicate that an update has occurred on the top of this page so Customers and End Users are
encouraged to review this Services Privacy Policy from time to time.
For any questions relating to this Services Privacy Policy or to contact our data protection officer
please send us a mail to: [email protected]. You may also send us
or our data protection officer regular mail:
NetSee – Attn: Legal Team/Data Protection Officer
3rd
Floor, No. 23, Anahita Deadend, Nelson Mandela Boulevard, Tehran, Iran