Privacy Policy

LAST UPDATE AS OF 24 MAY 2018

OfferToro (the “Company”) is committed to protecting the privacy of its users. This Privacy Policy (“Privacy Policy”) is designed to help you understand what information we gather, how we use it, what we do to protect it, and to assist you in making informed decisions when using our Service. Unless otherwise indicated below, this Privacy Policy applies to any website that references this Privacy Policy, any OfferToro website, as well as any data the OfferToro may collect across partnered and unaffiliated sites.

By using our website, or services across partnered and unaffiliated sites, you are accepting the policies and practices described in this privacy policy. Each time you visit our website or use our services, and any time you voluntarily provide us with information, you agree that you are consenting to our collection, use, and disclosure of the information that you provide, and you are consenting to receive emails or otherwise be contacted, as described in this privacy policy.

This privacy policy is incorporated into our terms of use. Whether or not you register or create any kind of account with us, this privacy policy applies to all users of the website.

OfferToro is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

OfferToro may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 24 may 2018.

Data Collection of User Information

OfferToro does not acquire or collect any personal information about you. Your name, address and phone number all remain your private property. OfferToro does, however, collect information that is specific to how you use the Internet. This non-personally identifying information can include and is not limited to, the advertisements you engaged with, the server you are logged onto, User Agent, mobile device ID, the geographic location of the ISP you use and your IP address. This information is obtained solely for the purpose of targeting ads and measuring a given ad's effectiveness on behalf of OfferToro’s advertisers.

There are instances where a user may provide specific personal information in response to an ad containing a survey, registration questionnaire or the like. For such programs, OfferToro (or a third party working in conjunction with OfferToro and the advertiser) acquires this information on behalf of the advertiser. OfferToro may aggregate this information in a compiled format without identifying users specifically. This provides the advertiser precise profiles of the types of individuals that respond to the ads.

In addition, OfferToro hereunder may from time to time provide the information described above to third-party providers, solely for purposes of analyzing user behavior and without reference to any personally identifiable information.

Cookies and Advertising Technologies

OfferToro uses cookies to enhance the Internet user's experience on the Web. A cookie is a small text file that is stored on your computer for the purpose of identifying your web browser. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide You with a more personal and interactive experience with the website. When you are served an OfferToro ad, OfferToro may assign various information in a cookie on ads you've seen, information on sites you've visited and activities performed to your computer browser. We do this to understand the way a user responds to the ads we deliver. For example, this information lets us keep track of how many times you view an ad we distribute. Likewise, the cookie can help make sure you do not see the same ad over and over - thus enhancing your online Web viewing experience.

OfferToro collects this information via our technology and it may be stored for up to 10 years for the purpose of analyzing campaign results, ensuring that our technology is functioning properly, and preventing fraud across our sites. We do not link the information we store in cookies to any personally identifiable information you submit while on our website or our member sites. We may, however, obtain non-personally identifiable information about you and combine it with data that we have collected to better target ads that match your interests. Most web browsers automatically accept cookies, but you can usually change your browser to prevent that use if you desire.

Although we believe that cookies help enhance your experience on the Web (by not repeatedly serving the same ads to you and delivering more relevant messages to you), neither OfferToro nor its third party ad serving party needs cookies to deliver ads to you. If you do not want the benefits of cookies, there is a simple procedure that allows you to deny or accept this feature. In order to "opt out" of the benefits of cookies, you may manually delete your cookies by following the instructions contained in the Help section of your browser.

How we use collected information

We use the information we collect through the OfferToro, where and as permitted by applicable law, to:

  1. Display interest-based advertising customized to individuals’ inferred interests, preferences and locations, and to analyze the effectiveness of the ads.
  2. Information you provide helps us respond to your customer service requests and support needs more efficiently;
  3. We may use information in the aggregate to understand how our Users as a group use the services and resources provided on OfferToro;
  4. We use the information we have to support our services through activities such as infrastructure monitoring and internal maintenance, analyzing how our services are used, research and development, and billing. We may also use the information we have to maintain, protect, improve and develop our and our related companies’ services.
  5. We use this information to provide filtering options for Publishers to manage ads appearing in their Partner Apps, and to provide targeting options for Advertisers.
  6. We use the information we have to measure and understand the effectiveness of ads served across browsers and devices. This includes measuring interactions with advertisements and advertisers’ websites, apps, and stores by analyzing information such as clicks or other interactions with ads, visits to websites or apps linked to from ads.
  7. Protection of you, ourselves, and others – We may use the information to detect, prevent, investigate and address fraud and other unauthorized or illegal activity.
  8. Support and Inquiry – We may use the information provided to respond to inquiries and to provide customer and user support.

How we protect your information

OfferToro is committed to protecting the privacy of it’s users. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information as outlined above.

The security of your personal information is important to us. When you enter sensitive information to our registration or order forms, we encrypt that information using secure socket layer technology (HTTPS). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Although we use reasonable security to protect your personal information, we cannot guarantee its absolute security.

Sharing your personal information

We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

We may use third-party service providers to help us operate our business and the Site or administer activities on our behalves. We may share your information with these third parties for those limited purposes.

Third party websites

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. Your use of these links, websites, or services may result in the collection, processing or sharing of information about you, depending on what you use. We are not responsible for the content or privacy practices of other websites or services that may be linked on our services. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. Any information you choose to provide to these services, or that they collect, is covered by their privacy policy rather than ours, so please make sure to read it.

Survey Policy

Advertiser surveys - Advertisers have ability to run survey ad offers through OfferToro. If you complete one of those surveys, your responses go to the advertiser (not to OfferToro), and will be governed by the advertiser’s privacy policy.

Information from our advertisers or publishers - the advertisers and publishers using our services may provide us with information they have separately collected about you (for example, whether you already have the app that is being advertised), so that we can improve the relevance of the ads we serve on their behalf (for example, by not showing you an ad for an app because you already have it).

User Profile and Password

If you register as a Publisher, you can update, correct, or delete your user information and email subscription preferences by going to the log in section of the OfferToro and consistent with the other policies and agreements governing your use of the OfferToro Site. Publisher registration information is accessible online only through the use of a password. To protect the confidentiality of your personal information as a Publisher, we recommend that you keep your password confidential.

Advertising

Ads appearing on our site may be delivered to Users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile non personal identification information about you or others who use your computer. This information allows advertisers to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This privacy policy does not cover the use of cookies by any advertisers.

The EU GDPR

The EU General Data Protection Regulation (“GDPR”), effective May 25, 2018 in the EEA countries and Switzerland, requires OfferToro, publishers and advertisers using our services to provide data subjects with information about the processing of personal data. (“Personal data”, as used in the GDPR, means information relating to an identified or identifiable natural person, including name, address, cookie identifiers, mobile device identifiers, and more; “data subject” here means the person involved; and “processing” of data includes collection, storage, and use.). This section provides representations and information in compliance with our GDPR obligations, for the benefit of our users located in the EEA countries.

Legal grounds for processing your personal data

The GDPR requires us to identify the legal ground we’re relying on to process personal data about you. Our legal grounds for processing your personal data as described in this Privacy Policy will typically be because:

  • You provided your consent. To store and access information on your device, we rely on your consent. For this “cookie consent” (which applies not only to “cookies” but also to mobile ad identifiers), to fulfill our obligations under the ePrivacy Directive, we rely on mobile app developers and oblige them contractually to pass on only legally obtained data. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to consent and its withdrawal.
  • The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing personal data to provide our and our commercial partners’ services. A legitimate interest we rely on, for instance, is the tailoring of offers and opportunities to obtain in-game rewards to users of mobile applications and services, which is beneficial to users and offers them a value exchange and goes beyond the original collection of mobile ad identifiers and also includes providing analysis of and reporting about ad campaigns. We also rely on legitimate interest when we use personal data to maintain the security of our services, including fraud detection and identifying and fixing bugs.
  • Contractual Relationships. Sometimes, we process personal data as necessary under a contractual relationship we have, such as our customer records and contact information).
  • Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations

Personal data retention

As a general matter, we retain your personal data for as long as necessary to provide our services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.

If you are a OfferToro advertiser or publisher, we retain your information as long as your account is active and for as long as necessary for legal or operational purposes, such as auditing, corporate record-keeping, compliance, or accounting, after its closure.

Exercising your rights as a data subject

As a data subject covered by the GDPR, you have certain rights about the personal data that data controllers hold about you, including the right of access, right to request correction, right to be forgotten (i.e., deletion), and right to object to processing (including profiling for online ad targeting).

Changes to this privacy policy

OfferToro reserve the right to update (amend) this Privacy Policy from time to time to reflect changes in the law, our data collection, and use practices, the features of our services, or advances in technology. When we do, we will revise the updated date at the top of this page.

If we decide to change our privacy policy, we will post these changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. Any such modifications become effective upon your continued access to and/or use of the website five (5) days after we first post the changes on the website or otherwise provide you with notice of such modifications.

Please check this page periodically for changes and review them carefully, as our use of information at a given point is governed by the Privacy Policy that is then in effect. Your continued use of our services after a Privacy Policy update means that you consent to the updated policy.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Customer Support

To submit a request for OfferToro customer support, you must submit a working email address; this is required for us to be able to communicate with you about investigating and resolving your support issue. Providing this info for support, the user acknowledges and agrees to the terms of use.

Emails and other information submitted for support purposes will only be used for support purposes; depending on the circumstances, this may require us to share your information with the advertiser and publisher whose advertisement and app are involved.

Contacting us

If you have any questions or concerns regarding our privacy policies, please send us a message to support@offertoro.com or publishers@offertoro.com.