Detailed Privacy Policy

AXWAVE COMPLETE PRIVACY POLICY

Effective Date: April 16th, 2015

Axwave is committed to being a responsible participant in the mobile and TV ecosystem and to protecting personal information about mobile application users content usage. This privacy policy explains what information we collect, how we secure it, and how we use it in relation to the service Axwave provides to its customers.

WHAT WE DO

Axwave has content recognition technology (the “Platform”) which gets integrated into mobile applications (“Apps”) using a Software Development Kit (“SDK”). Using the Platform, App Developers and Publishers (referred to collectively as “AppDevelopers”) know what their users’ are watching on TV, Over-The-Top (“OTT”) streaming content like Netflix or what music they are listening to.

Our goal in doing so is to provide AppDevelopers with a mechanism to efficiently understand what are the media consumption habits of their end-users. Specifically providing data on:

*                Live TV in US and Europe – which channel and programs are being watched

*                Use of DVR – time-lapsed channel & program viewing

*                TV Ads – which Ads have been watched

*                OTT content consumption – which TV Series & Movies.

The end-user insights on media consumption will enable the AppDeveloper to provide an enhanced user experience in the respective application.

We also provide an advertising solution for our AppDevelopers to sell available advertising inventory in their applications to our advertising buying customers.

Axwave stores, processes and analyzes this Data and produces Analytics (see Use of Information section).

In operating our services, Axwave strives to adhere to all laws and industry guidelines in relation to our privacy practices.

 HOW WE DO IT

The content is recognized by using the mobile phone microphone. The audio is immediately secured and processed by a proprietary algorithm into a “Fingerprint”. The Fingerprint is then encrypted, compressed and transferred to the server for content matching. If the content is successfully recognized then we send information about the content to the mobile app.

To help ensure user privacy and security, after the matching attempt, the Fingerprint is immediately deleted on the mobile device and the server. Even if someone was to get a Fingerprint, it is impossible to understand any recognizable audio from these Fingerprints.

TERMINOLOGY

Non-identifiable information (NII): When we refer to non-personally identifiable information (NII), we mean information such as demographic, behavioral, unique device identifiers, age, gender, zip code, or other information that alone, or in combination with other available information, does not identify the end to Axwave.

Personally identifiable information (PII): When we refer to personally identifiable information (PII), we mean information such as first and last name, email or home address, or phone number that, either by itself or in combination with data reasonably obtainable by Axwave from another source, could be used by Axwave to personally identify an end- user.

WHAT INFORMATION WE COLLECT AND HOW WE COLLECT IT

Axwave does not transmit, collect, share or store PII, but only NII in anonymous or aggregate form. Also, Axwave generally requires AppDevelopers to ensure that there are clear end-user notice mechanisms, that they have obtained all relevant permissions for all use cases, including automatic recognition, that they have the right to pass such information to Axwave and that they comply with all state and federal laws and regulations that may apply to them regarding the protection of personal information. Axwave may provide reasonable assistance to App Developers in these areas upon request. .

Mobile devices have anonymous identifiers (“Mobile IDs”) which are used by Axwave to understand which devices have recognized content and provide metadata associated with that content type, like Live TV, TV Ads, Over-The-Top OTT Video or music. The Mobile IDs do not enable Axwave to identify individuals, but can be used for certain analytics purposes, like understand how often a device has been exposed to a specific TV advertisement. If Axwave stores a Mobile ID, it would be for these analytics purposes, and would not be used to create profiles of end-users over time.

Axwave may also collect data (“Data”) that it can see about an end-user’s device and the manner in which it has connected to the Internet (such as mobile carrier, IP Address, phone model, etc.). This information is used to ensure the accuracy of the Axwave content recognition and support the functionality provided to the application. For clarity, Data includes but is not limited to: browser or device type; operating system; time of day; use of particular Service features or applications (such as, for example, viewing histories for television programs and advertisements); information about the geographic location of the end-user device (mobile or stationary) on which an App is loaded or operating. At no time will an App access, collect or store any of the personal contacts or photographs or any other information stored on the end user device without their permission.

For monetization purposes, AppDevelopers may transfer certain information to Axwave that we use to enable the delivery of relevant advertisements to consumers on their mobile phones by our ad-buying customers.

When our AppDeveloper’s end-user devices interact with our Platform, it may automatically pass information that our AppDevelopers provide or is otherwise accessible on the advertising request.  Axwave endeavors to receive assurance from our AppDevelopers that, through clear notice mechanisms, the AppDeveloper has the right to pass such information to the Platform, and that such notices advice the end-user why the information is being collected and that it’s being used for marketing purposes. Axwave may work with its partners to provide improved mechanisms to manage consumer notice and control over their marketing experience in the mobile environment.

FOR ADVERTISING WE MAY RECEIVE THIS INFORMATION FROM OUR APPDEVELOPERS OR IS OTHERWISE ACCESSIBLE BY AXWAVE:

NII.  AppDevelopers and developers may send NII to Axwave with an ad request in accordance with the AppDevelopers’ stated privacy practices and notices. Examples of this type of information include, but are not limited to, age, gender, zip code, and location information.  

Anonymous Advertising Identifiers. Many mobile devices have IDs which are accessible by AppDevelopers and which can be passed to Axwave with an ad request. These IDs do not enable Axwave to identify individuals, but rather can be used for certain advertising purposes. It can be used to limit the number of times a specific advertisement is presented to the same device, track a device to show that the device interacted with an ad (i.e. “clicked” on it, watched a video ad, or downloaded an application as a result of an advertisement). If Axwave stores an ID, it would be for these advertising administrative purposes, and would not be used to create profiles of end-users over time.

Other Information Available from the Ad Request. Axwave may also collect information that it can see about an end-user’s device and the manner in which it has connected to the Internet (such as mobile carrier, IP Address, phone model, etc.). This information is not necessarily provided by the AppDeveloper, but the information is passed from the device via an application or mobile website to support the delivery of advertising or to otherwise support functionality of the device or application. This information, however, is collected in a non-identified manner that may not be used to identify individuals.

Information Collected by Axwave Directly.  Axwave may also collect NII about how consumers interact with ads delivered, such as anonymously counting clicks. Further, when available, Axwave may partner with third-party companies that enable targeting of advertising based on information that is in addition to what the AppDeveloper may provide or is otherwise available to Axwave. When partnering with these third-party data providers, Axwave does not accept, use or store PII.  These services may have information about end-users past browsing or application use which can be used to enable the delivery of more relevant advertising to the end-user.

Cookies: Axwave website (not sdk) may use a simple technology feature on a end-users’ browser (not on mobile applications – where cookies are not generally utilized). Axwave will place a cookie on your browser unless the browser settings are set to prohibit this. Cookies are used to recognize a device they have encountered before. This may be used by Axwave for frequency capping (limiting the number times an advertisement is seen) and other advertising administrative type functions. As the mobile advertising ecosystem evolves, and if cookies or equivalent technologies become more available for mobile advertising, Axwave may amend this policy to provide further notice regarding their use.

UNDERSTANDING ADVERTISING AND TARGETED ADVERTISING

At Axwave, we try to make sure that end-users, AppDevelopers and ad-buyers have access to information that would enable them to understand best practices around advertising and targeted advertising, as well as methods to provide or take advantage of opportunities to opt-out of certain types of advertising. Targeting and Opt-out solutions are limited in mobile advertising compared to online advertising, primarily because the technologies used in online are not as readily available in the mobile ecosystem. Regardless, to ensure that end-users understand what information we may receive from AppDevelopers and developers, App Developers and developers should encourage end-users the privacy policies for mobile web sites and applications that they use.

 USE OF INFORMATION

Axwave strives to enable its marketing partners (“Partners”) to better understand how mobile devices are being used in conjunction with TV and Music, which includes Market Research companies to the advertising ecosystem. These Partners sign a comprehensive agreement which describes exactly what they are allowed to do with the data. Axwave provides its Partners with this information either in an aggregated or an anonymized form and at no time is PII information provided. Where Axwave provides information to our partners, they are contractually required by Axwave to use the information they receive in compliance with applicable laws and regulations.

Axwave stores, processes and analyzes Data (“Analytics”). This Analytics means device statistics, metrics, abstractions and other analyses that are based on or derived from the use of the Axwave technology, which are developed in the aggregate with other data or which are developed in a manner that does not disclose End-User identity or personal Data (unless in aggregated or anonymized form). At this time, Analytics are primarily related to advertising in television programming.

OTHER INFORMATION SHARING AND DISCLOSURE

Axwave may provide copies of log files to AppDevelopers and ad-buying partners and certain information relating to the performance of advertising campaigns, and other specific transactions they are a party to on the Platform.  These files contain information that allows partners to analyze the effectiveness and performance of their advertising campaigns.  Our partners also have the ability to use information collected in connection with the use of our Platform for their own purposes, provided such is in compliance with their own privacy practices as communicated to their end-users. The information provided to AppDevelopers or ad-buyer does not contain PII.  Where Axwave provides information to our partners, they are required to use the information they receive in compliance with applicable laws and regulations.

Axwave may share the information it collects with selected partners, vendors, agents or others who work on our behalf, in order to provide products or services for our AppDevelopers or ad-buying customers.  Axwave does not work with, receive or endeavor to compile PII, so information provided to third-parties will not contain PII.

Notwithstanding the other statements in this policy, Axwave may disclose information if required by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect or defend legal rights or property, or (iii) protect the personal safety of individuals or the public.

CHILDREN’S PRIVACY

Axwave does not knowingly collect, store, or use information about children under the age of 13.  If we become aware of information in our system that relates to a child under 13, we will take commercially reasonable steps to delete that information.

 STORING OF DATA AND SECURITY

Axwave takes data security seriously.  Anonymous and aggregated information that we may store on our servers is done so in a secure manner with electronic, physical, and administrative safeguards designed to protect against unauthorized access to such information.

 CHANGES TO POLICY

Axwave reserves the right to change this privacy policy from time to time, by posting a new policy on www.axwave.com.  In the event that we must make a material change to our practices or this policy, we will make every effort to update this policy at least 30 days prior to implementing the change.

If you have questions about this policy or the privacy practices applicable to Axwave’s mobile ad services, contact us at privacy@Axwave.com.

Opt-Out

The best way to ensure that Axwave is not collecting data related an end-user device is to uninstall the application that contains the Axwave SDK. If an end-user does not know which application is using the Axwave SDK, and you does not want any data stored related to the device, then he or she should email: privacy@axwave.com and we will provide instructions on how to be removed. Alternatively please contact us at:

 

Axwave Inc.
459 Hamilton Avenue, Suite 205
Palo Alto, California 94301, USA