TRESENSA TECHNOLOGIES, INC.
EFFECTIVE AS OF MAY 10, 2021
Natural persons located in the European Economic Area (“EEA”) should review the General Data Protection Regulation (“GDPR”) privacy notice for their specific rights, remedies, and other GDPR -related information here.
Important Notice to Non-U.S. Residents
The Playable Ads and Website and its servers are all operated in the United States and elsewhere. If you are located outside of the United States, please be aware that any information you provide to us and/or that we collect from you, including personal information, will be transferred from your country of origin to the United States. We are certified under the EU-US Privacy Shield Framework and continue to comply with its requirements. Except in the case of data transfers under the Swiss-U.S. Privacy Shield Framework or the Standard Contractual Clauses (as described in the GDPR Notice linked above), your decision to provide such data to us, or allow us to collect such data it through our Website or services, constitutes your consent to this data transfer.
Children’s Online Privacy Protection Act
Our Playable Ads are for general audiences and are not directed to children under the age of 13. We do not knowingly collect personal information from children under the age of 13.
What Information We Collect, The Purpose Of Collection And Use
Contact Information: We collect contact information through the email contact on our Website from visitors and customers who wish to obtain information or support. Such contact information primarily includes first name, last name, e-mail address, and other information necessary for us to properly respond (collectively, the “Contact Information”). This Contact Information is used by our sales, support, and product teams to contact our Website visitors and customers for the purpose of providing the required information or support and/or providing our services.
Other Information: In addition to the Contact Information, we may collect or receive the following information:
- From Your Activity on Our Website, With Our Playable Ads, and When We Serve You Playable Ads: In an ongoing effort to improve the Playable Ads and the Website and provide quality services to our advertiser clients and Platform partners, we automatically collect certain information when end-users are served and engage with the Playable Ads (through Mixpanel and internally) and when visitors visit the Website (through Google Analytics). This information generally consists of: Browser type, language, and version; Referring and exit pages and URLs; information about the application that served the Playable Ad; Date and time; Playable Ad interaction information, such as the amount of time spent on particular portions of the Playable Ad, scores, and other performance and usage data; Type of device; Advertising Identifier (“IDFA” or “AdID”); Operating system or and version (e.g., iOS, Android or Windows); Carrier; Geo-location; and Network type (WiFi, 3G, 4G, LTE).
- From Our Advertisers and/or Their Service Providers: In order to help us provide better services and receive proper attribution or credit for the services we provide, we may receive other information from our advertisers and/or their service providers (e.g., data management platforms, attribution providers, etc.) such as advertising identifiers and post-engagement data (e.g., conversions, actions taken on target site or app).
Local Shared Objects: Local shared objects may also be stored on your computer or device (via Mixpanel and internally) when engaging with our Playable Ads in order to collect the data listed in Other Information (e.g., interaction with the Playable Ad, score obtained, click-throughs). Local shared objects operate like cookies, but are not always managed in the same way. Depending on how local shared objects are enabled on your computer or device, you can manage, clear, or disable them via browser or app settings. For more information on Mixpanel (including opt-out information), please visit https://mixpanel.com/legal/privacy-policy/.
The Information Collected by or Through Third-Party Advertising Companies
In connection with the Playable Ad, neither we nor any third party acting on our behalf employs behavioral advertising or retargeting in connection with users whom we know to be under 13 years old.
How to Opt Out of Interest-based Advertising
TreSensa does not serve ads to you based on your personal characteristics besides, at most, high-level interests. You can use your device settings to opt out of interest-based advertising from us by following the instructions below.
iOS Go to your Settings > Select Privacy > Select Advertising > Select “Limit Ad Tracking”.
Android Go to your Settings > Select Services > Select Ads > Select “reset advertising ID”
Data Analysis and Sharing
We may analyze the Other Information in order to operate, maintain, manage, and improve the Playable Ad, the Website, the Platform, and/or the marketing services we provide to our advertisers. This information does not identify you personally. We may share this information with the Platform on which you are playing the Playable Ad and also with our advertiser clients, affiliates, agents, and business partners. We may also disclose anonymized and aggregated user statistics in order to describe our products, the Playable Ad, and the Platform to current and prospective business partners and to other third parties for other lawful purposes.
Onward Transfer to Third Parties
Disclosure to Public Authorities
We may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
How We Protect Your Information
We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
Opt-Out for Direct Marketing; Email Management
You may opt out at any time from the use of your personal information for direct marketing purposes by contacting us at Privacy@TreSensa.com. Please allow us a reasonable time to process your request.
You may manage your receipt of automated marketing and non-transactional communications by clicking on the “Manage Email Preferences” link located on the bottom of any TreSensa marketing email and following the instructions found on the page to which the link takes you. You cannot opt out of receiving transactional e-mails related to their account or purchase orders. Further, you may always reach out to Privacy@TreSensa.com in cases where you no longer wish to receive emails from the TreSensa team personally (or respond directly within such email).
Retention of Personal Information
If you are a resident of California, legislation in your jurisdiction – such as the California Consumer Protection Act (“CCPA”) affords you certain specific data protection rights, as noted below. If you make a request, to protect your privacy and security, we will take steps to verify your identity and requests before granting the rights set forth herein.
CCPA rights (California residents)
You can request access to or ask that we delete your personal information at any time. Please note that, under certain circumstances, we have the right to impose a small fee for access and disclosure of your personal information where permitted under applicable law, which will be communicated to you. Certain information may be exempt from such requests under California law. For example, we may retain certain information for legal compliance and to secure the Platform. If you are a California resident seeking to exercise your CCPA rights, please email us at Privacy@tresensa.com, or (ii) complete the CCPA Webform to exercise your rights under the CCPA.
California law requires us to provide California residents with information regarding how we collect, use, and share your “personal information” (as defined in the CCPA). The specific pieces of information we collect from you or your device and how we use and share such information are described in detail above. We may disclose your personal information to the categories of recipients described in detail above.
How to Contact Us