Privacy Policy

01. Introduction

Flyads inc., operating under the brand name «flyads» (hereinafter referred to as “Company”, “flyads”, “we”, “us”, “our”) is a mobile advertising company that provides customers with a platform and software to deliver more targeted advertising to their consumers.

Our technology enables our partners to show mobile applications and websites users more relevant advertising that is based on users’ interests and behaviors. In order to provide these services, we collect and use certain information about user activity and preferences. We understand that our users (“you”, ”your”) care about their personal information and how it is used and shared, and we take your privacy very seriously.

We have created and enacted this Privacy Policy to help you understand our privacy practices.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By using our services in any manner, you acknowledge that you accept the privacy practices and policies we outline in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the ways outlined in this policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Any capitalized terms used herein without definition shall have the meaning given to them in the Company Terms of Use.

flyads commits to comply with The EU General Data Protection Regulation (GDPR). flyads complies with the EU-U.S. Privacy Shield Framework and 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. flyads has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

02. What does this privacy cover?

This Privacy Policy applies to www.flyads.com, www.mdspinc.com and the online services consisting of providing and administering the advertising and optimization platform and software owned and operated by flyads. This Privacy Policy describes how flyads collects, uses, shares and secures the personal information you provide, your choices regarding the use, access and correction of your personal information. This Privacy Policy also describes treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our services.

Please note that this policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

This Privacy Policy covers the following:

• The information we collect;
• Our use of the information;
• Our sharing of the information;
• Your options for opting out of these practices.

03. The information we collect

We collect two main types of information through the Services - personal information and anonymous information and we may also generate a third type of information, aggregate information, as set forth in more detail below. Descriptions of these terms are available in the Definitions section of the Policy.

Depending on your interaction with the Services, flyads may collect information automatically and or when you voluntarily choose to provide it. We may also acquire information from other trusted sources to update or supplement the information that you voluntarily provide to us or that we automatically collect.

A. Information We Collect from Advertising Partners

If you are one of our Advertising Partner, we may collect the following categories of information from you:

• Registration information that you provide when you create an flyads account. For example, in order to register for the Services we require all Advertising Partners to create a username and password, and provide us with basic contact information (such as first and last name, email address and company name).
• Transaction information that you provide when you request information from flyads, submit a payment to us in connection with your use of the Services, or receive a payment from us in connection with your use of the Services. Examples of transaction information may include basic contact information, bank or financial account information, credit card or debit card numbers and similar details required to process your payments or respond to your request.
• Technical, viewing and usage information that relates to your interaction with the Site, such as your physical location, the unique identifier or Internet Protocol address (“IP Address”) of the device that you use to access the Site and the amount of time you spend viewing certain portions of the Site.

We may also collect certain types of information automatically through the use of Cookies as outlined below and other similar tracking technologies. These tracking technologies enable us to personalize your experience with the services and improve the services for you.

In case of any breach of data you will be notified within 72 hours of becoming aware of the leak.

B. Information We Collect From Consumers

Consumers are those individuals who download, use or otherwise interact with an websites of our Advertising Partners and/or 3rd parties that work directly with website owners.

If you are a Consumer that uses or otherwise interacts with our website or the services, we may collect and transfer non-sensitive device information provided by our advertising exchange partners that may consist of the following:

• Generic geographic location;
• Carrier;
• Device make, Manufacturer, Operating system and Language Settings;
• Name of application interactive with Flyads Services;
• IP Address;
• Internet browser used to access the Services;
• Connection speed;

We may track this information and may also combine the device information with anonymous information from other sources in order to deliver advertisements through the Services. In addition, flyads may collect information from Consumers through use of a Cookie or similar tracking technologies if the Consumer accesses advertisements from a browser or is redirected to a browser by advertisements provided through the Services. Certain advertisements may redirect you to a browser where we may use a Cookie to track Consumer activities.

C. Information You Provide to Us

We receive and store any information you knowingly provide to us. For example, we collect Personal Information such as your name, email address, browser information. You have an opportunity not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features.

If you have provided us with a means of contacting you, we may use such means to communicate with you. For example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Services. Also, we may receive a confirmation when you open a message from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by emailing us at: support@flyads.com. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the services, and you are responsible for reviewing such legal notices for changes.

Additionally, you may sign up to receive reports and communications from us. If you would like to discontinue receiving any information that you receive from us, you may email us at support@flyads.com

D. Information Collected Automatically:

Passive Collection. As is true of most websites and advertising companies, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

User Data Supplementation. We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, deliver our marketing services and provide products and services that may be of interest to you. If you provide us Personal Information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Advertising Partners wishing to opt out from information from flyads can click “UNSUBSCRIBE” in marketing emails or email us at support@flyads.com

Examples of the types of Personal Information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include purchased marketing data from third parties that is combined with information we have been provided by business partners, to create more tailored advertising and products.

Cookies and Tracking Technologies. Flyads and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. A full list of cookies we use on this site is found on our Cookie Policy.

Cookies are small text files placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as provide information to the owners of the site.

You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. We follow guidelines set forth by the Information Commissioner’s Office with regards to European Union rules on cookie use.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org.

04. Behavioral targeting

We partner with a third party to display advertising to manage our advertising on other sites and/or apps. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click preferences-mgr.truste.com or if located in the European Union click www.youronlinechoices.eu. Please note you will continue to receive generic ads. If you do not want to receive generic ads contact us at support@flyads.com.

05. What does flyads use the personal information for?

Uses of Information We Collect
Flyads uses the information we collect about you to provide the Services and to gain a better understanding of the products and services that may interest you. For example, we may use your information in order to:

• Operate, manage and improve the Services;
• Allow our users to set up a user account and profile;
• Fulfill your requests for certain products and services;
• Provide you with requested services;
• Communicate with you about your Flyads account, your interactions with the Services or your contacts’ interactions with the Services;
• Protect the rights or property of Flyads or third parties;
• Deliver targeted advertisements on behalf of our Advertising Partners;
• Analyze how users utilize the Services;

The Services may link to third party websites, non-flyads Apps and/or other third party content. Please note that flyads cannot control the treatment of your information by such third parties, and that the privacy practices of third parties likely differ from those described in the Policy.

We also may share certain types of Personal Information with third parties, as described below.

06. Will flyads share any of the personal information it receives?

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Sharing of Information, We Collect.
We neither rent nor sell your Personal Information in personally identifiable form to anyone. However, we do share your Personal Information with third parties as described in Section II and in this Section:

Affiliated Businesses and Third Party Websites We Do Not Control.
In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service.

List of our current partners:

• Google AdX;
• Magnite;
• OpenX;
• SpotX;
• Index Exchange;
• Xander;
• Oath;
• Adform;
• Freewheel;
• Sovrn;
• OneTag;

We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies. If you have any questions about these practices, please contact us at support@flyads.com

Service Providers
We employ other companies and people to perform tasks e.g., provide computer and network infrastructure services on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

User Profiles and Submissions
Certain user profile information, including without limitation a user’s name, location, and any content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for Company’s services.

Non-Personal Information
We may share aggregate or anonymous information with Business Partners and other third parties in accordance with the terms of this Policy.

Legal Notice
We may also disclose your Personal Information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

If flyads is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

07. How can i opt out of seeling interest-based advertising from flyads?

To opt-out please email us at support@flyads.com

Opting-out just means that the advertisements you do receive from us will not be targeted in any sort of way. Note that even if you opt-out, you may still receive content and advertising from us.

• You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.
• You may limit the disclosure of certain Non-Personal Information by your mobile Device to us and Partners by adjusting the settings on your mobile Device.
• You may opt out of certain cookies and browser-enabled, interest-based advertising. Please note that these opt outs apply to interest-based advertising by participating advertisers. You may still receive other types of online advertising from participating partners, and the websites you visit may still collect information for other purposes. In addition, the opt-out choices you select are stored in opt-out cookies only in the browser that you use to visit the opt-out websites, so you should separately set your preferences for other browsers or Devices you may use. Deleting browser cookies can remove your opt-out preferences, so you should visit these opt-out websites periodically to review your preferences or update your preferences to apply to new participating advertisers.
• Partners may also provide ways for you to opt out from or limit their collection of information from and about you. Please note, however, that we are not responsible for the privacy practices of Publishers, Advertisers, and other third parties.

Security
The security of your Personal Information is important to us. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once it is received. If you have any questions about the security of your Personal Information, you can contact us at support@flyads.com

Access
Upon request, flyads will provide you with information about whether we hold any of your Personal Information. You may access, correct, or request deletion of your Personal Information by contacting us at support@flyads.com. We will respond to your request within a reasonable timeframe.

Data Retention
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Service / Analytics Platform Disclosure
If you are using our analytics platform, the use of information collected through our service shall be limited to the purpose of providing the service for which you have engaged flyads.

Flyads collects information under the direction of you and its customers, and has no direct relationship with the individuals whose personal data it processes. If you are a client of one of our customers and would no longer like to be contacted by one of our customers that use our service, please contact the customer that you interact with directly.

We may transfer Personal Information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.

Flyads acknowledges that you have the right to access your Personal Information. Flyads has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to flyads’s customer (the data controller). If requested to remove data we will respond within a reasonable timeframe.

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.

We will retain personal data we process on behalf of our customers for as long as needed to provide services to our customer. Flyads will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

08. Independent recourse mechanism

Since we are committed to protecting your privacy as set forth in this Policy, if you think we are not in compliance with our Policy, or if you have any question or if you wish to take any other action concerning this Policy or your Personal Information, we encourage you to contact us at privacy@flyads.com. We will investigate your complaint, take appropriate action and report back to you within 45 days.

flyads has further committed to refer unresolved Privacy Shield related complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit JAMS https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS to resolve Privacy Shield related complaints are provided at no cost to you. Complaints that involve concerns outside of the scope of the Privacy Shield Principles are not covered by this section, and may be resolved in another forum.

Additionally, with respect to complaints concerning human resources data that is transferred from the EU in the context of the employment relationship, we have agreed to participate in the dispute resolution procedures of the EU Data Protection Authorities. Flyads will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints concerning human resources data that is transferred from the EU to the United States brought under Privacy Shield. For complaints involving human resources data transferred from Switzerland in the context of the employment relationship, we commit to cooperate with Swiss Federal Data Protection and Information Commissioner (“FDPIC”) and comply with the advice given by the FDPIC. Complaints regarding processing of human resources data pertaining to EU and Swiss citizens may be reported by the individual to the relevant Data Protection Authority.

These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law.

Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.

09. International transfers

As we are based in the United States, if you are located outside the United States and provide personal information to us, or to one of our group companies, your information will be transferred to us in the United States in accordance with this privacy policy.

flyads participates in and has certified its compliance with the EU-U.S. and the Swiss – U.S. Privacy Shield Framework. flyads is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [www.privacyshield.gov/list]

flyads is responsible for the collecting and the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf in accordance with this privacy policy. flyads complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

We have certified to the Department of Commerce that we adhere to the Privacy Shield principles of: (1) Notice; (2) Choice; (3) Accountability for Onward Transfer; (4) Security; (5) Data Integrity and Purpose Limitation; (6) Access; and (7) Recourse, Enforcement and Liability in respect of any personal information received from the European Union or Switzerland in reliance on the Privacy Shield (the “Privacy Shield Principles”).

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, flyads is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, flyads may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If there is any conflict between the policies of this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall take precedence.

10. Other international transfers

If you are based in the European Union, we may also transfer personal information that we collect from you to third party data processors located in countries that are outside of the European Economic Area (including to the United States). Please be aware that countries which are outside the European Economic Area may not offer the same level of data protection, although our collection, storage and use of your personal data will continue to be governed by this privacy policy.

11. Children’s privacy

We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register for the Services. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to us or on the Services. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at support@flyads.com

12. Changes to this privacy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

13. Contact information

Since we are committed to protecting your privacy as set forth in this Policy, if you think we are not in compliance with our Policy, or if you have any question or if you wish to take any other action concerning this Policy or your Personal Information, we encourage you to contact us at support@flyads.com. We will investigate your complaint, take appropriate action and report back to you within 45 days.