Notice at Collection and Website Privacy Policy

Last Updated: October 2023.

We at Digital Turbine, Inc. (“Digital Turbine,” “we,” “us,” or “our”) put great efforts into making sure that we secure personal information related to you and use it properly.

The notice at collection (“Notice at Collection”) and privacy policy (“Policy,” and collectively: the “Notices”) provided on this page explain our privacy practices for processing personal information related to you when you use our Website at www.digitalturbine.com (the “Website”).

The term “personal information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or household that identifies an individual or relates to an identifiable individual. For example, personal information is your name, email address, telephone number, and other contact details that you submit to us or that we collect from your mobile device or app.

These Notices apply to visitors to our Website (“Customers”).

The summary of this policy will give you a quick and clear view of our practices. Please take the time to read our full policy. If you disagree with this Privacy Policy, please do not access or use our Website.

The Policy Summary below will give you a quick and clear view of our practices. The first six headings in the summary also serve as the Notice at Collection.

A Summary of the Policy

The Digital Turbine Website Privacy Policy

Categories of Personal Information That You Provide Us

We receive and store any information you enter on our Website or give us in any other way. For example, when you contact us via the Website, we receive any information you provide.

When you contact us to apply for a job with us, you provide us with personal information related to you, which we process for recruitment and general HR purposes.

Categories of Personal Information That We Collect

Like many websites, we use “cookies” (for further information about cookies, please see our Cookies and Similar Tracking Technologies Policy), and we obtain information when your browser accesses our Website.

We also receive information about your online activity from third-party analytics services when you use the Website. Please see this policy’s “Aggregated and Analytical Information” section for more information.

Examples of such information we collect and analyze include the Internet Protocol (IP) address, login, e-mail address, device and connection information such as browser type, version, time zone setting, browser plug-in types and versions, operating system, and platform.

What Do We Do with Personal Information?

We use personal information related to you for the following purposes:

• To provide you with the Website, newsletter, or blog you may have registered to or to contact you if you filled out a form requesting us to do so;
• to provide you with notifications related to your use of the Website, such as electronic newsletters, blogs, or promotional emails;
• to solicit your feedback and provide support;
• to maintain the Website and to continue developing and making it better;

We obey the law and expect you to do the same. If necessary, we will use personal information related to you to enforce our terms, policies, and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of our Website, and to take any action in any legal dispute and proceeding.

We commit to process personal information related to you solely for the purposes described in this policy.

Who do we Disclose, Share, or Sell Personal Information related to you with?

We do not sell, rent, or lease personal information related to you.

Personal information related to you is shared with certain employees, external consultants, and our affiliates, all governed by this Policy.

We also share personal information related to you with our vendors worldwide and third-party service providers that process your personal information on our behalf. Such vendors and service providers are contractually bound to keep personal information related to you confidential and appropriately secure.

A merger, acquisition, or any other structural change will require us to transfer personal information related to you to another entity as part of the structural change, provided that the receiving entity will comply with this policy.

We will share personal information related to you only subject to the terms of this policy or subject to your prior consent.

We will need to disclose personal information related to you in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

How Long Do We Retain Personal Information?

We retain different types of personal information related to you for different periods, depending on the purposes for processing the information, our legitimate business purposes, and legal requirements under applicable law.

We will maintain your contact details to help us stay in contact with you. You can contact our privacy team at [email protected] and request to delete your contact details. We will keep your details without using them if necessary and for the period required for legal requirements and proceedings.

We will retain personal information related to you after you have left our Website if retention is reasonably necessary to resolve disputes between our users, to prevent fraud and abuse, or to enforce this Privacy Policy and our Terms of Use. We will keep aggregated non-identifiable information without limitation, and to the extent reasonable, we will delete or de-identify potentially identifiable information when we no longer need to process the information.

In any case, we will keep information about you for as long as you use our Website unless applicable law requires us to delete it or if we decide to remove it at our discretion, according to the terms of this policy and our Terms of Use.

Your Choices and Rights

General
The section below applies to all Users, regardless of which laws apply to processing personal information related to them.

We will give you choices about how we use and share personal information related to you and respect your choices.

We will send newsletters or promotional communications to our users. To unsubscribe to these communications, you must click an “Unsubscribe” link in these emails and confirm the email address for which you would like to unsubscribe.

We collect and receive personal information related to you that we need for the purposes described in this policy. You can stop using our Website at any time; after that, we will stop collecting personal information related to you. However, as detailed above, we will store and continue to use or make available certain personal information about you.

You may request that your account be terminated and that personal information related to you be deleted by contacting us. Any termination of your account will involve deleting your account information from our live databases and storing all the information and data for such an account.

You may request a copy of the personal information related to you that we store about you by contacting us. You may also request that we transfer personal information about you or provide you with copies of such personal information to enable its transfer to a third party.

When we delete personal information related to you that we have collected from or about you, it will be deleted from our active databases. Still, we will keep a reasonable number of copies in our archives. Although we will deactivate your account, we will continue to retain the personal information related to you for legitimate business purposes as set forth above.

Web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is an HTTP header field indicating your preference for tracking your activities on our Website or through cross-site user tracking. Our Website does not respond to DNT signals.

Additional Rights Applicable to United States Residents

In addition to your rights under the general section above, if you are a resident of the United States (“US”), you are also entitled to the following specific rights under federal and state laws and regulations governing the protection of personal information and Privacy (“US Privacy Laws”), regarding personal information related to you:

• Access and Data Portability. You have the right to request that we disclose certain information about our collection and use of personal information about you over the past 12 months. Upon verification of your request, we will disclose to you:
  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting that personal information;
  • The categories of personal information that we disclosed for a business purpose and the categories of third parties with whom we disclosed that particular category of personal information;
  • The specific pieces of personal information that we collected about you;
  • Suppose we disclose personal information related to you for a business purpose. In that case, we will provide you with a list identifying the personal information categories each recipient obtained.
• Correction. You have the right to request that we correct inaccurate personal information that we maintain about you.
• Deletion. You have the right to request that we delete any personal information related to you. Upon confirmation of your request, we will delete personal information related to you from our records unless an exception applies. Note that when we delete personal information related to you that we have collected from or about you, it will be deleted from our active databases. Still, we will keep a reasonable number of copies in our archives. We will continue to retain your personal information for legitimate business purposes, as set forth under the “Specific Provisions for US Residents” section in this policy.
• Opt-out of Selling or Sharing. You have the right to opt out of the sale or sharing of personal information related to you or otherwise the use of such data for targeted advertising or profiling to make decisions that produce legal or similarly significant effects concerning you. As detailed above, we do not sell or share personal information. Still, we do engage third parties that collect personal information on our Website to provide us with services that, although they do not pay us for collecting information, the right granted to them may be considered as disclosure for the purpose of sale or sharing. You can opt out of such processing anytime by contacting us or visiting our Do not Sell or Share My Personal Information.
• Non-discrimination. You also have a right not to be discriminated against for exercising your rights under US Privacy Laws.

Exercising Your Rights

If you wish to exercise any of your rights about personal information related to you, please email us at [email protected].

You can stop using the Website at any time.

You may also control what personal information we collect from your device by changing the permissions settings on your browser or mobile device.

You may request to exercise the rights detailed under this section by submitting your request to us by emailing [email protected].

Note that only you or a person authorized to act on your behalf may make a request related to personal information about you. An access request can be made by you only twice within 12 months.

Also note that your request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and describe your request with sufficient detail that will enable us to understand, evaluate, and respond to it appropriately.

We cannot respond to your request or provide you with the requested personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you. We will only use the personal information provided in your request to verify your identity or authority to make the request.

We will do our best to respond to your request within 30 days of receipt. If we require more time (up to 30 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12 months preceding receipt of your request. Our response will also explain why we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If the request warrants a fee, we will inform you of the reasons for such a decision and provide a cost estimate before completing your request.

We will not require that you create an account to exercise your rights under this Policy, and we will not increase the cost or decrease the availability of our Website based solely on the fact that you have chosen to exercise one of your rights.

After receiving our reply, you can appeal against our decision by contacting us. We will review your appeal and provide you with our answer and our explanation of the reasons for our decision(s) within 60 days of receiving it. We will also provide you with a link (to the extent available) where you can submit a complaint with the relevant Attorney General or Supervisory Authority, as applicable.

Aggregated and Analytical Information

We use standard analytics tools. The privacy practices of these tools are subject to their privacy policies, and they use their cookies to provide their service (for further information about cookies, please see our Cookies and Similar Tracking Technologies Policy).

We use the standard analytics tools of Google Analytics, and we will use additional or other analytics tools from time to time to learn how you and other users use our Website to support its related activities and operations.

The privacy practices of these tools are subject to their privacy policies. See Google Analytics Privacy Policy at Privacy Policy – Privacy & Terms – Google.

We use anonymous, statistical, or aggregated information and will share it with our partners for legitimate business purposes. It does not affect your privacy because there is no reasonable way to extract data from the aggregated information that we or others can associate specifically with you.

Specific Provisions for United States Residents

This section applies solely to all visitors, users, and others who reside in the US.

Any terms defined under US Privacy Laws have the same meaning when used in this section.

Additionally, as used under this section and the rest of this Policy, personal information is defined under applicable US Privacy Laws.

This chapter supersedes any contradicting provisions under the other sections of this policy.

We have collected the personal information related to you described above under the sections titled “Categories of Personal Information You Provide Us” and “Categories of Personal Information that We Collect” of this Policy. Such Information consists of the following categories:

• Identifiers and personal information categories are listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the Website.
• Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Geolocation data, namely your physical location or movements.
• Inferences are drawn from any of the information mentioned above.

We obtain the categories of personal information related to you listed above from the following categories of sources:

• Directly and indirectly from you and your activity on the Website.
• Third parties such as reliable service providers.

We use the personal information related to you that we collect or receive for the purposes mentioned under the section “What Do We Do With Personal Information?” of this Policy.

We disclose personal information related to you to third parties for business purposes as described above under the section titled “Who Do We Disclose, Share, or Sell Personal Information With?”.

We do not sell personal information related to you.

Categories of Sensitive Personal Information

The Website is not intended to collect sensitive personal information (within the meaning of US Privacy Laws). We do not knowingly collect or allow others to collect sensitive personal information about you, and we require you not to provide us with any such data.

Selling and Sharing Personal Information

We do not sell or share personal information. However, we engage third parties to provide services such as analytics, marketing automation, and user experience and allow them to collect personal information on our Website.

We do not knowingly sell or share consumers’ personal information of children under 16 years of age.

The categories of personal information collected by these third parties in the preceding 12 months include identifiers, online activities, and inferences drawn from such activities.

These third parties do not pay us for collecting such information. Still, the right granted to them to collect personal information may be considered as disclosure for the purpose of sale or sharing for cross-context behavioral advertising. At any time, you can opt out of collecting personal information from our service providers by contacting us or visiting our Do not Sell or Share My Personal Information page.

Storing of Personal Information in the United States

In the United States, we store and process information from our Website, including personal information, either directly or using third parties, such as data hosting service providers. Digital Turbine has data centers in the United States.

Cookies and Other Tracking Technologies

We use cookies and similar tracking technologies to ensure our Website is continuously improved and meets your needs. Please view our Cookies and Similar Tracking Technologies Policy for more information on our use of cookies.

Information Security

Digital Turbine is committed to ensuring the security of personal information. We and our hosting services implement systems, applications, and procedures to secure personal information related to you to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security.

However, please understand that no security system is impenetrable. Although we make efforts to protect your privacy, we cannot guarantee that the Website will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Dispute Resolution

We do periodical assessments of our data processing and privacy practices to ensure that we comply with this policy, update the policy when we believe that we need to, and verify that we display the policy properly and in an accessible manner. If you have any concerns about how we process personal information related to you, you are welcome to contact our privacy team at [email protected] or write to us.

We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you.

Changes to this Privacy Policy

From time to time, we will update this policy. If the updates have minor, if any, consequences, they will take effect 14 days after we post a notice on the Website. Substantial changes will be effective 30 days after we initially posted the notice.

Until the new policy takes effect, if it materially reduces the protection of your privacy right under the then-existing policy, you can choose not to accept it and stop using our Website. Continuing to use the Website after the new policy takes effect means that you agree to the new policy. Note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required by law.

Incorporation to the Terms of Use

This policy is an integral part of the Digital Turbine Terms of Use or, if applicable, of any other service agreement between you (or the entity you are acting on its behalf) and us or any of our corporate affiliates.

Contact Us

Don’t hesitate to get in touch with us at [email protected]