PRIVACY POLICY

Last modified: October 25, 2019

GDMServices, Inc. (“GDMServices” or “we” / “us” / “our”) is a marketing service company focusing on the mobile and CTV application marketplace. We are committed to maintaining the privacy of your information when you visit our www.gdm.services website (our “Website”), and when we provide products that optimize the mobile and CTV marketplace inclusive of ads and app download environments, on behalf of our mobile and CTV application provider clients (“Clients”).

This Privacy Policy describes how we treat the personal information received about you on this Website and when providing marketing services to our Clients (our “Services”). Information on our EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework is available at https://gdm.services/privacy-shield-policy.

Website of GDMServices

When you use certain features of our Website or visit our Website, we may collect certain information from you:

Except as specifically set forth in this Privacy Policy and in the Privacy Shield Policy, we will not share your personally identifiable information outside of GDMServices.

We may disclose and use personally identifiable information to resolve disputes, troubleshoot problems, enforce our Terms of Use (for example, when necessary to protect our or a third party’s intellectual property or proprietary rights), or to alert you to changes in our policies or agreements that may affect your use of our Website. We may also disclose personally identifiable information when we, in our sole discretion, believe it is necessary or appropriate, in connection with a sale or transfer of some or all of our assets in the Website, or when we, in good faith, believe that the law requires us to do so.

Marketing Service of GDMServices

GDMServices buys mobile and CTV/OTT advertising space on behalf of our Clients which are generally mobile/CTV application providers and companies looking to advertise via mobile/CTV applications or OTT content. When you click on a Client ad or application link delivered by GDMServices, GDMServices servers receive and store an advertising identifier (“Advertising ID”) or device identifier (“Device ID”), either of them is a pseudonymous number that is associated with your mobile or CTV device. GDMServices cannot use the Advertising/Device ID to identify you personally, but it does enable us to deliver relevant advertising to each mobile or CTV device. In addition to the Advertising/Device ID, we collect information about the kind of mobile/CTV device you use (e.g., iPhone, Samsung, Roku etc.), the operating system for your mobile device (e.g., Android, iOS, Fire OS etc.), IP address, content that you may be watching through video streaming CTV/OTT applications, the applications you download from Clients of GDMServices, when, how, and how often you use those applications.

We use your device’s Advertising/Device ID and other information about Client applications you download to help our Clients understand which ads are most effective at generating downloads of our Client’s applications or at achieving other goals defined by Client. We also use your Advertising/Device ID and the information associated with your device Advertising/Device ID over time (e.g., the applications you download, when and how you use those applications, and any publisher-provided demographic data) to enhance our services and to select GDMServices’ Client ads that are most likely to be of interest to you.

GDMServices may use agents and contractors in order to provide our services to Clients. If such agents and contractors have access to your Advertising/Device ID and/or the information associated with your Advertising/Device ID, they are required to protect this information in a manner that is consistent with this Privacy Policy by, for example, not using the information for any purpose other than to carry out the services they are performing for GDMServices.

We may aggregate your data with other customers’ data in non-personally identifiable, aggregated, and de-identified form to better optimize marketing campaigns and to improve our Website or service. We may also share this de-identified aggregate data publicly, for example in order to provide analytical summaries.

Information Sharing, Onward Transfer

We disclose the information in our systems, including your Advertising/Device ID and/or the information associated with your Advertising/Device ID over time for the following purposes:

We may transfer information to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If GDMServices 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 or uses of your personally identifiable information, as well as any choices you may have regarding your information.

Choice Mechanism, Opt-out

We don’t collect personally identifiable information unless you provide it to us. You may send requests to understand what personally identifiable information we have on you by emailing dpo@gdm.services.

The World Wide Web Consortium (W3C) has been attempting to develop a Do Not Track (DNT) standard, but it has not been finished. Currently, the standards regarding the DNT signals and appropriate responses are not well defined. Accordingly, we do not assign a meaning to DNT signals. If you’d like to opt-out from GDMServices, please click here. By opting out of GDMServices, you will continue to see advertising, although it will not be tailored to your interests by data provided by GDMServices.

Rights to Your Information According to GDPR

GDPR stands for the General Data Protection Regulation (EU) 2016/679, which is a European Union law governing privacy and data protection for all residents of the EU. The provisions of GDPR can be also applied to how data is processed and verified (more on that later) outside the European Union.

Generally speaking, the GDPR represents a new set of rules intended to empower the citizens of the European Union to control their personal information. In accordance with the applicable laws, users are authorized to access and modify their own data held by the companies, which includes data collection, ad tracking, surveys, cookies, location data, and every other bit of a user’s “digital footprint”. Users are also entitled to transmit their personal details to other organizations. The GDPR also enforces companies to determine their in-house data security policies.

At any time by emailing dpo@gdm.services you have the right:

We will process your requests to us within 30 days. We will also notify you within and a relevant supervisory authority within 72 hours from a breach related to your personal information that we hold.

Please note that we may at any time ask for additional documentation and information from you in order to verify your identity.

Please also be warned that we may transfer your request to the applicable party who served as a first point of contact in terms of receiving a relevant personal information from you in order for him to comply with it and to verify your identity accordingly.

We have assigned Anton Slobodskyi as our Data Protection Officer (DPO). You may reach him via dpo@gdm.services. Our DPO is tasked with ensuring that GDMServices acknowledges and abides its data protection responsibilities.

EU Representative – according to Art. 27 GDPR:
ePrivacy GmbH
represented by Prof. Dr. Christoph Bauer
Große Bleichen 21
20354 Hamburg
Germany
https://www.eprivacy.eu

We will not store personal information for more than 24 months from the date of your last active session on the Website or for more than 24 months from the date of termination of an agreement between GDMServices and you (whichever is earlier).

GDMServices will gather and manipulate only non-sensitive data signals. Personal information will be pseudonymized and encrypted to ensure the user privacy. The collected information will be handled for standard cases of mobile / CTV advertising use: brand targeting; campaign operations; brand measurement; performance attribution and optimization on the Demand Side Platform.

Our Application Marketing Service compels any calls of advertising ID and other user data to be stripped of personally identifiable information before mapping to all other non-sensitive marketing data.

Do Not Sell My Personal Data

To restrict any our further commercial use of any your personal data which we may currently have in our possession please follow the instructions here .

Cookies

When you visit our Website, we may place “tracking cookies” on your computer. These are small text files that can tell us what you are on our Website, even though they usually don’t record your name or other personally identifiable information.

Website Analytics

We have implemented a third-party analytics’ features that will collect data on our Website. You can opt-out of these analytics features by clicking here.

Data Integrity

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

Children’s Privacy

GDMServices adheres to the Children’s Online Privacy Protection Act. We do not create nor use any behavioral advertising segments of children under 16 as part of our Services. Our Website is not directed at children under the age of 16. If we are made aware that we have received personally identifiable information from someone under 16, we will use reasonable efforts to remove that information from our records.

Security

The security of your information is important to us, including but not limited to the personally identifiable information collected via the Website. GDMServices has implemented reasonable security measures to protect the information, both during transmission and once it is received. This includes but is not limited to the use of firewalls and encryption. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while the company strives to use commercially acceptable means to protect your information, it cannot guarantee absolute security. If you have any questions about these security practices, please email dpo@gdm.services.

Links to Other Content

We frequently make content or services from other websites available to you from links located on our Website. These other websites are not subject to this Privacy Policy, and GDMServices has no control over how such websites may use the personally identifiable information collected on those sites. We recommend that you review the privacy policy at each such website to determine how that site protects your privacy.

Transfer to the U.S. or Other Countries

Your information may be stored and processed in the United States or any other country where GDMServices has facilities.

Changes to this Privacy Policy

When we make a material change to this Privacy Policy, we will inform you by posting a notice on the home page of this Website that the policy has been updated and by changing the date on this page noting when the policy was last updated.

Contact GDMServices

If you have any questions or concerns regarding this Privacy Policy, please email us at dpo@gdm.services.

Alternatively, you may contact us at the address below:

GDMServices, Inc.
Attn: Data Protection Officer
177 Huntington Ave #179369
Boston, MA 02115