Chinar Libertas is a mobile advertising company that provides mobile application developers, brands, and advertising agencies “Customers” with a service to deliver advertising to users on their mobile devices “end Users”. In order to best deliver advertising to these end Users, we collect and may use certain information about these end Users to target the most relevant advertising.
Our Commitment to Your Privacy
Chinar Libertas PTE LTD. (“Chinar Libertas/ Clibertas”) is committed to respecting the privacy rights of its customers, visitors, and other users of the website located at www.clibertas.com (the “Site“) or of any software or services provided by Chinar Libertas (collectively, the “Service“) and end-Users that may be served advertising by Chinar Libertas in mobile applications and sites by Chiner Libertas on behalf of our Customers. Below is a summary of the personally identifiable information (“Personal Data“) and other information that is collected from or about Customers, visitors and other users of the Service and our policy regarding the use and disclosure of that Personal Data, and the measures we take to safeguard that Personal Data.
This Policy is only applicable to the Service, and not to any other third-party websites or services that you may be able to access from the Site, each of which may have data collection and use practices and policies that differ materially from this Policy. This Policy also explains how you can contact us if you have a question about, or want to exercise any of, your legal rights in respect of any of your Personal Data that Chinar Libertas may be processing.
We will only collect and use Personal Data in accordance with applicable data privacy law, in particular, where:
we have lawful grounds to do so, including to comply with our legal obligations;
we are performing a contract with you for our Services; and
we have legitimate interests in using your Personal Data and your interests and fundamental rights do not override those interests.
For the purposes of the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR“), we are “data controller” in respect of Personal Data that we collect and use for the purposes of providing the Service. In certain cases, where we are carrying out services on behalf of our Customers, we also act as “data processor”.
This policy is effective as of May 15, 2019.
As part of the Service we offer to our Customers, we may collect Personal Data as well as process Customer-provided end User data for the purposes of carrying out our Service. This section shall cover policies related to both of these areas.
INFORMATION COLLECTION PRACTICES
INFORMATION COLLECTED BY CHINAR LIBERTAS
In operating the Site and providing the Service, Chinar Libertas may collect certain information, including without limitation the following:
When you register for the Service, Chinar Libertas may ask you for Personal Data including but not limited to your name, business name, business address, phone number, e-mail address, contact preferences, and billing information. We use this Personal Data to remain in contact with you about your use of Chinar Libertas Services and for the purposes of billing. We may retain your Personal Data after you cease to use Chinar Libertas Services for our accounting and business records.
AUTOMATICALLY COLLECTED INFORMATION
1. Our servers automatically recognize information that your browser sends whenever you visit a website, which may include information such as the domain names and Internet Protocol (IP) addresses of visitors to the Site, as well as the browser type and the date and time of the browser’s access to the Site. No Personal Data about you is revealed in this process and we generally treat information collected by such process as non-personal data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Data by applicable law, we treat these identifiers as Personal Data.
2. The Site may also gather anonymous “traffic data” that does not personally identify you, but that may be helpful for marketing purposes or for improving the services we offer.
3. Chinar Libertas uses services to capture session usage of some areas of the site to assist with Customer troubleshooting and learn about Customer usage of the Site to help us make decisions about product improvements. Session captures are limited to select areas of the Chinar Libertas site only and do not record any other browser or computer activity. As part of session information we collect account, IP, and browser and operating system data. We do not capture any password inputs.
When you send email or other communications to Chinar Libertas, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
RETENTION OF INFORMATION
Chinar Libertas will retain your Personal Data for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. We review the Personal Data we hold at regular intervals and delete permanently or anonymise any Personal Data which is no longer necessary.
USE AND SHARING OF INFORMATION
- PERSONAL INFORMATION
- ANONYMOUS INFORMATION
We use anonymous information to analyze our Site traffic, but we do not examine this information for Personal Data. In addition, we may (subject to “AUTOMATICALLY COLLECTED INFORMATION” above) use anonymous IP addresses to help diagnose problems with our servers, to administer our Site, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis.
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WEBSITE AREAS BEYOND CHINAR LIBERTA’S CONTROL
The Site may include interactive forums such as bulletin boards and blogs. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your Personal Data. Chinar Libertas will not be liable for any disclosure of your Personal Data or other information as a result of your use of any such public forums, that you display publicly or that becomes publicly known as a result of your actions.
THIRD PARTY WEBSITES
The Site may contain links to other websites. If you choose to visit any other websites other than the Site, we will not be responsible for the privacy practices or content of those other websites, and you shall bear all risk of access to such websites. It is solely your responsibility to review the privacy and usage policies at those websites and confirm that you understand and agree with their policies.
USE AND SHARING OF CUSTOMER PROVIDED INFORMATION FOR CHINAR LIBERTAS SERVICES
A Customer may provide Chinar Libertas with information about end Users for the purposes of advertising to those end Users through Chinar Libertas services. This information is passed to Chinar Libertas via the Customer, either directly or through a technology partner of the Customer. The Customer is responsible for requesting permission to use personal data from end Users for such purposes.
WHAT DATA WE RECEIVE
We receive mobile device advertising identifiers, such as Android GAID and iOS IDFA. We do not receive or store any other Personal Data on end Users from our Customers.
HOW WE USE THIS DATA.
When buying media on behalf of our Customers, if we are able to buy an advertising opportunity (Impression) that matches a mobile advertising identifier of one of our Customer’s end Users we may show that end User an ad from that Customer. Not all impressions served to an end User on one of our Customer end User lists may be targeted for that end User. The end User may be served advertising from Chinar Libertas that is not specifically targeted to their mobile advertising identifier.
Our technology and how we collect information on end Users. End Users are those that may be served advertising from Chinar LIbertas on behalf of our Customers.
In providing services to our Customers, we collect information to identify end Users’ interests and activity in mobile applications. We use this information to determine what advertising we think may be most relevant to an end User to serve them the most relevant ad opportunity from our Customers. To identify end Users we use mobile device advertising identifiers, such as Android GAID and iOS IDFA, and IP information. The information we collect on end Users is provided via the mobile app or site owner to Chinar Libertas via technology partners we are integrated with that enable the buying and selling of advertising opportunities, such as banners and videos.
In addition, some of our Customers may utilize the Chinar Libertas platform to engage in re-targeting or re-engagement activities. Retargeting and re-engagement is when an advertiser (our Customer) wants to advertise to an end User that may already be using, have used, or expressed interest in their product or service. Our Customers, in their relationship with this end User/s may request and collect some personal identifier and then may provide this information to Chinar Libertas in order to retarget or re-engage the end User. The Customer will provide a mobile device advertising identifier only, such as an Android GAID or iOS IDFA to Chinar Libertas for the about consumers they are interested in reaching via advertising and the Customer is responsible for obtaining consent to use personal identifying information from the end User before providing to Chinar Libertas. As an end User you can manage the use of your device identifier for such activity by reaching out directly to the advertiser, our Customer. You can also opt out of all targeted Chinar Libertas advertising as outlined below.
Chinar Libertas has implemented and maintains administrative, technical and physical security measures to help prevent unauthorized access, disclosure, loss, theft, misuse, destruction and alteration of Personal Data, Customer provided end User information, but we cannot guarantee that such measures will prevent any unauthorized access, disclosure, loss, theft, misuse, destruction or alteration of Personal Data or Customer end User information. Chinar Libertas will notify affected parties of any suspected or confirmed unauthorized access, disclosure, loss, theft, misuse, destruction or alteration of your Personal Data or Customer end User information to the extent required by and in accordance with applicable state and federal laws. We may attempt to notify you so that you can take appropriate protective steps, or we may post a notice on the Site if a security breach occurs.
DISCLOSURE AND SALE OF PERSONAL INFORMATION
LEGAL DISCLOSURE OF PERSONAL INFORMATION
Without limitation to the foregoing, we may disclose Personal Data if required to do so by law or in the good-faith belief that such action is necessary to
(i) satisfy any applicable law, regulation, legal process or enforceable governmental request,
(c) detect, prevent, or otherwise address fraud, security or technical issues, or
(d) protect against harm to the rights, property or safety of Chinar Libertas, its users or the public as required or permitted by law.
SALE OF INFORMATION
In order to accommodate changes in our business, we may sell, buy or otherwise transfer portions of our company or other companies or assets, including the information collected through this Site. In the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or substantially all of the assets of Chinar Libertas, user information (including Personal Data) will be one of the assets transferred to the transferee.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
Our headquarters are located in the United States. Accordingly, if you are an EU citizen/resident in the EU, please note that we may transfer your Personal Data to our data centers located in the United States, in accordance with EU data protection law requirements. Such a transfer may be necessary in order to perform a contract with you for the Service or to fulfil your requests and/or through obtaining your consent. In other cases, we may use standard contractual clauses that have been approved by the European Commission.
YOUR RIGHTS IN RESPECT TO YOUR PERSONAL DATA
If you are an EU citizen and reside in the EU, or are non-EU national residing in the EU, you may have the following rights with respect to the Personal Data you provide to us or we collect from you when you use the Service, to the extent permitted by applicable data protection laws:
To see what Personal Data we hold about you (if any), including why we are holding it and who it could be disclosed to;
- To have your Personal Data rectified;
- To have your Personal Data erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there is no other legitimate grounds for processing it or you consider it has been unlawfully processed;
- To have the processing of your Personal Data restricted if you contest its accuracy, its processing is unlawful, we no longer need it but you need it for a legal claim, or you have objected to its processing and await verification of our legitimate grounds for processing it; and
- To withdraw any consents you have given us to the processing of your Personal Data.
You can exercise these rights at any time by contacting us by email at firstname.lastname@example.org. You also have the right to complain to your national data protection regulator if you feel that your Personal Data has been unlawfully processed.
CALIFORNIA NOTICE AND PRIVACY RIGHTS
We do not sell personal information, and we have not sold personal information since January 1, 2020, the date the CCPA went into effect. We also do not rent, sell, or share personal information (as defined by California Civil Code §1798.83) about you that we collect on the Services with other people or unaffiliated companies for their direct marketing purposes, unless we have your permission.
If you are a California resident under the age of 18 and you wish to remove publicly available content or information posted by you on the Services, please contact us at email@example.com The removal described in the proceeding sentence does not ensure complete or comprehensive removal of the content or information you posted.
A California consumer has the following rights: to request additional information about our data collection, use, disclosure, and sales practices in connection with the consumer’s personal information; to request the specific personal information collected about the consumer during the previous 12 months; and to request the deletion of the personal information we have about the consumer. A California consumer may not be discriminated against for exercising the consumer’s California privacy rights.
To make a request, you may email us at firstname.lastname@example.org In most cases, you will be required to provide your name, email address and in some cases additional information may be required.
Please note that, when you make a request, we may require that you provide information and follow procedures so that we can verify your identity (and the applicable jurisdiction). The verification steps we take may differ depending on the request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so. We will respond to your request within the 45-day time period required by applicable law. However, we may not always be able to fully comply with your request, and we will notify you in that event.
CONTACT INFORMATION AND POLICY UPDATES
If you have any questions about this Policy, or our practices related to this Site, please feel to contact us at email@example.com.
UPDATES AND CHANGES
Chinar Libertas PTE LTD
20 Collyer Quay, #0 9-01, Singapore 049319, Singapore.