Effective August 18, 2010

Greystripe provides an advertising platform and related services to connect advertisers that are part of the Greystripe’s network (”Advertisers”) with publishers of mobile applications and mobile websites (”Publishers”), by facilitating the sending of advertisements through such platform (”Ads”). Our goal is to enable Advertisers to better reach their target audience, Publishers to maximize their advertising revenue, and consumers to receive Ads that are relevant to their interests. This Privacy Policy is made available on our website at www.Greystripe.com (the “Site”), and provides information on our policies and procedures regarding the collection, use and disclosure of personal information we receive from (i) our Publishers and Advertisers (collectively, “Grestrype Customers”), (ii) consumers who view and/or interact with Ads (”Consumers”), and (iii) users just browsing the Site (”Visitors”). This Privacy Policy may be updated from time to time.  We will notify you of any material changes by posting the new Privacy Policy on the Site. You are advised to consult this policy regularly for any changes.

As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

1 – Greystripe Customers

Greystripe Customer Information: Collection and Use

This section applies to information that we may collect from our Greystripe Customers in connection with their access to and use of our advertising platform and related Greystripe technology and services (including but not limited to the Site) (collectively, the “Services”). Our primary goals in collecting information are to provide and improve the Services and to administer your Greystripe account (”Account”).  We may collect information from our Greystripe Customers in the following instances:

  • When you register with us through the Site (whether as a Publisher or an Advertiser), we will ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you. Personally identifiable information includes, but is not limited to:

    • For Publishers: name, phone number, Account password, bank or on-line account information, Federal Tax ID number, email address, postal address, device IDs;

    • For Advertisers: name, phone number, Account password, bank or on-line account information, Federal Tax ID number, email address, postal address, and click-through URLs;

    • For all Greystripe Customers: any other personal information listed in the Account registration form.

  • We also collect the other non-identifying information that you provide as part of registration and the administration and personalization of your Account (e.g., without limitation, zip code (on its own) and individual preferences).

  • We use your personally identifiable information (in some cases, in conjunction with your non-identifying information) mainly to provide the Services, complete your transactions, administer your inquiries, and contact Greystripe Customers regarding Account activities or communications relevant to Services.

  • Certain non-identifying information would be considered a part of your personally identifiable information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-identifying information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your personally identifiable information with non-identifying information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Services and to analyze and understand how our Site and Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.

  • In addition, if you are a Publisher, we may collect information related to interactions of Consumers with your mobile applications and/or mobile sites, including demographic data associated with a device ID (not personally identifiable), as described in more detail below.

Greystripe Customer Information: Sharing and Disclosure

We may share and/or disclose information that we collect from our Greystripe Customers in the following instances:

Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include personally identifiable information and we may otherwise disclose non-identifying information (including, without limitation, any device IDs and associated demographic data) and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your personally identifiable information.

Service Providers. We may employ third party companies and individuals to facilitate our Site and Services, to provide the Services on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Site’s features) or to assist us in analyzing how our Site and Services are used. These third parties have access to your personally identifiable information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Business Transfers. Greystripe may sell, transfer or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Compliance with Laws and Law Enforcement. Greystripe cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Greystripe or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.

Changing or Deleting Your Information

All Greystripe Customers may review, update, correct or delete the personally identifiable information in their registration profile by contacting us. If you completely delete all such information, then your Account may become deactivated. If you would like us to delete your record in our system, please contact us at publisher@greystripe.com with a request that we delete your personally identifiable information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

2 – Consumers Who View Ads

This section of the Privacy Policy applies to information that Greystripe may collect, access and/or obtain about Consumers who view Ads while using or accessing a Publisher’s mobile application or mobile site (”Mobile Media”).

Consumer Information: Collection, Use, and Sharing

Our primary goals in collecting, accessing or obtaining information are to deliver tailored Ads based on the inferred interests of Consumers, and measure their effectiveness with Consumers. We do this by utilizing the non-identifying information that we collect, access or obtain through cookies and Pixel Tags (as defined below) embedded on a Mobile Media on which you view Ads, in conjunction with the information about you that is provided by you or provided to us by our Publishers, to personalize the content of Ads that you see.

  • Our Publishers allow us to serve Ads on their Mobile Media. We use technology to send, directly to your browser or mobile application, the advertisements and links that appear on the Mobile Media. If you are a Consumer, we automatically receive your IP address when this happens, and we use other technologies (such as cookies and Pixel Tags, as described below) to measure the effectiveness of the Ads and to personalize the advertising content that you see on the Mobile Media. We also collect, access or obtain other non-identifying information in conjunction with your IP address; these non-identifying details include, but are not limited to, the website you are logged onto or the application you are using, the geographic location of the IP address you are using to access the Internet, the type of browser used, which and how many web pages have been viewed by you, which applications you have used, search terms used, referring/exit pages, platform type and date/time information. We may also conduct surveys by serving interactive ads that ask Consumers to provide information such as their gender and age range (e.g., 30-40, 40-50), which information will be associated with a device ID (not personally identifiable). If you are a Consumer and decide to respond, your demographic information will be associated with an anonymous device ID and used only for the purposes described in this Section 2 of the Privacy Policy. We do not collect, access or obtain personally identifiable information (such as name, username, address, phone number or email address) from you when you view or interact with Ads.

  • Independent of the information that we collect, access or obtain as described above, our Publishers also may provide us with non-identifiable information about their users, such as usage, demographic, geographic and other psychographic information that does not personally identify an individual user (for example, a user’s gender, date of birth, hobbies, or interests), which may be associated with an anonymous device ID. Occasionally, our Publishers may also provide us with a limited amount of personally identifiable information about you (such as your name) from time to time, in conjunction with this non-identifiable information. This information is collected when you visit the Mobile Media, pursuant to such Publisher’s information collection practices, which are typically outlined in a privacy policy like this one, provided on the Publisher’s website.

  • We encourage you to read the privacy policies or statements of the Mobile Media you visit. If you do not wish to allow Publishers to share your personally identifiable information with their third-party service providers (such as Greystripe), you should follow the instructions set forth in a given Publisher’s privacy policy or otherwise provided by the Publisher to indicate to the Publisher that you do not wish such personally identifiable information to be so shared. Greystripe’s Privacy Policy does not apply to, and we cannot control the activities of, such Publishers or other websites.

  • The information we collect, access or obtain about you is usually anonymous and does not personally identify you except as noted above when Publishers share a limited amount of your personally identifiable information with their third-party service providers like Greystripe. This information is used by Greystripe for the purpose of delivering Ads and measuring their effectiveness with Consumers. If we ask a Publisher to enable us to serve an Ad to a certain audience, or a Publisher requests an advertising campaign for a certain audience (for example, men ages 18-34) or audience segment (for example, women ages 25-40 who have viewed certain content) and you respond to or interact with that Ad, we may conclude that you fit the description of the audience we are trying to reach. We aggregate this information and use it to analyze trends, identify the audience most likely to respond to an advertisement and to tailor advertisement placement for members of our advertising network accordingly. This aggregated information may be shared with our affiliates, advertisers, employees, customers and Publishers. In addition, we may share with such entities any device IDs and associated demographic data. Any information shared in this context will not contain your personally identifiable information. We reserve the right to track IP addresses for the purposes of fraud prevention, and we reserve the right to release IP addresses to legal authorities.

Cookies

We use cookies in connection with Ads served through our platform. A cookie is a small data file that we transfer to your mobile device’s memory for record-keeping purposes when you are served an Ad. Cookies help us better understand the effectiveness of an Ad (for example, by tracking the way in which you respond to, select and interact with an Ad or any content provided therein, or the location and context in which you view an Ad). Our cookies do not contain any personally identifiable information and they can help control the number of times you view an advertisement.

Pixel Tags

We may also use “pixel tags” “web beacons”, “clear GIFs” or similar means (individually or collectively “Pixel Tags”) to analyze usage patterns of Consumers and to serve Ads to you that are tailored based on our analysis. A Pixel Tag is an electronic image, often a single pixel, which is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a webpage or in a mobile application and may be associated with cookies on your hard drive. Pixel Tags allow us to count users who have visited certain websites or used certain mobile applications and pages within websites, to personalize the Ads, and to help determine the effectiveness of promotional or advertising campaigns.

Advertisement Links

The Ads may contain links to other websites, including those of our Greystripe Customers. Such websites may use cookies and/or other data collection tools. Greystripe is not responsible for the privacy practices, policies or the content of such websites. Greystripe encourages you to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. Greystripe has no control over the use of your personally identifiable information by third party websites, and you should exercise caution when deciding to disclose any personally identifiable information. Additionally, Greystripe does not have access to, or control of, the cookies and/or other data collection tools that may be placed on any advertisement by a third party, including those of our Greystripe Customers, and this Privacy Policy does not cover the use of cookies and/or other data collection tools by any third party.

3 – Visitors

This section describes the information that we may collect from Visitors. To the extent you are a Greystripe Customer and visit the Site, this section will apply to you as well.

  • If you contact us by email or by filling-out a registration form, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you. In addition, we may use the personal information described above to send you information regarding the Sites and/or our services. If you decide at any time that you no longer wish to receive such information or communications from us, please follow the unsubscribe instructions provided in any of the communications.

  • When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website (”Log Data”). This Log Data may include information such as your computer’s Internet Protocol (”IP”) address, browser type or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and the Service and for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, and to better tailor it to our visitors’ needs.

  • Like many websites, we may use both session cookies and persistent cookies to better understand how you interact with the Site, to monitor aggregate usage by our users and web traffic routing on the Site, and to improve the Site and our services. In addition, please be aware that other parties may also place their own cookies on the Site, and may collect or solicit personal information from you. A session cookie enables certain features of the Sites and our service and is deleted from your computer when you disconnect from or leave the Sites. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser help file directions. As described above, most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

4 – General

The following provisions apply to everybody (Greystripe Customers, Consumers and Visitors).

Security. Greystripe is very concerned with safeguarding your information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

International Transfer. Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Greystripe transfers personally identifiable information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information, or your submission of such information to us or one of our Publishers represents your agreement to that transfer.

Links to Other Sites. Our Site contains links to other websites. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Our Policy Toward Children. This Site or Services are not directed to children under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at publisher@greystripe.com. If we become aware that a child under 13 has provided us with personally identifiable information, we will delete such information from our files.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at publisher@greystripe.com.