Last updated: 2019/06/05
CrossInstall is a mobile advertising company that creates and deliver advertising on behalf of other companies. Our technology enables our partners to show mobile application users more relevant advertising that is based on users’ interest in applications. In order to provide these services, we collect and use certain information about user activity in mobile applications.
CrossInstall remains committed to protecting user privacy and complying with the legal requirements of all regions we operate in.
If we make any material changes we will notify you by means of a notice on this site. Any changes or modifications will be effective immediately upon posting.
COLLECTION OF PERSONAL DATA AND LAWFUL BASIS FOR PROCESSING
Like most ad platforms, CrossInstall collects Personally Identifiable Information (PII) for the purposes of delivering targeted and relevant advertisements to mobile app users. The PII we have access to are limited to:
Your IP address
Your mobile device identifiers such as the ID for Advertising for iOS (IDFA), Google Advertising ID or similar mobile identifiers
We do not have access to your name, your home address, your place of work, your date of birth, your telephone number, your social security number, your passport number, your driver’s license number, or your credit card numbers.
Additionally, CrossInstall collects Personal Data related to your activity on your mobile device:
A partial list of apps that have published ads through our network
A partial list of apps that were installed as a result of ads displayed through our network
Some of your interactions within an app (e.g. in-app purchases, registration)
Some information regarding which advertisements you have seen and/or interacted with
How we use your information
We process your Personal Data to enable targeted advertising on the applications that we support.
On certain occasions, we process your Personal Data when it is necessary for the performance of a contract to which you are a party, such as to provide services to you.
We may also process your Personal Data to respond to your inquiries concerning our products and services.
On other occasions, we process your Personal Data where required by law. We may also process your Personal Data if necessary to protect your interests or the interests of a third party.
Finally, we process your Personal Data when necessary to do so for fraud prevention, improving our network and services, and marketing our services to advertisers and publishers; where these interests are not overridden by your data protection rights.
You have the right to withdraw your consent to processing of Personal Data at any time.
How we share your personal information and who we share it with
We do share your personal information (as described in the "COLLECTION OF PERSONAL DATA AND LAWFUL BASIS FOR PROCESSING" section above) with our customers (advertisers and the attribution company of their choice, when applicable) whose ads have been rendered on your device. The purpose of sharing the personal information is to assist with fraud prevention, install attribution and auditing, which are required to perform the Services we provide. Our advertising partners may combine your personal information with other information that you’ve provided to them or that they’ve collected from your use of their services.
You have the right to withdraw your consent to processing of Personal Data at any time.
Opt-Out from Interest-Based Ads From All Providers
Your mobile device provides a easy way to disable interest-based ads from all providers:
Go to your iPhone's settings app.
Scroll to the Privacy section.
In Privacy, scroll down to the Advertising section.
Slide the "Limit Ad Tracking" to on.
Go to your Android's Settings.
Select Accounts & sync (the name of this may vary depending on your particular Android device).
Find Google, then tap Ads.
Check the box next to "Opt out of interest-based ads".
We do not knowingly collect personal information from children under the age of 16 through our advertising services and through this site.
Specific Provisions for EU Individuals
If you are located in the European Union the following provisions apply to you.
GDPR compliance at CrossInstall
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a European Union regulation law on data protection and privacy for all individuals that reside within the European Economic Area (EEA). The GDPR enforcement goes into effect May 25, 2018.
CrossInstall does not record nor process PII of the citizens of countries that belong to the EEA unless we receive explicit consent to do so from the user via our partners. When consent is not provided, we do not rely on PII to personalize and optimize our advertising, and we do not store the PII on our servers.
International Data Transfer
CrossInstall is headquartered in the United States and its platform process personal data of users in the EEA. Therefore, CrossInstall will process personal data that originates from the EEA on its servers and facilities in the United States.
The GDPR replicates the Data Protection Directive restrictions on transferring data outside the EEA. Transfers are permitted only if certain safeguards are in place, such as by self-certifying to the EU-US Privacy Shield. Accordingly, CrossInstall is in the process of certifying to the EU-US Privacy Shield to protect all transfers of non-HR European data to CrossInstall in the US.
Privacy Shield Framework
The United States Federal Trade Commission (FTC) is the enforcement authority with jurisdiction over this compliance with the Privacy Shield.
In compliance with the Privacy Shield Principles, CrossInstall commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CrossInstall at:
As an individual in the EEA, you may be entitled:
To request access to the personal data we hold about you;
To request that we rectify or erase your personal data;
To request that we restrict or block the processing of your personal data;
Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
How to access your information?
Fill out and submit the “Data Subject Rights” form. We’ll honor your request by sending you the information we collected about you within 45 days.
How to opt-out of future data collection by CrossInstall?
Fill out and submit the “Data Subject Rights” form. We’ll honor your request within 45 days.
Note: if you reset your mobile device identifier, you will need to send us another message to opt-out again.
Dispute Resolution and Arbitration
If you reside within the EU or Switzerland, any inquiries or complaints regarding CrossInstall’s compliance with the Privacy Shield program should be sent to the CrossInstall’s email set forth above. CrossInstall will respond within 45 days.
If you do not receive timely acknowledgment of your complaint, or if you cannot resolve your complaint directly with CrossInstall, you can contact the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR/AAA), by visiting its web site at http://info.adr.org/safeharbor. CrossInstall has engaged the ICDR/AAA as an independent dispute resolution provider to address unresolved Privacy Shield complaints.
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.
Federal Trade Commission Enforcement
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.
Disclosure Requests by Public Authorities
CrossInstall may be required to disclose your personal data in response to a lawful request by public authorities, including to meet national security or law enforcement requests.
Onward Transfer Liability
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.
DISTRIBUTION OF INFORMATION
We may share information with governmental agencies or other companies assisting us in fraud prevention or investigation. We may do so when: (1) permitted or required by law; or, (2) trying to protect against or prevent actual or potential fraud or unauthorized transactions; or, (3) investigating fraud which has already taken place. The information is not provided to these companies for marketing purposes.
COMMITMENT TO DATA SECURITY
Your personally identifiable information is kept secure. Only authorized employees, agents and contractors (who have agreed to keep information secure and confidential) have access to this information.
Data Protection Officer
650 California St, Floor 30
San Francisco, CA 94108
Please be sure to include your name, address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.