Adwe Privacy Policy

We at Adwe, Inc. (“Adwe,” “we,” “us,” “our”) know that our users (“you,” “your”) care about how your personal information is used and shared, and we take your privacy seriously. Please read the following Adwe Privacy Policy (the “Privacy Policy”). By visiting or using the website or application, and any other linked pages, features, content, or any other services we offer from time to time in connection therewith (collectively, “Adwe”), you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways. This Privacy Policy only applies to products and services related to Adwe; other products and services provided by Adwe may be governed by separate privacy policies. Adwe is a member of the Interactive Advertising Bureau (“IAB”) and abides by the IAB Code of Conduct including its “Self Regulatory Principles for Online Behavioral Advertising”.  More information may be found here.

I. What Does This Privacy Policy Cover?

This Privacy Policy summarizes Adwe’s collection and handling of various categories of information from our users. Personal Information. This Privacy Policy covers our treatment of THE LIMITED TYPES OF “PERSONAL INFORMATION” (INFORMATION THAT ALLOWS THE IDENTIFICATION OF A SPECIFIC INDIVIDUAL) Adwe MAY COLLECT. SEE SECTION II FOR DETAILS. INFORMATION THAT IS Not Personal. It also does not apply to information that is not personally identifiable, a category which includes information that would be personally identifiable for a specific individual when standing alone, but that has been combined with the corresponding information of many other individuals (aggregated) and stripped of any individually identifying characteristics (anonymized or de-identified). Other Entities. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. No Children. Adwe does not knowingly collect or solicit any kind of Personal Information at all from children, i.e., anyone under the age of 13, and we do not knowingly allow such persons to register. If you are under 13, please do not attempt to register for Adwe or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any Personal Information to Adwe or through Adwe. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at [email protected] Information Originating Outside Of The United States. If you are located outside the United States and choose to provide information to us, that information is provided to Adwe in the United States, and may be and processed and stored in the United States and otherwise outside of your country of residence, by Adwe and by third parties with whom we share Personal Information in accordance with this Privacy Policy (as set forth in Section III below). By using Adwe, you consent to the collection, transfer, use, storage and disclosure of your information as described in this Privacy Policy, including to the export of your Personal Information outside of your country of residence.

II. What Information Does Adwe Collect?

We gather specific and limited types of Personal Information from our users, as explained more fully below. We may use this Personal Information to personalize and improve the Adwe experience, to allow our users to set up a user account and profile, to contact users, to fulfill your requests for certain products and services, to analyze how users utilize Adwe, and as otherwise set forth in this Privacy Policy. We may share certain types of Personal Information with third parties (as set forth in this Section and in Section III below). We collect the following types of information:

A. Information You Provide to Us:

1. General Information. We receive and store information you knowingly provide to us. For example, during the registration process for a Adwe user account, we collect Personal Information such as your email address and age. We may collect other Personal Information you provide us through your use of Adwe – for example, if you respond to a survey or otherwise interact with Adwe, or if you contact Customer Service. In addition, if you create a publisher or development account we will ask you for additional information such as phone number, address, financial information and SSN. You can choose not to provide us with certain information, but then you may not be able to take advantage of many of our special features or Adwe services. 2. Location Information. We may make offers available to you that ask you for, access, or track geolocation-based information from your mobile device while downloading or using our mobile application(s) or our services.  If we make these offers available to you, and you consent to enable such services, we will receive information about your location which we may collect and use to provide you with the requested services including geographically relevant features, offers, applications, and application recommendations. 3. Device ID. To provide you with certain features, such as tracking virtual rewards, organizing Adwe-related applications, and providing you with additional application recommendations, Adwe collects and uses identifiers that uniquely identify, or approximate the identification of, your device, which may include Android ID, ID for Advertising (IDFA), or MAC address (collectively, “Device ID”). Adwe may also exchange Device ID and device type information with our publisher and advertiser partners to fulfill your requests for certain products and services — for instance, with game publishers as necessary for tracking and crediting your virtual rewards for a game.  4. For Publishers and Advertisers. Different information may be needed to register for a Publisher or Advertiser account; in addition to collecting your email address, we also provide you with the option of providing us with additional information such as name and address as well as financial information such as Tax ID, VAT or sales tax registration number or any other relevant tax number and credit card information. If you choose to provide us with sensitive financial information (such as a credit card number) we encrypt the transmission of that information using secure socket layer technology (SSL), and utilize a credit card processing company to process your payment information. (This Section 4 applies to application publishers and for advertisers; it does not apply to you unless you are a publisher or advertiser who partners with us.) We also provide Publishers or Advertisers with the option of adding users to your Publisher or Advertiser account. When you do so we will collect the email address of the individual you wish to add. We will then send that individual a one-time email informing them they have been added. If you have been added to an account and wish to no longer have your email address used you may contact us at [email protected] 5. Referrals. If you choose to use our referral service to invite a friend to Adwe, we will ask you for your friend’s email address. We will automatically send your friend a one-time email inviting him or her to visit Adwe. We store this information for the sole purpose of sending this one-time email and tracking the success of our referral program. 6. Customer Support. If you notify us of a problem with our Adwe services or submit a suggestion, complaint, question, request or any other email correspondence, Adwe asks for your email address or other Personal Information so that you may receive a response. This information will be used to notify you of receipt of your submission and of a resolution to the inquiry.  We may use this information to also contact you in order to conduct surveys to improve our customer support and Adwe services. We may employ a third party service provider in order to conduct such surveys on our behalf.  That third party will be prohibited from using your Personal Information for any other purpose.

B. Information Collected Automatically:

C. E-mail and Other Communications:

We may contact you, by email or other means; for example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of Adwe. If you do not want to receive email or other communication from us, please indicate your preference in your profile or by emailing us at [email protected] Also, we may receive a confirmation when you open an email from us. This confirmation helps us make emails more interesting and improve our service.

D. Feedback:

All comments, feedback or materials submitted by you to Adwe including feedback, testimonials, images, reviews, questions, comments, suggestions or ideas (collectively, “Feedback”) shall be received and treated by us on a non-confidential and unrestricted basis. Adwe will be free to use, display, perform, distribute, copy, adapt, and promote, in any medium now known or later developed, without compensation to you, the Feedback along with all ideas, concepts, know-how, techniques or methodologies contained in such Feedback, for any purpose whatsoever, including without limitation, developing, marketing and selling products and services incorporating such Feedback. You agree that in submitting Feedback, it will not violate any right of any third party, including any confidentiality, copyright, trademark, privacy or other personal or intellectual property or proprietary rights, and will not cause injury to any person or entity. You further agree that no Feedback you submit will be or contain libelous or otherwise unlawful, threatening, abusive or obscene material, or contain viruses, commercial solicitations, or any form of “spam”. If you wish to access any personal information which may be associated with this information you can contact us at privacy at Adwe dot com.

E. Surveys or Contests:

We may, from time to time, offer you the opportunity to receive our newsletters and/or participate in contests or surveys. If you participate, we will request certain Personal Information from you including your contact information (such as name and address), and demographic information (such as zip code). Participation in these newsletters, surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this Personal Information. In the case of a contest winner, we will use the Personal Information, such as contact information, to notify contest winners and award prizes. We may also use this information to improve the quality of our products and services, including by helping us better personalize our users’ experience with our products and services. We may use a third party service provider to conduct these surveys and/or contests; that company will be prohibited from using our users’ Personal Information for any other purpose. We will not share the Personal Information you provide through a contest or survey with other third parties unless we give you prior notice and you consent.

F. Blogs & Forums:

We may ourselves manage and operate a discussion board or other forum (“Forum”) on our website, or use a third party hosted and managed site, for general matters of interest regarding our products and services. The use of any Forum is subject to the forum rules posted on the Forum website, and the use of any Forum on a third party site will be subject to that third-party website’s forum rules. Please note that if you post any personally identifiable information to any Forum, then that information can be read, collected, and used by other users of the Forum. To request removal of your personal information from our blog or community forum, contact us at [email protected] In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

III. Will Adwe Share Any of the Information It Receives?

We neither rent nor sell your Personal Information to anyone. We share your Personal Information (in personally identifiable form) with third parties only as described in this Privacy Policy, which may involve the export of your Personal Information to third parties in the United States and otherwise outside of your country of residence.

A. Agents; Service Providers:

We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we might use an email service provider to send you emails on our behalf, or a statistical data services firm to help us improve the Adwe services and provide more relevant products and services. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

B. User Actions:

You understand that we cannot control what other users do with any content (including without limitation images, ratings, captions, and comments) you voluntarily disclose for such users to view on Adwe (“User Submissions”). If you have allowed other users to have access to your User Submissions, those other users make your User Submissions publicly available to be collected and used by others, or to be redistributed through the internet and other media channels. To request removal of your Personal Information from our open forums, please contact us by way of the contact channels listed below. In some cases, we may not be able to remove your Personal Information, in which case, we will let you know if we are unable to do so and why.

C. Business Transfers:

In the event of a merger, acquisition, reorganization, change of control, sale of all or substantially all of its assets, or the sale of an individual mobile or web properties owned by us, customer information is typically one of the business assets that is transferred and we may therefore transfer and/or disclose your Personal Information to the prospective seller or buyer of such business or assets or to a third party as a part of such merger, acquisition, reorganization, or sale. In addition, if we go out of business or enter bankruptcy, Personal Information would be one of the assets transferred to or acquired by a third party.

D. Protection of Adwe and Others:

We may release Personal Information when we believe in good faith that release is necessary to comply with the law or in response to any request from any law enforcement agency or other governmental organization; to enforce or apply our conditions of use and other agreements; or to protect the rights, property, or safety of Adwe, our employees, our users, or others. This includes exchanging Personal Information with other companies and organizations for fraud protection and credit risk reduction.

E. With Your Consent

Except as set forth in A through D above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

F. Facebook Connect and Other Social Features:

Adwe may allow users to use social features, such as Facebook Connect, offered by Facebook or other third-party social networking sites (“SNS”) to interact with friends. If you opt to use such a service, by proceeding, you are allowing Adwe to access and use certain of your information maintained by the SNS, and you are agreeing to the Terms of Use provided by that SNS. By way of example, and depending on the privacy settings you have chosen at a given SNS, you might interact with friends who are also members of that SNS by automatically sharing your game reviews or other Adwe activity through the SNS (e.g., in the case of Facebook, by choosing to have your Adwe reviews automatically posted on your Timeline or choosing to use Facepile to post the Facebook profile pictures of users who have connected with your page), or by keeping up on your friends’ Adwe activity through their own automatic SNS account postings (e.g., on their updates shown on your Facebook Newsfeed). If you are not currently registered with Adwe, you can use Facebook Connect to register; when you click on “Sign in Using Facebook”, you will first be asked to enter your Facebook credentials and then be given the option to register and join Adwe. Once you register on Adwe and connect your Facebook credentials, you will be able to automatically post recent activity back to Facebook (i.e., on your Facebook Wall or Timeline). You have the option to disable Facebook Connect or similar SNS services at any time by logging into “My Profile” on your Adwe account and clicking on “Social Settings”. You can also edit your privacy settings on the SNS itself (such as Facebook) to control the extent to which your activity on Adwe appears on Facebook, or to disconnect the Facebook Connect service, by visiting the Facebook Application Settings page.

IV. Is Personal Information About Me Secure?

V. What Personal Information Can I Access?

VI. What Choices Do I Have?

VII. How Does Adwe Handle “Do Not Track” Requests?

VIII. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Use of information we collect is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will post the changes to the Adwe website and/or send you an email prior to the change becoming effective.

VIX. Questions or Concerns

If you have any questions or concerns regarding our privacy policies, please send us a message to [email protected] or call us at +1 415 799 9956. We will make every effort to resolve your concerns.

Effective Date: January 5, 2015 Last Updated: January 6, 2015