Privacy Policy

Last modified: July 16, 2018

GDMServices, Inc. d/b/a FiksuDSP (“FiksuDSP” or “we” / “us” / “our”) is a marketing service company focusing on the mobile application marketplace. We are committed to maintaining the privacy of your information when you visit our www.fiksu.com website (our “Website”), and when we provide products that optimize the mobile marketplace inclusive of ads and app download environments, on behalf of our mobile 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://fiksu.com/privacy-shield-policy.

Website of FiksuDSP

When you use certain features of our Website, we may collect personally identifiable information from you that may include your email address and mobile phone number. We automatically collect non-personally identifiable information such as IP addresses and website usage information from you when you visit our Website. 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 FiksuDSP.

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.

Application Marketing Service of FiksuDSP

FiksuDSP buys mobile advertising space on behalf of our Clients which are generally mobile application providers and companies looking to advertise via mobile applications. When you click on a Client ad or application link delivered by FiksuDSP, FiksuDSP servers receive and store a mobile identifier (“Mobile ID”) which is a pseudonymous number that is associated with your mobile device. FiksuDSP cannot use the Mobile ID to identify you personally, but it does enable us to deliver relevant advertising to each mobile device. In addition to the Mobile ID, we collect information about the kind of mobile device you use (e.g., iPhone, Samsung), the operating system for your mobile device (e.g., Android, iOS), IP address, the applications you download from Clients of FiksuDSP, when, how, and how often you use those applications.

We use your device’s Mobile 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. We also use your Mobile ID and the information associated with your device Mobile 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 FiksuDSP’ Client ads that are most likely to be of interest to you. FiksuDSP may use agents and contractors in order to provide our services to Clients. If such agents and contractors have access to your Mobile ID and/or the information associated with your Mobile 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 FiksuDSP.

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 Mobile ID and/or the information associated with your Mobile ID over time for the following purposes:

  • To Clients of FiksuDSP when you click on their ad and/or download their application;
  • In response to legal process (for example, a court order, search warrant or subpoena);
  • 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, or when we, in good faith, believe that the law requires us to do so;
  • In other circumstances when necessary either to protect the rights or property of FiksuDSP, Clients of FiksuDSP, and third parties.
  • We may transfer information to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If FiksuDSP 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@fiksu.com.

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

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@fiksu.com you have the right:

  • to access your personal information that we hold;
  • to request the rectification of your personal information that we hold;
  • to request the erasure of your personal information that we hold;
  • to request to restrict processing of your personal information;
  • to object to processing of your personal information by us;
  • to request to transfer your personal information that we hold (e.g. data portability);
  • to file a complaint to a supervisory authority in your jurisdiction; and
  • to withdraw any consent related to your personal information given by you.

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.

We have assigned Anton Slobodskyi as our Data Protection Officer (DPO). You may reach him via dpo@fiksu.com. Our DPO is tasked with ensuring that Fiksu DSP 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 Site or for more than 24 months from the date of termination of an agreement between FiksuDSP and you (whichever is earlier).

Fiksu DSP 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 advertising use: brand targeting; campaign operations; brand measurement; performance attribution and optimization on the Demand Side Platform and Data Management Platform.

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

Cookies

Some of the advertisers and web analytics firms used on our Website may place “tracking cookies” on your computer. These are small text files that can tell such companies what you are doing online, even though they usually don’t record your name or other personally identifiable information. These cookies are used by these companies to try and match ads to a user’s interests. They are used all over the Web. FiksuDSP may place cookies on your computer, in addition to any placed by advertisers.

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

FiksuDSP 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. FiksuDSP 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@fiksu.com.

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 FiksuDSP 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 FiksuDSP 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 FiksuDSP

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

Alternatively, you may contact us at the address below:

GDMServices, Inc. d/b/a FiksuDSP
Attn: Data Protection Officer
177 Huntington Ave #179369
Boston, MA 02115