Digital Turbine Privacy Notice for California Residents

Introduction

This notice (“Privacy Notice“) addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulation by the Attorney General (collectively, “CCPA”) and supplements the information contained in the Privacy Policy. Any terms defined in the CCPA or the Privacy Policy shall have the same meaning when used in this Privacy Notice.

Digital Turbine, Inc. and its subsidiaries (collectively “we”, “us” or the “Company“) provides disclosures for the 12 months preceding January 1, 2020 as required by the CCPA vis-à-vis California residents.

  • What Information We Collect
  • Sharing Personal Information
  • Selling Personal Information
  • User Rights Under the CCPA
  • Non Discrimination
  • Children’s Information
  • Update or Amendment to the Privacy Notice
  • How to Contact Us

If you have a visual disability, you may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Privacy Notice.

What Information We Collect?

We collect certain information which identifies an individual or may with reasonable effort identify an individual (“Personal Information”). In addition, we treat information which is specifically connected or linked to any Personal Information – as long as such connection or linkage exists – as Personal Information.

In the preceding 12 months we may have collected the following categories of Personal Information:

Mobile Delivery Platform (known as ‘Ignite’):

We operate an installer platform which may be embedded in your device by default and used to remotely install applications on your device and further allows you to install applications based on your preferences, through our various services.

Category of Personal Data CollectedPersonal Information CollectedBusiness/Commercial Purpose for Collection
A. IdentifiersAndroid Advertising ID (AAID), Digital Turbine ID, IMSI (International Mobile Subscriber Identity), MDN (Mobile Directory Number), IMEI (International Mobile Equipment Identity), IP addressTo provide you with our service.

For advertising optimization and attribution purposes.

NewsHub:

NewsHub is a news and content app operated by the Company which provides users with personalized news and content feeds made available by third party content providers.

Category of Personal Data CollectedPersonal Information CollectedBusiness/Commercial Purpose for Collection
A. IdentifiersIP address, Google/Android Advertising ID (GAID/AAID), Device Specific Anonymous ID (OAID)To provide you with our service;

For advertising optimization and attribution purposes;
B. Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))Zip CodeComply with legal obligations;

To enhance and personalize your experience and customize the advertising content we display.

All personal information that is collected by us is collected directly from the consumer’s devices. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

When you use or interact with the content in NewsHub, we may use (and authorize third parties to use) web beacons, cookies pixel tags, scripts, tags, APIs and other technologies (“Tracking Technologies“).

The Tracking Technologies allow us and authorized third parties to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), in order to enhance your navigation on our services, improve our services performance and customize your experience on our services. This information can also be used to collect statistics about the usage of our services, perform analytics, deliver content which is tailored to your interests and administer services to our users, advertisers, publishers, customers and partners.

Below you can find a list of authorized thirds parties who collect your personal information directly, including the categories of data collected and link to their privacy policies:

Third-PartyCategories of Data Collected
Microsoft (MSN)A. Identifiers;
F. Internet network activity information;
G. Geolocation
OutBrainA. Identifiers.
GoogleA. Identifiers;
G. Geolocation.

Sharing Personal Information

We disclose your Personal Information to third parties for a Business Purpose. When we disclose Personal Information for a Business Purpose, we enter into a contract that describes the purpose and requires both parties to keep that Personal Information confidential and not use it for any purpose except in the performance of the contract.

In the preceding twelve (12) months, we may have disclosed the above-mentioned categories of Personal Information with the following categories of recipients for a business purpose:

    • Our customers (carriers and device manufacturers which utilize our software and services);
    • Advertisers;

  • Advertising Networks; and
  • Service providers.

Selling Personal Information

We do not sell your Personal Information to third parties and businesses for commercial purposes.

In the preceding twelve (12) months, we did not sell any Personal Information to third parties or businesses for commercial purposes.

User Rights under the CCPA

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Personal Information

You may request, up to two times each year, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information about you that we sold, the categories of third-parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable. Access my data.

Deletion Requests

You have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies. Delete my data.

Exercising Your Rights

In addition, to request access to your Personal Information or request deletion of your Personal Information, you can also submit a verifiable consumer request to our email address: california-privacy@digitalturbine.com

Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.

The request must:

  • Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
  • We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You may only request a copy of your data twice within a 12-month period.

If you have any general questions about the Personal Information that we collect about you how we use it, please contact us at california-privacy@digitalturbine.com.

NewsHub:

Since we do not store or have access to the data collected by authorized third parties through our services, if you want to exercise your consumer rights with respect to the data collected by such third parties, as described above, please contact the relevant third parties directly.

Third-PartyCategories of Data Collected
Microsoft (MSN)Privacy Policy
Microsoft (MSN)Privacy Dashboard
OutBrainPrivacy Policy
GooglePrivacy Policy
GooglePrivacy Dashboard

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Children’s Information

Our Service is not intended for minors below the age of 16 years or otherwise below the legal age for providing consent that is not subject to authorization by the holder of parental responsibility, in accordance with the laws in the jurisdiction you reside (“Age of Consent”), and we will not knowingly collect personal information from children. If we become aware that a user is under the age of Age of Consent, we will remove their information from our files. We reserve the right to request proof of age at any stage so that we can verify that children are not using the Service.

Updates or Amendments to the Privacy Notice

We reserve the right to change this Privacy Notice at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Notice on our website or if you have volunteered any other means of communication with you. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above-mentioned methods. Otherwise, all other changes to this Privacy Notice are effective as of the stated “Last Revised” date, and your continued use of the Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. Notwithstanding the forgoing, as of January 1st 2020, this Privacy Notice will be updated at least once every 12 months.

How to Contact Us

If you have any questions (or comments) concerning this Privacy Notice, you are welcome to contact Please contact us at privacy@digitalturbine.com.

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time.

Last Revised: May 13, 2020