Privacy Policy

Last Updated: [March 29th, 2023]

This Privacy Policy (“Privacy Policy”) is posted by Influence Mobile, Inc. (“Influence Mobile” or “we” or “us”), registered at 1916 Pike Place, Suite 12 #1363, Seattle, WA 98101. The Privacy Policy describes how and when we may collect, use, secure, store, share and otherwise “process” information collected in connection with our mobile apps (“App(s)”), websites, content, products, any type of digital destination we may operate and any related services (collectively the “Services”), and your choices regarding that information.

As used herein, the term “App(s)” refers collectively to any application where this Privacy Policy is posted, including without limitation Rewarded Play and Beauty Rewards. Likewise, the “websites” referenced above include any website where this Privacy Policy is posted, including without limitation https://influencemobile.com/.

As used herein, “Affiliates” refers collectively to Influence Mobile Exchangeco Inc., Influence Mobile Canada Inc., and Blind Ferret Entertainment Inc.

This Privacy Policy is incorporated into and forms a part of the Influence Mobile Terms of Use, which constitutes a binding agreement between you and Influence Mobile.

Please read this Privacy Policy carefully. We may update it from time to time by posting a new version with an updated date. If we make material changes, we will notify you, prior to the changes becoming effective, through the Services. Your continued use of the Services after the date first appearing on the Privacy Policy will be an acknowledgement of our updated practices (unless, in compliance with applicable law, we are required to obtain your consent to any new processing, in which case we will seek your consent through the Services).

Table of Contents

  1. Information We May Collect and How We Collect It
  2. Information You Provide
  3. Information Collected or Generated When You Use our Services
  4. Information Collected Using Cookies and Similar Technologies
  5. Information Collected From Other Sources
  6. How We Use Information
  7. How We Share Information
  8. Interest-Based Advertising
  9. Your Rights and Choices
  10. Accessing, Updating, or Correcting Your Data
  11. Deleting Your Data
  12. Communication Preferences
  13. Other Rights
  14. Data Retention
  15. Security
  16. Use by Minors
  17. Information for Individuals in Canada
  18. Additional Information for persons located in the EEA, United Kingdom, and Switzerland
  19. Location of data processing and data transfers
  20. Rights and Choices Available to persons in the EEA, UK or Switzerland
  21. Legal Basis for Processing Personal Data
  22. Points of Contact
  23. Additional Information for Residents of California
  24. Contact Us

 

Information We May Collect and How We Collect It

We may collect various types of information, including information you provide or make available to us directly, information collected from your devices (including web and mobile), and information collected from other sources, like social networking sites and gaming partners. We have provided more details and examples of each category of information, below. 

Some of this information may be considered “personal information” or “personal data” under applicable privacy or data protection laws. As used herein, the terms “personal information” or “personal data” generally refer to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with a particular data subject, consumer, or household.

Information You Provide

You may provide personal information directly to Influence Mobile when you:

  • Use or access the Services;
  • Communicate with or contact others using our Services, including when you use “invite a friend,” or other similar features;
  • Contact us, including in writing or by telephone for customer or technical support; or
  • Complete surveys offered by us or on our behalf.

In order to register an account, you must provide us with a first and last name and a phone number. Depending on how you choose to use the Services, you may also provide us with the following personal information:

  • Your email address, home address or shipping address, and other contact information; and
  • Your age, date of birth, and gender.

If you opt-in to one of our surveys (currently available to users in the US), you may choose to provide us with the following:

  • Information about your health;
  • Information about your race and ethnicity;
  • Information about your employment;
  • Information about your education;
  • Information about your household; and/or
  • Information about your shopping habits.

Information Collected or Generated When You Use our Services

When you access or use our Services, we collect information from and about you and the device(s) you use. This may include the following information:

  • IP address, unique device identifiers, advertising identifiers, device serial numbers, and similar identifiers;
  • Hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, or clickstream data;
  • App activity data, including which third party apps you have installed and data related to the use of third party apps installed via our Services;
  • Approximate geolocation data, zip/postal code (inferred from your IP address, using publicly available data); and/or
  • Scores and achievements, points accrued, and other information as reasonably required to offer and enhance our Services.

Information Collected Using Cookies and Similar Technologies

We may use cookies, beacons, software development kits, mobile analytics software, and/or similar technologies (which we refer to in this Privacy Policy under the general term “cookies”) for a number of purposes, including to authenticate users, prevent fraud, remember preferences and settings, analyze advertising and messaging campaigns, analyze traffic and trends, personalize content (including ads), and otherwise provide the Services. These technologies may collect information about your use of our Services, pages you view, links you tap, third party applications you access, messages you open, and other actions taken in connection with our Services, as well the information referred to above, under the sub-heading “Information Collected or Generated When You Use our Services“.

Depending on the choices and settings available for the browser(s) you use, you may be able to disable cookies in your browser settings. Additionally, depending on your location, we may be required to seek your consent before cookies can be used, in which case we will present you with consent options when you access the Services.  If you disable cookies or refuse consent, the availability and functionality of our Services may be impacted. For information on interest-based advertising and how to opt out, see the Interest-Based Advertising section below. 

Information Collected From Other Sources

We may also collect information about your approximate location (including your zip/postal code, which we infer from your IP address), from other sources, including from our third-party partners or service providers and publicly available sources. We may also receive feedback from other players, or social networking sites as described below. We may combine this information with other information in our possession, which helps us to update, enhance, and analyze our Services, and provide tailored experiences for you.

How We Use Information

We may use the information we collect for a number of business and commercial purposes, including to:

  • Internal operations: Perform internal operations necessary to develop, provide, maintain, and improve our Services, including troubleshooting, providing customer and technical support, and conducting data analysis, testing, and research.
  • Business model: To support our business model, which requires us to track third party app installations (conversions).
  • Core in-app Services: Perform our core in-app Services, including awarding points and rewards to users based on their active usage of our third party partner applications and enabling in-app gift card redemption.
  • Personalization: Understand how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns and tailoring third party app recommendations to you based on your location, your gender and age, and your mobile device’s operating system).
  • Security and integrity: Maintain the safety, security, and integrity of our Services (and monitor compliance with our Terms of Use), for example by authenticating users and providing account security and fraud detection.
  • Facilitation of social connections: Facilitate your communication with friends and other users, and enable features that allow you to share information with other people, including via social media and other third party platforms (for example, if you choose to use our invite a friend feature or embedded sharing options).
  • Legal: Comply with legal requirements and/or to investigate or address claims or disputes relating to your use of the Services.
  • Marketing: Market our Services (including any new features, promotions or offers, as well as any existing, new or related Apps) to potential and existing users, including through in app messaging and push notifications. 

How We Share Information

We may share the information we collect about you with a variety of third parties in various ways, including:

  • With vendors, business partners, and other third-party service providers as necessary to carry out work on our behalf and otherwise support our provision of the Services, including vendors that provide us with IT infrastructure and software, professional services (such as legal, tax and accounting), marketing or promotional strategy, and analytics tools.
  • With our game developer business partners, for the purpose of establishing appropriate conversion rates based on your app installations;
  • With other players, to enable you to interact with them, including when you use “invite a friend,” or other similar features, and to share App-related data such as gift card wins and other leaderboard information;
  • With the general public, if you choose to share information when contributing content to our Services through a forum, blogs, social features, or the like (to the extent such opportunities may be made available, from time to time);
  • With others who share your device, if you make your account available to them through that device;
  • With specific third parties if we believe disclosure is required by applicable law, regulation, or legal process;
  • With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our terms or other policies, and/or are fraudulent or in violation of applicable law, or as we determine necessary to protect the rights, property, or safety of Influence Mobile or others;
  • In connection with a merger, consolidation, restructuring, sale of company stock and/or assets or other corporate change, including during the course of any due diligence process; and/or
  • In an aggregated form or otherwise in a form that cannot reasonably be used to identify you.

In some cases, we may enable you to access third-party products or services through our Services. Please note that those products or services are offered by people or companies not affiliated with or controlled by us, and we are not responsible for their actions, their terms, their use of information, or their products or services. If you submit your information to a third party, that third party’s treatment of your information is governed by their privacy policy, which may differ from this Privacy Policy and which we encourage you to review. In the event of any conflict between this Privacy Policy and any such other privacy policy, the other privacy policy will govern only with respect to the applicable services covered by such other privacy policy.

Interest-Based Advertising

We may work with third-party advertising partners in the event that we serve third party advertisements within our Services. In such case, we may share information about you (including your approximate location, advertising identifiers, gender and age) with these partners to make advertising more relevant, measure its effectiveness, and help recognize your devices and serve ads. We or they may also employ cookies or similar technologies, as described above, to ensure appropriate advertising and personalized experiences.

If you prefer to opt out of having your information used for interest-based advertising, you can learn how to do so by clicking here, or if located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, by clicking here. If you would prefer to opt out of having information about your App usage used for interest-based advertising, you may do so through your device settings (“Limit Ad Tracking” on iOS and “Opt Out of Ads Personalization” on Android). Depending on your location, we may be required to obtain your consent prior to obtaining your personal information, including for interest-based advertising purposes, in which case we will present you with consent options when you access the Services. Please note that if you opt out or fail to provide consent, you may continue to receive generic ads that are not based on your preferences. 

Your Rights and Choices

You can access and modify any personal and other information that is made available to you in your account or otherwise through functionality within our apps, as may be made available from time to time. You can manage your information as described below, by contacting us, and you may also have additional rights related to that information as described elsewhere in this Privacy Policy.

Accessing, Updating, or Correcting Your Data

You are expected to maintain accurate, complete, and up-to-date information in connection with your account, but we provide you functionality to update or correct that information directly in-app.

Deleting Your Data

We offer you the ability to request deletion of personal information we have collected and stored about you, subject to our Data Retention policy described below. If you would like to have your personal information deleted, please contact us at 888-973-0809 or email us at [email protected]. We will respond to your request consistent with applicable law. Please also note that if you request deletion of your personal information, you may no longer be able to use or access the Services, and if you share devices with someone else who uses the Services, that person may lose their progress or related account information and access. If you decide to use or access the Services again, Influence Mobile may consider this a new account and may collect personal information associated with that account in accordance with this Privacy Policy.

Communication Preferences

Email, phone, and text: We may contact you (for customer support or user authentication purposes) at the email address(es) or phone number(s) provided in connection with your account. You may opt out of these messages by following the unsubscribe instructions in the message (e.g. by tapping an unsubscribe link or replying “STOP”).

Push: In connection with certain Services, you may choose to opt in to receiving push notifications. If you no longer want to receive them, you can turn them off at the device level.

Cookies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Depending on your location, we may be required to obtain your consent prior to using cookies to access your information, in which case we will present you with consent options when you access the Services. Please note that if you choose to remove or reject cookies (or fail to consent to their use), this could affect the availability and functionality of our Services.

Other Rights

In some cases, particularly if you are a resident of the EEA, the United Kingdom, or Switzerland, or if you are a resident of the State of California, you may have additional rights with respect to your personal data or personal information as defined under applicable laws. For more information on these rights, please refer to the additional disclosures below.

Data Retention

We may retain personal information where required by law or where we have an ongoing legitimate business need to do so. For example, we may retain such information to provide you a service you have requested, to comply with applicable legal, tax or accounting requirements, or where necessary for fraud prevention, dispute resolution, enforcement of our contracts and terms, or for safety reasons (e.g., we may retain certain information about an account to prevent that user from opening a new account).

Security

We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession, and only those at Influence Mobile with a legitimate business need to access your personal information are permitted to do so. We also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us.

Use by Minors

We do not knowingly collect or process personal data from or about, or direct or target interest-based advertising to, anyone under the age of 16, nor do we knowingly allow such individuals to use our Services. If you believe we might have any data from or about a child under this age, please contact us. If we learn that we have inadvertently gathered such information, we will delete it.

Information for Individuals in Canada

Your personal data is maintained on our servers or those of our service providers and will be accessible by authorized employees, agents and representatives who require access for the purposes described in this policy. You may request access to or correction of the personal data in our custody or control by contacting us as set forth in the “Contact Us” section. Your right to access and correct personal data is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before providing access or making corrections.

Additional Information for persons located in the EEA, United Kingdom, and Switzerland

Location of data processing and data transfers

Influence Mobile is a global business headquartered in the United States. When you provide personal data to us or when we otherwise collect or obtain your personal data for processing as described in this Privacy Policy, we process your personal data in the United States or such other jurisdictions in which we utilize third party service providers. The laws governing our processing of personal data in such jurisdictions may differ from those in the jurisdictions in which you are located.  Regardless of where your personal data is processed, we will treat it in accordance with applicable data protection laws and this Privacy Policy. 

With respect to personal data originating in the EEA, UK or Switzerland, we will only transfer it in or to a country that provides an adequate level of protection or by implementing appropriate safeguards to protect your personal data, including through the use of standard contractual clauses or another lawful transfer mechanisms approved by the European Commission and/or the UK or Swiss authorities (as applicable). For more information about the lawful transfer mechanisms we rely on, please contact us.

Rights and Choices Available to persons in the EEA, UK or Switzerland

If you are a located in a member country of the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you may have the following rights with respect to any information about you that constitutes “personal data” under EEA and UK law:

Access your personal data: You may have the right to obtain confirmation regarding whether we process your personal data and obtain a copy of the personal data we have collected about you. (Note that this right only applies to personal information relating to you, and not to any other player.)

Rectify or correct your personal data: You may have the right to correct your personal data where it contains inaccuracies.

Request erasure (deletion) of your personal data: You may have the right to request that Influence Mobile delete your personal data in certain cases, for example when it is no longer necessary to fulfill the purposes for which Influence Mobile collected it. This right may be limited to the extent that Influence Mobile is permitted or required by applicable law to retain the data. (Note that if you request deletion of your personal data, you may no longer be able to use or access the Services. If you share devices with someone else who uses the Services, that person may also lose game progress or related account information and access. If you decide to use or access the Services again, Influence Mobile may consider this a new account and may collect personal data associated with that account in accordance with this Privacy Policy.)

Restrict or object to the processing of your personal data: In certain cases, you may have the right to object to Influence Mobile processing of your personal data, or request that Influence Mobile restrict that processing. Because the data that Influence Mobile collects is generally required to provide the Services to you, if you object to the processing of your personal data, this may have the same effect as requesting deletion of this data (i.e., you may no longer be able to use of access the Services). This right may be limited to the extent that Influence Mobile is permitted or required by applicable law to continue processing the data. 

Request a portable copy of your personal data: In certain limited cases, you may be able to request that Influence Mobile provide you with a copy of your personal data in a structured, commonly used and machine-readable format so that you can transmit it elsewhere.

To protect the privacy of your information, Influence Mobile verifies your identity and processes all rights requests through our customer support system. If you wish to exercise any of the rights described above, please contact us at 888-973-0809 or email us at [email protected]  

In addition to the rights described above, if we have collected and processed certain types of personal data with your consent, you may withdraw that consent in the manner described when you provided consent. Withdrawing your consent will not affect the lawfulness of any processing conducted prior to then, nor will it affect any processing based on lawful grounds other than consent.

In some cases, you may have the right to file a complaint with a data protection authority about our collection and use of your personal data. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us.

Legal Basis for Processing Personal Data

If you are from the EEA, the United Kingdom, or Switzerland, our legal basis for processing your personal data will depend on the type of information in question, the context in which we collect it, and the purpose for which we process it. In general, we process your personal data from you only where we need it to perform a contract with you, or where it is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to process your personal data or may otherwise process it to protect your vital interests or those of another person. In certain circumstances we may obtain your consent to process your personal data and will explain the specific purposes for the processing at such time. 

More information about the legal bases on which we rely are set out below, by reference to the purposes for which we process personal data (each of which are described in full, above, under the heading “How We Use Information”):

Purpose of processing Legal basis
Internal operations
  • Legitimate interests (our interests in ensuring the proper management of our business and success of our Services) 
  • Contract (fulfillment of our contract with you)
Business model
  • Legitimate interests (our interests in tracking user conversations rates and being remunerated by our business partners, which is core to our business model and which allows us to deliver rewards to users).
Core in-app Services
  • Legitimate interests (our interests in providing quality Services to our users to ensure continued engagement and growth) 
  • Consent (where necessary, we will seek your consent to allow us to undertake processing necessary for the functioning of the Services, including tracking your third party app usage and determining what apps you have loaded on your device)
Personalization
  • Legitimate interests (our interests in providing personalized Services to you which we have found to be more engaging to our users and more likely to drive use of our Services) 
  • Consent (where necessary, we will seek your consent to allow us obtain information to allow us to personalize our Services)
Security and integrity
  • Legitimate interests (our interest in keeping our Services secure and safe for our users and our business and ensuring compliance with our Terms of Use as well as internal policies and procedures)
Facilitation of social connections
  • Legitimate interests (our interest in providing functionality to our users to allow them to invite friends / share information related to our Services via social media to increase our overall user base and enhance our users’ experiences)
Legal
  • Compliance with a legal obligation
  • Legitimate interests (our interests in ensuring we comply with laws applicable to us in the jurisdictions in which we do business)
Marketing 
  • Legitimate interests (our interests in promoting and driving interest in our Services)
  • Consent (where necessary, we will seek your consent to send marketing communications to you)

If you have questions about the legal basis on which we collect and use your personal data, please contact us. We have appointed DataRep as our data protection representative in the UK and EU so you can contact them directly in your home country. 

(If you choose to mail DataRep please make sure that you mark your letters to ‘DataRep’ and not ‘Influence Mobile’, or your inquiry may not reach DataRep. Please refer clearly to influence Mobile in your correspondence).

Points of Contact

Data Controller EU Representative UK Representative
Influence Mobile, Inc.
[email protected]For general inquiries:
[email protected]
DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany

DataRep, 72 rue de Lessard, Rouen, 76100, France

[email protected]

DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom

[email protected]

Additional Information for Residents of California, Virginia, Connecticut, Utah, or Colorado

Influence Mobile is providing the following details regarding the categories of Personal Information about California, Virginia, Connecticut, Utah, or Colorado residents that we have collected (online and offline) or disclosed within the preceding 12 months. This Notice does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us.

Personal Information is information that identifies, relates to, or could reasonably be linked with a particular resident or household.  

We collected the following categories of Personal Information:

  • Identifiers: Name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol (IP) address, email address, account name, device information, or other similar identifiers;
  • Customer records information: Name, physical characteristics or description (i.e., gender), address, telephone number or network;
  • Characteristics of protected classifications under California or federal law: gender identity, gender expression, age;
  • Commercial information: products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Internet or other electronic network activity information: Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement;
  • Geolocation data; and
  • Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

We collect this Personal Information from you as well as from our joint marketing partners.  We use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including using Personal Information to:

  • Fulfill your requests, process your transactions, and respond to your inquiries;
  • Develop, improve, repair, and maintain our products and services;
  • Personalize, advertise, and market our products and services;
  • Conduct research, analytics, and data analysis;
  • Maintain our property and our records, and undertake quality and safety assurance measures;
  • Conduct risk and security control and monitoring, and detect and prevent fraud;
  • Perform accounting, audit, and other internal functions, such as internal investigations and record-keeping;
  • Carry out corporate transactions, such as mergers, joint ventures or acquisitions;
  • Comply with law, legal process, and internal policies, and exercise and defend legal claims.

We disclosed the following Personal Information to third parties for our operational business purposes:

  • Identifiers: Name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol (IP) address, email address, account name, device information, or other similar identifiers;
  • Customer records information: Name, physical characteristics or description (i.e., gender), address, telephone number or network;
  • Characteristics of protected classifications under California or federal law: gender identity, gender expression, age;
  • Commercial information: products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Internet or other electronic network activity information: Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement;
  • Geolocation data; and
  • Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

We disclosed these categories of Personal Information to our Affiliates and trusted third-party service providers.

We DO NOT “sell” your Personal Information for money. However, our delivery of research results to our clients in exchange for a fee may constitute a “sale” under the CCPA, or in other states, like Virginia, this information sharing may qualify as “targeted advertising” (collectively, “personalized advertising”) and therefore we may have “sold” the following categories of Personal Information:

  • Identifiers: Name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol (IP) address, email address, account name, device information, or other similar identifiers;
  • Customer records information: Name, physical characteristics or description (i.e., gender), address, telephone number or network;
  • Characteristics of protected classifications under California or federal law: gender identity, gender expression, age;
  • Commercial information: products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Geolocation data.

Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

If you are a California, Virginia, Connecticut, Utah, or Colorado resident, you may request that we:

  • Disclose to you the following information covering the 12 months preceding your request:
    • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
    • The specific pieces of Personal Information we collected about you;
    • The business or commercial purpose for collecting or selling (if applicable) Personal Information about you;
    • The categories of Personal Information about you that we sold and the categories of third parties to whom we sold such Personal Information (if applicable);
    • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
  • Delete Personal Information we collected from you.
  • No longer “sell” your information as described above.

To make a request for the disclosures or deletion described above, please contact us at 888-973-0809 or email us at [email protected]. To opt out of the “sale” of your personal information as described above, please click here. We will respond to your request consistent with applicable law.

You have the right not to receive discriminatory treatment by Influence Mobile, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services. Please understand, however, that certain exercises of your rights may render it impossible for us to render services to you.

California residents  also have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided above. In order to verify you have authorized an agent we will require a signed, written authorization from you.

If you make a request, please note that we may ask you for additional information to verify your identity. This information may include: your full name, phone number, email address, or other basic personal information about you that we already have on file.

If you prefer to opt out, find more information here

Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at 888-973-0809 or email us at [email protected]. You may also mail us at Influence Mobile, 1916 Pike Place Ste 12 #1363, Seattle, WA 98101. We will respond to your request consistent with applicable law.

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