Privacy Policy

Aequus Ads Inc. is a company organized under the laws of Delaware, with a registered office at 9888 W Belleview Ave Ste 2373, Denver CO 80123 (»Aequus«, »We«, »Us«). Aequus provides advertising technology services that allows publishers of mobile applications (“apps”) to show advertisements in their apps and advertisers (companies or individuals that advertise products or services within the app) to reach audiences that may be interested in their products or services. This Privacy Policy explains how Aequus collects, uses, shares, or otherwise process personal data of app users with integrated Aequus Technology (Aequus SDK and/or APIs). »You« refers to a user that uses and app with integrated Aequus Technology.

Aequus operates a Mediation Platform (»Aequus Services«), meaning a platform that helps app developers (»Publishers«) manage advertisers that serve ads within Publisher’s apps with the help of Aequus technology. Publishers have direct contractual relationships with the Advertisers. Aequus technology includes the Aequus software development kit (“Aequus SDK”) and/or application programming interfaces (“APIs”). Aequus SDK, is a software component that allows us to serve ads in mobile apps and to collect information directly from end users of such app.

Aequus collects information in one of two ways:

Directly – from your device through Aequus SDK integrated by app developers in their apps, or
Indirectly – through Advertisers with which we engage in order to serve you ads, or by receiving information from our Advertisers.

We work with a variety of partners (collectively, “Aequus Partners”) in order to provide the Aequus Services, including:

Data Partners: companies that create audience segments, including demographic and interest segments, based on device identifiers, location data, and other personal data;
Fraud and Measurement Partners: companies that help with anti-fraud, quality, and security efforts to ensure the safety, security, privacy, and accuracy of the Aequus Services, including detecting whether clicks on ads are fraudulent and whether ads are viewable within an app;
Publishers: with the Aequus SDK and/or APIs integrated in their Apps in order to show advertising in their Apps;
Supported Advertising Mediation Partners: companies that Publisher(s) work with directly in order to serve ads in their apps. Aequus Services support the technical integration of these Supported Advertising Mediation Partners’ services in our Publisher(s)’ Apps through Aequus’ mediation.

Aequus collects information as described in this Privacy Policy for its own purposes, as a data controller under data protection law where relevant, except as otherwise indicated herein. Aequus Partners are each independent controllers of your data.

Personal Data We Process

1.1. Personal Data We Collect About You Through Apps

When you use an app with the Aequus SDK and/or APIs integrated, we may collect personal data about you. The Aequus Services do not intentionally collect information like your name, address, or email address, however personal data we may collect may enable us to recognize your device over time and across Apps. Depending on where you live and your privacy choices, the personal data we may collect includes:

device identifiers, including your IP address, iOS Identifier for Advertising (IDFA), iOS Identifier for Vendors (IDFV), Google Advertising ID (AAID), and Aequus specific identifier (id per game), number of sessions, session length, new installs, DAU, MAU;
Device technical data: Information about a device, such as device model and name, network provider, browser type, language, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, International Mobile Equipment Identity (IMEI) on Android, Android ID, Android Serial No;
Your precise geo-location, when location services have been enabled for an app on your device integrated with the Aequus SDK and/or APIs. When location services have not been enabled in any of your apps with the Aequus SDK and APIs integrated, we will still infer data about your location based on other information, including your IP address;
Information that a Publisher has collected about you and/or shared with Aequus, including demographic information (e.g., your age or gender) or information about your interests, to help make the ads served to you more relevant;
Information about your app usage, including the apps on your device which use the Aequus SDK and APIs and the version of such apps, the app on your device which is requesting an ad, the start/stop time of your app session, your current time zone, and your network connection type (e.g., WiFi, cellular), (ad performance data);
Information about ads served, viewed, or clicked on, including the type of ad, where the ad was served, whether you clicked on it, and whether you visited the advertiser’s website or downloaded the advertiser’s app.

1.2. How We Use the Personal Data We Collect About You Through Apps

We use the personal data we collect about you through apps with the Aequus SDK and/or APIs integrated for the following purposes:

1.2.1. Serving Ads: Allowing Publisher(s) to offer advertising inventory in their apps, and Third party Ad Networks to bid on and fill that inventory with ads. We use the information collected directly from you through the Aequus SDK, and information provided to us by a Third party Ad Network (“Ad Network Information”) from your device to serve ads on app developers’ apps.

1.2.2. Personalized Advertising: Advertisers may use the Mediation Information and/or Advertiser Information for personalized advertising (i.e. ads that are based on your interest or profile). Mediation Information is information received (through our SDK) from the Publisher which are integrated with our mediation platform. Advertiser Information are Information received from advertisers (through the Advertiser itself or through a third party on behalf of such advertiser). Advertisers may use Mediation Information and/or Advertiser Information for personalized advertising (i.e. ads that are based on your interest or profile)

1.2.3. Ad Reporting and Conversions: Reporting to Advertisers information about when and how you have been exposed to their ads or clicked on their ads, and reporting to Publisher(s) information about when and how ads were shown on their properties and were clicked on.

1.2.4. Frequency Capping: Preventing you from seeing the same ad or type of ad too many times.

1.2.5. Fraud Detection and Prevention: Identifying invalid clicks (or ad queries) and protecting Aequus and Advertisers from fraudulent behaviour.

1.2.6. Providing and Operating Our Services: Auditing, researching and analysing data in order to maintain, protect, and improve Aequus Services, and to ensure that our technologies function properly.

1.3. How We Share the Personal Data We Collect About You Through Apps

We share personal data that we collect about you through the apps with the Aequus SDK and/or APIs integrated for the following purposes:

1.3.1. Data Partners: We share personal data with Data Partners so that they can create audience segments, including demographic and interest segments, to help Advertisers choose the best ad for you on our mobile advertising exchange and across the broader advertising ecosystem.

1.3.2. Fraud and Measurement Partners: We share personal data with Fraud and Measurement Partners in order to help with anti-fraud, quality, and security efforts to ensure the safety, security, privacy, and accuracy of the Aequus Services and the broader advertising ecosystem.

1.3.3. Aequus Partners: We share personal data with Aequus Partners so that they can build and improve their products and services for use on Aequus and across the broader advertising ecosystem.

1.3.4. Services Providers: We share your Ad Network Information, Mediation Information, and Advertiser Information with our service providers for the purpose of receiving services such as fraud detection and prevention, viewability measurement, reporting, and storage.

1.4. Controlling the Processing of Your Personal Data for Personalized Advertising

We give you control over how we process personal data from you for personalized advertising. We may collect and transfer Ad Network Information to other entities, such as advertisers, other ad networks, and third parties acting on behalf of these types of entities that use the information described in this Privacy Policy for serving you with personalized ads (i.e. ads that are based on your interests or profile).

1.4.1. The GDPR – EEA, Switzerland and United Kingdom: If you are located in the EEA, Switzerland or the United Kingdom, Publisher(s) who would like us to serve you personalized ads must first obtain your consent so that Aequus and Aequus Partners can process your personal data for this purpose. Some Publisher(s) may choose to obtain your consent for this purpose even if you are located outside of these regions. If you provide your consent, we will collect, use, share, and otherwise process all of the personal data described above for the purpose of serving you personalized advertising.

1.4.1.1. Withdrawal of Consent: You can withdraw your consent to Aequus’ personalized advertising experience at any time by opting-out and/or limit the use of tracking data for ad targeting. If you do not want us to transfer your information to third parties for personalized ads, you can opt-out by following instructions below:

- - For iOS devices: go to Settings > Privacy > Apple Advertising > enable Limit Ad Tracking. Please note that if you use more than one device, you need to opt-out separately in each device.
  - For Android devices: Please follow the instructions set forth at: https://support.google.com/ads/answer/2662922?hl=en. Please note that if you use more than one device, you need to opt-out separately in each device.

Scope of the Opt-Out: Note that if you reset your advertising ID through your device’s platform settings, you should follow the steps above to reset your opt-out choice. In addition, opting out may not stop data from being collected from your device or transferred for other, non-personalized advertising purposes such as optimization, reporting, frequency capping, internal operations, and fraud prevention. If you become aware of any third party that received your Ad Network Information from us, and that does not respect your choices, please let us know by contacting us at: privacy@aequus.mobi.

You can reset the identifiers on the User’s mobile device in the device settings. iOS users can do this by following Settings > Privacy > Advertising > Reset Advertising Identifier. For Android, the path is Google settings > Ads > Reset advertising ID. Following such restart, the device is harder to associate with past activity, but tracking can start anew using the new advertising identifier.

If you would like to delete all cookies, you can also delete the cookies that indicate your preference to opt out of targeted ads. Please note that even if you opt out of targeted advertising, we will still use cookies for other purposes, such as to limit the number of times the user is served with a particular ad.

Even if you do not consent to a personalized advertising experience, or you later withdraw such consent, we may still process your personal data when necessary to comply with our legal obligations or to support our legitimate interests, as described below.

1.4.1.2. Legal Necessity: We may process personal data as necessary to comply with our legal obligations. For example, when we collect your IP address in order to perform a lookup of your country, so that we know whether you are located in the EEA, Switzerland or the United Kingdom. Similarly, if you consent to our personalized advertising experience, but later withdraw such consent, we will continue to retain a record of the iOS Identifier for Advertising or Android Advertising ID of your device for the purpose of recording when you consented and withdrew consent from our processing of your personal data. As part of your withdrawal of consent request, we may also make available the iOS Identifier for Advertising or Android Advertising ID of your device to our current Aequus Partners so that they, as independent controllers of your personal data, can also respect your choice to withdraw consent.

1.4.1.3. Legitimate Interests: We may process personal data as necessary to support our legitimate interests. For example, even if you do not consent to a personalized advertising experience, we may still:

- - generate, collect, and use the Aequus-specific identifier for the purpose of analytics and frequency capping (to prevent you from seeing the same ad too many times). In some circumstances, we may enable our Advertisers to receive this identifier for non-personalized advertising purposes, including frequency capping and analytics;
  - enable our service providers to receive your IP address for purposes of detecting invalid clicks and other fraudulent activity. In order to protect your privacy, we contractually prohibit our fraudulent activity detection service providers from using this data for any purpose other than fraud detection on and off of Aequus;
  - for iOS users, collect and enable our Advertisers to receive your Identifier for Vendors (IDFV) for non-personalized advertising purposes, including frequency capping and analytics.

1.4.1.4. Data Subject Rights: Please note that you have the right to request from us access to and rectification or erasure of your personal data we process as controllers, to restrict or to object to processing of your personal data in accordance with the provisions of the GDPR. To submit a request for exercising your rights, please send an email with your request to the following address: privacy@aequus.mobi. Please note that we will process your request subject to verification of your identity.

You also have the right to file a complaint with the relevant supervisory authority (e.g. of your country or domicile) where Aequus has not addressed your concerns.

1.4.2. United States and Other Countries: Opt Out: If you are located in the United States or another country outside the EEA, Switzerland and the United Kingdom, you can opt out of receiving personalized advertising by using your applicable device settings:

On iOS version 13 and earlier only, you may opt out by enabling the “Limit Ad Tracking” setting in your iOS settings (precise directions may be different on different iOS versions);
On iOS version 14 and later only, you may opt out by disabling the “Allow Apps to Request to Track” setting in your iOS settings (precise directions may be different on different iOS versions);
On Android devices, you may opt out in the Google Ads settings within your Android settings by toggling the “Opt out of Ads Personalization” switch on (precise directions and name of the switch may be different on different Android versions and OEM Android variants).

If you opt out through your device settings, as described above, Aequus will send your opt-out preference with each request for an advertisement sent to our Advertisers. Aequus requires that our Advertisers honour opt-out preferences expressed using these controls by only serving contextual advertisements in response to such ad requests, and prohibit the use of any data contained in such ad requests to serve personalized advertising or to create a personalized advertising profile of the user or device.

California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

the right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
the right to request that we delete the personal information we have collected from you or maintain about you;
the right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales;
the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us by sending an email to privacy@aequus.mobi.

Please note that we may need to request additional information from you to verify your identity or process your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your name and email address. We will also collect information that identifies your device when you submit a request, in order to help verify your identity.

1.5. Access to Personal Data We Collect About You Through Apps

Due to the nature of the personal data Aequus collects, we do not have sufficient information available to provide secure, authenticated access to the personal data that we store about you or to confirm that specific personal data relates to you. However, as noted above, you can exercise control over how we process your personal data for personalized advertising as explained above. You can also contact us using the details below.

1.6. Deletion

Unless we have another legal basis for storing your personal data, if you are located in the EEA, Switzerland or the United Kingdom, we will delete or de-identify the personal data we have stored about if you withdraw your consent.

1.7. Privacy Practices of Aequus Partners

Aequus requires Aequus Partners to comply with all applicable laws and regulations. In addition, Aequus requires Publishers who are each independent controllers of your personal data, to comply with the Aequus Terms of Service and this Privacy Policy and to provide you with sufficient notice of their processing of your personal data.

When you consent to Aequus’ processing of your personal data, you are also consenting to Aequus sharing your personal data with Aequus Partners in order to show you advertising that we believe is more relevant to you. If, as described above, you use your device settings to no longer receive Aequus’ personalized advertising experience, the next time you use an app with the Aequus SDK and APIs integrated on that device, we will communicate a signal indicating your choice to relevant Aequus Partners so that they, as independent controllers of your personal data, can also respect your choice. Aequus Partners may also have separate legal bases for collecting, using, retaining, and sharing your personal data. For example, some Publisher(s) and Advertisers may mutually agree to process your personal data for personalized advertising purposes on the basis of legitimate interests. While Aequus is not involved in the processing of your personal data in these cases, our policies require Publishers to provide visible notice when they choose to process your personal data in this manner.

We encourage you to read Aequus Partners’ policies to understand their privacy practices, the legal bases for their processing of your personal data, and any additional options that they provide for exercising control over such processing.

1.8. Children

Aequus does not permit the Aequus Services to be used to collect information from apps directed to children under the age of 13 for purposes of personalized advertising. Aequus does not knowingly collect or maintain personal information collected online from children under the age of 13, except to the extent that the U.S. Children’s Online Privacy Protection Act permits us to collect and maintain such information without parental consent. If you believe your child has provided us with personal information that is covered by the U.S. Children’s Online Privacy Protection Act without your required consent, please contact us at privacy@aequus.mobi and we will make reasonable efforts to delete the information from our records. Our services may link to other websites or mobile apps. Please be advised that we are not responsible for the privacy practices of such other websites or mobile apps as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these websites and/or mobile apps and we shall not be responsible for any use of such websites and/or mobile apps.

For EEA, UK and Switzerland (GDPR users): We do not collect or otherwise process personal data from individuals in the European Economic Area, the United Kingdom, and Switzerland whom we know to be under 16 years of age, except to comply with law or to support our legitimate interests or the legitimate interests of our app developers as described above.

1.9. Other Important Information

1.9.1. Law, Harm, and the Public Interest: Notwithstanding anything to the contrary in this Privacy Policy or controls we may otherwise offer you, we may preserve or disclose information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the rights or safety of any person; to address fraud, security or technical issues; or to protect the rights or property of Aequus or Aequus Partners.

1.9.2. Change of Ownership: In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal data may be sold or transferred as part of that transaction. This Privacy Policy will apply to your personal data as transferred to the new entity.

1.9.3. Contact: If you want to contact us in relations with this Privacy Policy or any other legal documents, please email us to: privacy@aequus.mobi. If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

1.9.4. Changes to This Privacy Policy: We may revise this Privacy Policy from time to time. The most current version of the policy will govern our processing of your personal data and will always be at http://www.aequus.mobi/privacy. If we make a change to this Privacy Policy that, in our sole discretion, is material, we will notify you via a banner on this website or, if you are a Publisher Partner or Advertising Demand Partner, an email to the email address associated with your account. By continuing to access or use the Aequus Services or an app containing the Aequus SDK and APIs after those changes become effective, you agree to be bound by the revised Privacy Policy.

California Consumer Privacy Statement (CCPA)

This California Consumer Privacy Statement supplements the Privacy Policy and applies solely to California consumers. This Statement does not apply to job applicants. This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1. Notice of Collection and Use

We may collect the following categories of personal information about you:

Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80 (For Our Commercial Relationships): signature, credit card number, debit card number, and or other financial information
Protected Classifications: characteristics of protected classifications under California or federal law, such as age and gender
Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
Geolocation Data
Sensory Information: audio, electronic, visual, and similar information
Employment Information: professional or employment-related information
Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in the Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

1.1. Purposes

1.1.1. Categories of Personal Information:

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services:	Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance	Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction	Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity	Debugging to identify and repair errors that impair existing intended functionality	Undertaking internal research for technological development and demonstration	Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
Identifiers	Identifiers	Identifiers	Identifiers	Identifiers	Identifiers	Identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80
Protected Classifications	Protected Classifications	Protected Classifications	Protected Classifications	Protected Classifications	Protected Classifications	Protected Classifications
Online Activity	Online Activity	Online Activity	Online Activity	Online Activity	Online Activity	Online Activity
Geolocation Data	Geolocation Data	Geolocation Data	Geolocation Data	Geolocation Data	Geolocation Data	Geolocation Data
Sensory Information	Sensory Information	Sensory Information	Sensory Information	Sensory Information	Sensory Information	Sensory Information
Employment Information	NO	NO	Employment Information	Employment Information	NO	NO
Inferences	Inferences	Inferences	Inferences	Inferences	Inferences	Inferences

2. Collection, Use, and Disclosure of Personal Information

We may have collected and used your personal information, as described in Section 1 of this Statement, during the 12-month period prior to the effective date of the Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.

Categories of Sources of Data Collection: We may have obtained personal information about you from various sources, as described below:

Categories of Personal Information
Directly from you	From your devices	Our affiliates	Vendors who provide services on our behalf
Identifiers	Identifiers	Identifiers	Identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80
Protected Classifications	/	Protected Classifications	Online Activity
Online Activity	Online Activity	Online Activity	Geolocation Data
Geolocation Data	Geolocation Data	Geolocation Data	Sensory Information
Sensory Information	Sensory Information	Sensory Information	Employment Information
Inferences	Inferences	Inferences	Inferences

Categories of Third Parties: We may have shared your personal information with certain categories of third parties, as described below:

Categories of Personal Information
Our affiliates	Vendors who provide services on our behalf	Professional services organizations, such as auditors and law firms	Partners & Data analytics providers	Government entities	Advertising networks
Identifiers	Identifiers	Identifiers	Identifiers	Identifiers	Identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80	Additional Data Subject to Cal. Civ. Code § 1798.80
Protected Classifications	Protected Classifications	Protected Classifications	Protected Classifications	Protected Classifications	Protected Classifications
Online Activity	Online Activity	Online Activity	Online Activity	Online Activity	Online Activity
Geolocation Data	Geolocation Data	Geolocation Data	Geolocation Data	Geolocation Data	Geolocation Data
Sensory Information	Sensory Information	Sensory Information	Sensory Information	Sensory Information	Sensory Information
Inferences	Inferences	Inferences	Inferences	Inferences	Inferences

Aequus’ Publisher(s) use our Services to show Interest-Based Advertising in their apps and may sell personal information using our Services. During the 12-month period prior to the effective date of this California Consumer Privacy Statement, the following categories of personal information may have been sold using our Services:

Identifiers such as a real name, alias, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
Internet and other electronic network activity information, including, but not limited to, your interaction with websites, applications or advertisements
Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences and characteristics predispositions, and attitudes.

We do not sell the personal information of minors we know to be under 16 years of age.

3. Your Rights Under CCPA

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

How to Submit a Request: To submit an access or deletion request email us at privacy@aequus.mobi To opt-out of the sale of your personal information email us at privacy@aequus.mobi.

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact privacy@aequus.mobi.