Privacy Policy

Updates 5.25.18
MediaWallah, LLC (hereinafter “MediaWallah”,” “we,” “us,” “our”) respects each person’s right to privacy. This Privacy Policy explains the ways in which we collect information and maintain and use that information.

Our Services
Mediawallah provides data connectivity services designed to enable our clients to reach consumers with greater efficiency and more relevant messages across various digital channels, including online, mobile and addressable TV.  Through our data connectivity services we establish anonymous user connections between devices, browsers, apps and events.

We do not incorporate Personal Information in data we provide to our clients.

Information We Collect
In order to establish connections between devices, browsers, apps and events to provide insights and reporting to partners, and to provide more relevant ads to users, we collect and store select information about devices directly from the device. We may also receive additional information about the device or the individual from partners with an existing relationship with the individual or from other third parties (as specified in the section below “What may be collected by MediaWallah”)

The technologies we use to collect information include browser cookies, pixels, application software development kits (SDKs), or server-to-server connections with our partners and clients.

A cookie is information that is stored on your computer that can uniquely identify your browser. Cookies may be stored for different periods of time depending on how they are used. “Session cookies” store information that is only relevant for your current activity and are no longer accessible after you shut down your browser. “Persistent cookies” remain after you close your browser and may be accessed by your browser on subsequent visits. When you visit our Websites, both session and persistent cookies may be transferred to your device. Your browser may allow you to refuse or remove some or all of these cookie technologies. For specific instructions, please consult the manufacturer of your Web browser software.

A pixel is a piece of code which is used on a website you review or email messages you receive to allows  our clients, partners and us to record non-personally identifiable information ( as specified in the section below “What may be collected by MediaWallah”).Pixels are also known as “web beacons” or “tracking tags.” We may collect information (as specified in the section below “What may be collected by MediaWallah”) about select user behavior (e.g., when a user opens an application or interacts with that application) in an application on behalf of that partner. In this case, we may use an application SDK or a server-to-server connection with our partners to collect that information. An application SDK is a library of code that is embedded directly in partner applications.

We may also use a server-to-server connection to exchange the same data when an SDK integration is not feasible or practical for the partner. While MediaWallah uses these technologies to track select activities within an application, including whether or not the user is accessing certain pages or features or is responding to marketing messages, MediaWallah does not track the emails a user sends or the individuals a user communicates with, or any sensitive financial or health related data.

We may also collect information (as specified in the section below “What may be collected by MediaWallah”) when we receive ad requests from our partners. In this case, we may use an application SDK or a server-to-server connection with our partners to collect that information.We use these technologies across platforms including websites, mobile applications, emails and TV applications so that we provide the best data connectivity service possible. Examples of how we deploy these technologies include: (1) when an ad is deliver and (2) when we integrate with our partners’ websites, newsletters and applications. We do not use “zombie cookies” or “history sniffing.”

We do not use local storage and flash cookies.What may be collected by MediaWallah for Data Connectivity Service:Time stampUser agent string that specifies device and browser informationIP addressUnique device identifier stored in a browser cookieMobile ad identifiers Web page or application where an ad may be placedWeb page or application that the individual is using when a MediaWallah pixel firesAnonymous data that can be extrapolated from an IP address. For example, we may be able to determine a user’s general location and therefore infer demographic information.Obfuscated user identifier, such as email address

What is not collected by MediaWallah for Data Connectivity Service:
Name
Address
Phone number
Password
Sensitive personal data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health and information about sex life.

We do not use or permit our customers to use precise location data, such as your exact location at any given time, to connect devices, to infer user interests for online behavioral advertising (which we define to mean advertising to consumers based on activities across websites or apps over time), or to deliver advertisements to you at a precise location (which we define to mean an area with a radius of less than one half mile), without your express consent to MediaWallah.

MediaWallah also receives “User Matching IDs” from partners and clients for the purpose of helping our partners and clients understand which of their existing customers or otherwise known IDs match specific IDs to enable our Data Connectivity Service. User Matching IDs may represent underlying, customer IDs, cookie IDs, obfuscated email addresses or other types of data to the partner or client, but MediaWallah never receives this information in a form that is identifiable to MediaWallah.

We require that partners and clients obscure and protect all User IDs before sending them to us, such that the underlying data is either meaningless to Mediawallah, as is the case with a 3rd party cookie ID where MediaWallah has no matching table, or is encrypted such that MediaWallah has no ability to access the underlying data.

Opting Out
There are several ways you can opt-out of MediaWallah data collection for our customers:

CookiesBlock all cookies: Block all cookies by disabling cookie use in your browser. This may cause some websites to work incorrectly.

MediaWallah Opt out cookie: Opt out by accepting a cookie which tells the MediaWallah system not to uniquely track your web browsing. Click here to opt out now. If you change computers or browsers, or use multiple computers or browsers or delete your cookies, you will need to repeat this process for each computer and in each browser.

Mobile Ad Identifiers
Block all mobile ad identifiers: please adjusting your advertising preferences on your mobile device.  For example, to adjust your advertising preferences in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads.  

Industry Opt-Outs
MediaWallah adheres to the Network Advertising Initiative (NAI)  code of conduct. You may use the NAI opt out tool http://www.networkadvertising.org/choices/.

We also support the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You can visit the DAA opt-out page here: http://www.aboutads.info/choices/ to block all cookies and you can download the DAA’s AppChoices tool for your mobile operating system to block all mobile ad identifiers.

Policy Regarding EU Data, Protection & Security
It is our policy to not accept any data where an individual resides in any EU member country including the UK. MediaWallah has a through process to ensure this doesn’t happen.We perform scans on all data that we ingest, from websites, partners and clients, to identify its origin. Any data originate in any EU member country including the UK is flagged and not collected or stored. MediaWallah also regularly audits its database to remove any data that is found to originate in any EU member country including the UK, which might has not been flagged in our screening process.Finally, we all require our websites, partners and clients to contractually to comply with GDPR.Through this process, MediaWallah fulfills its obligation stemming from the ePrivacy Directive.

Data Storage and Security
We retain the browser and in app information we collect for up to one year. After one year, we discard the information about individual users and retain only aggregated or summary data.  Every time our technology collects new data about a user or a client uploads or changes a customer record, this one-year counter begins again. We retain aggregated data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Even though we maintain the data we collect in an anonymous way, we work hard to ensure the integrity and security of our information systems, no method of transmission or safeguard is impenetrable and or could be compromised.  Therefore, we cannot and do not guarantee the security of any information we collect.

Children
We are committed to protecting the online privacy of children. In accordance with the Children’s Online Privacy Protection Act, we will not knowingly collect any personally identifiable information from or provide any services to children under the age of 13. Unfortunately, we cannot always determine the age of a visitor to our site or the sender of an email. If for some reason we learn that a user is under 13 years of age and we can identify personal information relating to such a user, we will take steps to delete such information promptly.

Disclosures of Information We Collect
Some of our websites, partners and clients may place their own cookies on your Internet browser outside of our service; however, we have no access to or control over these cookies.

Our Website
Our site is intended to offer information about MediaWallah and our services to the companies we serve. We use information from our website log files to understand how visitors use our website and to recommend future website improvements. If you choose to submit personal information, we may use that information for general marketing purposes and to notify you regarding updates to our products and services. We do not sell, rent, share, or otherwise dispose of the personal information collected to third parties for their marketing purposes. Once collected, we will store your information for a reasonable time for record-keeping purposes. To opt out of receiving MediaWallah targeted advertising, you will need to visit this site.

Changes to Our Privacy Policy
From time to time we may make changes to our Privacy Policy. Any changes to our Privacy Policy will be posted on this page.

Contacting MediaWallah
If you have any questions or concerns about our collection, use, or disclosure of your personal information, please email us at privacy@mediawallah.com, or, please write to us at:

Privacy
MediaWallah, LLC
100 Park Ave16th Floor
New York, NY  10017