CrossInstall Privacy Policy

Effective Date: September 29th, 2020

CrossInstall, a division of Twitter, Inc. and Twitter International Company (“CrossInstall,” “we” or “us”) provides advertising technology services that allow publishers of mobile applications (“apps”) to promote and advertise their apps on other mobile applications. This Privacy Policy refers to the publishers who work with CrossInstall to promote their apps as “Advertiser Partners” and to our technology as the “CrossInstall Platform.” 

We and our Advertiser Partners use the CrossInstall Platform to collect and analyze data to help ensure that the ads you see are relevant to your interests and to measure and report on the effectiveness of ads. 

This Privacy Policy explains how CrossInstall collects, uses, shares, or otherwise processes personal data.

• Section 1 describes how we process personal data about you to serve and personalize advertising on behalf of our Advertiser Partners and how you can exercise control over our processing of your personal data.

• Section 2 describes how we process personal data about you if you visit CrossInstall.com.

• Section 3 describes how we process personal data about you if you are an Advertiser Partner.

The last section covers other important information that applies to all of our personal data processing activities, and explains how you can reach us with thoughts or questions about this Privacy Policy.

Section 1: Personal Data We Process Through the CrossInstall Platform

Personal Data We Collect Through the CrossInstall Platform 

When you use an app that is supported by advertising, that app may share bid requests with its advertising partners, and we collect these bid requests. Bid requests are sets of information that describe an ad space that is available to be filled, and contain information about the ad space, the device on which the ad will be shown, and sometimes the user of that device. Our Advertiser Partners and data providers also share data about you with us to help us better target or analyze their ads.  

The CrossInstall Platform is designed to avoid collecting information such as your name, address, or email address, but the personal data we collect does enable us to recognize your device over time and across apps. Depending on where you live and your privacy choices, the personal data we collect includes:

• Device identifiers such as your IP address, iOS Identifier for Advertising (IDFA), iOS Identifier for Vendors (IDFV), Android Advertising ID, a CrossInstall-specific identifier, and other device identifiers provided by advertising exchanges through which the CrossInstall Platform bids on advertising inventory.

• Your precise geo-location, when location services have been enabled for an app. Note that when you have not enabled location services, we will still infer data about your location based on other signals, such as your IP address.

• Information that an app or one of our Advertiser Partners has collected about you and shared with CrossInstall, such as demographic information (e.g., your age or gender) or information about your interests, to help make the ads served to you more relevant.

• Information about your device, such as the type and model, manufacturer, operating system (e.g., iOS or Android), carrier name, and screen size.

• Information about your app usage, including the version of such apps, the app on your device that is requesting an ad, the start/stop time of your app session, your current time zone, and your network connection type (e.g., WiFi, cellular).

• Information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether you clicked on it, and whether you downloaded an Advertiser Partner’s app.

How We Use the Personal Data We Collect Through the CrossInstall Platform

We use the personal data we collect for the following purposes:

• Serving Ads: Bidding on advertising inventory, and understanding how you interact with those ads (such as whether you download the app being advertised, and whether you make any purchases within that app). 

• Interest-Based Advertising: Inferring what kinds of apps you may be interested in and showing ads to you based on these inferred interests. We do not make any inferences about information that we consider sensitive or are prohibited by law, such as race, religion, politics, sex life, or health.

• Ad Reporting and Conversions: Reporting to Advertiser Partners information about when and how you have been exposed to their ads or clicked on their ads.

• Frequency Capping: Preventing you from seeing the same ad or type of ad too many times.

• Fraud Detection and Prevention: Identifying invalid clicks (or ad queries) and protecting CrossInstall, our Advertiser Partners, and others from fraudulent or illegal behavior.

• Providing and Operating Our Services: Auditing, researching, and analyzing data in order to maintain, protect, and improve the CrossInstall Platform, and to ensure that our technologies function properly.

How We Share the Personal Data We Collect Through the CrossInstall Platform

We share personal data that we collect as follows:

• We may share personal data with our Advertiser Partners related to their respective ad campaigns so that they can understand how users interacted with their ads and the effectiveness of their advertising. 

• We may share personal data with fraud and measurement partners in order to help with anti-fraud, quality, and security efforts to ensure the safety, security, privacy, and accuracy of the CrossInstall Platform and the broader advertising ecosystem.

• We engage service providers to perform functions and provide services to us and our Advertiser Partners in the United States, Ireland, and other countries. We may share the personal data we collect with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that they use your information only on our behalf and pursuant to our instructions.

• We share information within the Twitter family of companies, including our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership. 

Controlling the Processing of Your Personal Data for Interest-Based Advertising

You may opt out of our use of your personal data for purposes of Interest-Based Advertising at any time by using the settings on your device. On iOS version 13 and earlier only, you may opt out by enabling the “Limit Ad Tracking” setting in your iOS settings (precise directions may be different on different iOS versions). On iOS version 14 and later only, you may opt out by disabling the “Allow Apps to Request to Track” setting in your iOS settings (precise directions may be different on different iOS versions). On Android devices, you may opt out in the Google Ads settings within your Android settings by enabling the “Opt out of Ads Personalization” setting (precise directions and name of the setting may be different on different Android versions and OEM Android variants).

California Privacy Disclosures

The California Consumer Privacy Act (“CCPA”) applies to the collection, use, and disclosure of “personal information” of California “consumers” (as those terms are defined in CCPA). Because some of the data processed on the CrossInstall Platform may be considered “personal information” under the CCPA, we are required to make certain disclosures to California consumers.  We will not discriminate against you if you choose to exercise the rights described below. 

Our Collection, Use and Disclosure of Personal Information

In the preceding 12 months, we have collected the following categories of personal information: online identifiers such as device identifiers and IP addresses; internet or other electronic network activity information; geolocation data; and inferences. For details about the precise data points we collect and the categories of sources of such collection, please see the Personal Data We Collect Through the CrossInstall Platform section above. We collect personal information for the business purposes described in the How We Use the Personal Data We Collect Through the CrossInstall Platform section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

We may also share the personal information we collect as described in the How We Share the Personal Data We Collect Through the CrossInstall Platform section above. 

Right to Request Access or Deletion

You may have the right to request that we disclose what information we collect, use, or disclose about you, and/or request the deletion of any of your personal information we collect or maintain, subject to certain exceptions. In order to make a request to exercise these rights, you must fill out and submit the “Data Subject Rights” form. Alternatively, you can email a request to us at CrossInstallPrivacy@twitter.com. When we receive your request, we will request additional information in order to verify your identity. Note that because CrossInstall collects only pseudonymous identifiers and does not collect identifying information such as name, email address, or other identifiers through the CrossInstall Platform, it may be impossible for us to verify your request. You may also designate an authorized agent to make such requests on your behalf. If you do, we will ask the agent to demonstrate that it is acting on your behalf, and we may ask you to confirm that you authorized the agent to act on your behalf and to confirm your identity so that we can process your request.

Do Not Sell My Personal Information  

Under the CCPA, California consumers have the right to opt out of the “sale” of their personal information, as such term is defined in the CCPA. CrossInstall does not sell personal information. 

To opt out of the use of your personal information for purposes of Interest-Based Advertising, please follow the instructions in the Controlling the Processing of Your Personal Data for Interest-Based Advertising section above. 

European Economic Area, the United Kingdom and Switzerland

Legal Basis for Processing

If you are located in the European Economic Area, the United Kingdom, or Switzerland, apps that would like us to serve you Interest-Based Advertising must first obtain your consent so that CrossInstall may process your personal data for this purpose.  You can withdraw your consent to Interest-Based Advertising at any time by following the instructions in the Controlling the Processing of Your Personal Data for Interest-Based Advertising section above. 

We may also process your personal data on the following lawful bases:

• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain and improve our products and services, to detect and prevent fraud, to count impressions and app installations, to conduct data analytics, or to optimize the CrossInstall Platform).

• To comply with legal obligations to which we are subject.

Data Retention

We store the personal data we collect for as long as is necessary to carry out for the purpose(s) for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Your Access and Deletion Rights

You may have the right to request that we disclose what information we collect, use, disclose or sell about you, and/or request the deletion of any of your personal information that we collect or maintain, subject to certain exceptions. In order to make a request to exercise these rights, you must fill out and submit the “Data Subject Rights” form. Alternatively, you can email a request to us at CrossInstallPrivacy@twitter.com. Note that because CrossInstall collects the minimum amount of personal data about you that is necessary to provide the CrossInstall Platform and does not collect identifying information such as name, email address, or other identifiers through the CrossInstall Platform, we generally will not have sufficient information available to provide secure, authenticated access to the personal data that we store about you or to confirm that specific personal data relates to you. 

Children

CrossInstall does not permit the CrossInstall Platform to be used to collect information from apps directed to children under the age of 13 for purposes of Interest-Based Advertising. We may collect information from apps directed to children for other purposes, such as serving advertisements based on contextual information, like the content or type of app being used (for example, serving an ad for a video game to a gaming app).

In addition, if you live in the European Economic Area, the United Kingdom, or Switzerland, you must be at least 16 years of age to consent to Interest-Based Advertising. CrossInstall does not collect or otherwise process personal data from individuals in the European Economic Area, the United Kingdom, and Switzerland whom it knows to be under 16 years of age, except to comply with law or to support our legitimate interests as described above.

Section 2: Personal Data We Process When You Visit CrossInstall.com

Personal Data We Collect When You Visit CrossInstall.com

When you visit CrossInstall.com, our servers automatically record certain personal data in our log files. This web log information includes your IP address, browser type, operating system, the referring web page, pages visited, and cookie information. Like many websites, we use web log information, along with cookies, pixels, and similar technologies, to operate our websites, better understand how they are used, resolve technical problems, and enhance your experience on our site.

Cookies are small files that websites place on your computer as you browse the web. A pixel is a small amount of code on a web page and is often used in connection with cookies. Most web browsers automatically accept cookies. In many cases you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. However, some features of our site may not function properly if you disable cookies.

Personal Data We Share When You Visit CrossInstall.com

We use a variety of third-party services, such as Google Analytics and Squarespace Analytics, to help operate and understand the use of our website. We may share personal data, such as cookie information, with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures.

Section 3: Personal Data We Process If You Are an Advertiser Partner

Personal Data We Collect From Advertiser Partners

If you are an Advertiser Partner, you will be asked to provide certain personal data, including your name, email address, physical address, phone number, and company name. You may be asked to provide additional personal data such as a username and password to register for a CrossInstall account. This information is used to provide our services and to send information about the services. 

We will also collect any information you provide to us, such as when you request more information about our services. We will use this information to respond to your request. To opt out of receiving promotional information, please follow the unsubscribe instructions in any of our promotional emails.

We will also collect web log information when you use our website, as explained in Section 2.

Accessing or Rectifying Your Personal Data as an Advertiser Partner

We provide you with account tools to access, correct, or modify personal data you have provided to us in association with your account. If you wish to delete your account, you may request to do so by emailing us at CrossInstallPrivacy@twitter.com. Unless we have another legal basis to store your personal data, such as compliance with tax or accounting laws, we will delete or de-identify the personal data we have stored about you upon your request to delete your account.

Personal Data We Share and Disclose About Our Advertiser Partners

We may disclose personal data about you when necessary to provide our services, such as for account inquiries or verification. We may also share information within our corporate family to provide, understand, or improve their or our services.

California Privacy Rights

If you are a California consumer and an Advertiser Partner, these additional disclosures apply to you. In the preceding 12 months, we have collected the following categories of personal information: identifiers such as your name, email address, and device identifiers and internet or other electronic network activity information. For details about the precise data points we collect and the categories of sources of such collection, please see the Personal Data We Collect From Advertiser Partners section above. We collect personal information for the business purposes described above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

We do not sell the personal information we collect from Advertiser Partners. You may have the right to request that we disclose what information we collect, use, or disclose about you, and/or request the deletion of any of your personal information that we collect or maintain, subject to certain exceptions. In order to make a request to exercise these rights, you may email us at CrossInstallPrivacy@twitter.com.   

Other Important Information

Law, Harm, and the Public Interest

Notwithstanding anything to the contrary in this Privacy Policy or controls we may otherwise offer you, we may preserve or disclose information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the rights or safety of any person; to address fraud, security or technical issues; or to protect the rights or property of CrossInstall, our Advertiser Partners, or others.

Change of Ownership

In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal data may be transferred as part of that transaction. This Privacy Policy will apply to your personal data as transferred to the new entity.

Additional Information or Assistance

Thoughts or questions about this Privacy Policy? Please, let us know by contacting us at CrossInstallPrivacy@twitter.com or writing to us at the appropriate address below.

If you live in the United States, the data controller responsible for your personal data is Twitter, Inc. with an address of:

Twitter, Inc. Attn: Privacy Policy Inquiry 1355 Market Street, Suite 900 San Francisco, CA 94103

If you live outside the United States, the data controller is Twitter International Company, with an address of:

Twitter International Company Attn: Data Protection Officer One Cumberland Place, Fenian Street Dublin 2, D02 AX07 IRELAND

If you are located in the European Economic Area or EFTA States, you can confidentially contact Twitter’s Data Protection Officer here. If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority or Twitter International Company’s lead supervisory authority, the Irish Data Protection Commission. You can find their contact details here.

Our Global Operations and Privacy Shield

To bring you our services, we operate globally. Where the laws of your country allow you to do so, you authorize us to transfer, store, and use your data in the United States, Ireland, and any other country where we operate. In some of the countries to which we transfer personal data, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those of your country. Learn more about our global operations and data transfer here.

When we transfer personal data outside of the European Union or EFTA States, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws, contractual obligations placed on the recipient of the data (model clauses may be requested by inquiry as described below), or EU-US and Swiss-US Privacy Shield principles.

CrossInstall complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. CrossInstall has certified to the Department of Commerce that it adheres to the Privacy Shield Principles as described in our  EU-US Privacy Shield certification and Swiss-US Privacy Shield certification. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. 

If you have a Privacy Shield-related complaint, please contact us at CrossInstallPrivacy@twitter.com. If you do not receive a timely acknowledgment of your complaint, or if you cannot resolve your complaint directly with CrossInstall, you can contact the independent dispute resolution body JAMS, and under certain conditions, through the Privacy Shield arbitration process.   

Under certain conditions, individuals may be able to invoke binding arbitration before the Privacy Shield Panel jointly created by the U.S. Department of Commerce and the European Commission. CrossInstall is subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to its compliance with the EU-U.S. Privacy Shield Framework. If a third party processes personal data on behalf of CrossInstall in a manner inconsistent with the Privacy Shield Principles, CrossInstall could be liable unless CrossInstall can prove that it is not responsible for the event giving rise to any damage.

Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our processing of your personal data and will be posted at https://www.crossinstall.com/privacy. If we make a change to this policy that, in our sole discretion, is material, we will notify you via a banner on this website or, if you are an Advertiser Partner, an email to the email address associated with your account.