Privacy Policy

Privacy Policy

LAST UPDATED: January 2021

EFFECTIVE: January 2021

1. INTRODUCTION

Adumu is a security data management company which provides data as a service and aims to enable Internet Security providers, network analysts, and/or organizations representing other industries (“Customers”) on a limited basis to transform their own digital assets into strategic knowledge and provide insights in a world of connected devices (“Data as a Service”).

This Privacy Policy explains how Adumu (“Adumu” or “we”, “us”, “our”) its subsidiaries and affiliated companies (“Affiliates”) collects, obtains, uses, secures, and/or discloses end users’ (“you” or “your”) information in the course of its Data as a Service offering (“Services”). Adumu is committed to respecting and protecting individuals’ privacy rights.

2. OUR SERVICES

Adumu may obtain information about you from various sources such as web service provider partners, Data Partners/vendors, customers, and/or application developers (“Sources”) who may collect information about you when you interact with each of them. We use this information to provide Data as a Service.

As a data platform, Adumu is not responsible for a Sources’ collection of or independent use of your data, so we urge you to refer the privacy policies of the respective Sources that you interact with.

We work to ensure that our Services respect users’ privacy rights. To accomplish this goal, we adhere to privacy-by-design and privacy-by-default principles throughout the process of designing, building, and delivering our Services.

We do not process information that directly identifies a particular individual such as an unencrypted name, address or government-issued ID number. However, whether or not User Data we receive are considered personal or personally-identifiable data depends on, among other factors, the definition that applies in a user’s physical location. For example, in some locations a user’s IP address may be deemed to be personal data, while in others it is
not.

Adumu’s processing of your data is in accordance with the applicable contract terms where the data is obtained from third parties and Data Partners. This Policy does not apply to information collected by our Data Partners or third parties who may provide information to us, as their information handling practices are covered by their own privacy policies

3. WHAT INFORMATION DO WE COLLECT/OBTAIN?

Information about your device. Adumu may purchase some or all of the following information about your device from Sources:

  • (a) Device identifiers. Device identifiers are alphanumeric strings that are unique to your device. These include:
    • iOS devices’ Identifier for Advertising (IDFA) and iOS Identifier for vendors
    • Google Advertising ID (GAID), or Android ID for Android devices
    • Cross Device IDFA/MAID Identifiers as detected by Third Parties
  • (b) Location information where permitted, including:
    • Geo-location or precise location of your device
    • General Location information we infer from your device’s IP address or Language
  • (c) Network information, including
    • Mobile carrier
    • Network provider or ISP (3G, 4G, 5G)
    • Network type (e.g., WiFi or cellular) and status
    • IP address
    • Session start/ stop time
  • (d) Information about the site, including:
    • Site name, version, or ID
    • App Usage and Browsing Data
    • Group Identifier
  • (e) Other information about your device, such as:
    • Device type (e.g., smart phone/ tablet)
    • Operating system (e.g., iOS, Android, Windows, Blackberry)
    • Mobile browser used (e.g., Chrome, Safari, Firefox) / UserAgent
    • Language settings and time zone
    • Persistent identifiers (cookie ID, Hashed IMEI, Hashed MAC)
  • (f) Demographic Data, such as:
    • city, region, gender, year of birth

Our Data Partners may collect data consented directly from users (both online and offline) or receive data from third parties.

In some countries, some of these data sets may be considered to be personal information, in which case, we ensure compliance with applicable laws in our use of the same, to the extent applicable in such jurisdictions.

Adumu does not directly interact with end users and relies on data sets obtained from third party Sources. The responsibility to obtain consent remains with the Sources. Adumu may infer the geo location of a device based on data collected through network identifier(s) that the device is connected to, subject to country specific laws and/or industry guidelines related to such collection or inference practices (e.g. pursuant to confirmation of consent from Sources).

To the extent any such information may be considered to be personal information, we comply with applicable laws in our collection or use of the same, to the extent applicable or required in such jurisdictions including certain data subject rights that you may enjoy and implement reasonable technical measures to ensure prevention of unauthorized disclosure of such personal information in our custody.

We do not maintain files on individuals’ purchases, nor sell lists of consumers. We do not collect consumer information for targeting of ads. We do not provide consumer scoring. We do not provide consumer marketing databases. We do not use any personal information collected through our Products to contact or market products or services. 

4. HOW DO WE USE YOUR INFORMATION?

Adumu may create segments, reports, profiles, insights, feeds, and conduct analytics (“Data Derivatives”) from the user data it obtains from Sources to cater to Customers from various industries in understanding network usage behavior and/or user behavior and to facilitate data matching and data enrichment.

Adumu uses your information as described above in this Policy and in accordance with your election regarding the use of your information as you may provide to the Sources. It may sell, license and/or otherwise transfer Data Derivatives on a bulk and/or aggregated format to its Customers in performing its Services. Our Customers may also use Data Derivatives for: developing their own analysis on IP and mobile network usage, to combat fraud and illicit activity, develop mobile analytics and risk modeling, general city planning, or offer related products and services.

5. WHO DO WE SHARE INFORMATION WITH?

  • Customers. Adumu may share Data Derivatives with our Customer as part of Services. Any Customer’s use of the information we share with them will be governed by their privacy policies and our contracts with them;
  • Affiliates. We may share personal or non-personal information with Affiliates so that the services of Adumu and/or its Affiliates may be improved and otherwise to serve our customers better;
  • We may use third party service providers or partners to help us operate our business; provide, support, maintain, or secure our Products and our website; or administer activities on our behalf. It may be necessary to provide or allow access to your personal information to these third-party service providers or partners for those purposes.
  • Disclosures to Protect Us or Others. We may also disclose your personal information as required by law; We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity; and
  • Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

We share the following data categories for the following purposes:

  • Customers – we share Online Identifiers, Browsing Data, Identity Data,
    Profile Data and Geolocation for the following purposes: analytics, data mapping, profiling, network measurement;
  • Hosting Providers – Online Identifiers, Browsing Data, Identity Data,Profile Data and Geolocation for the following purposes: storage;
  • Affiliates – we share Online Identifiers, Browsing Data, Identity Data, Profile Data and Geolocation for the following purposes: technical support and help Adumu operationally
    perform the services.

6. HOW DO WE KEEP INFORMATION SECURE?

Adumu uses reasonable technical and organizational measures to protect the information it collects/obtains about you in compliance with its legal and privacy requirements and contractual obligations. We also seek appropriate contractual protection from our partners regarding their collection, use or treatment of user data.

7. HOW LONG DO WE KEEP INFORMATION?

We will retain your personal information for as long as needed to fulfill the purpose for which we collected it and for a reasonable period thereafter in order to comply with audit, contractual, or legal requirements, or where we otherwise have a legitimate interest in doing so. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may retain personal information preserved in automatically generated computer back up or archival copies generated in the ordinary course of our information technology systems procedures, but those backups would be subject to the same retention period.

Adumu may retain and use user data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes and enforce agreements. Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.

Whenever possible we abide by data minimization principles and in many cases will erase data within 90-120 days.

8. OPTING OUT

Adumu does not directly interact with end users and therefore, does not collect your information directly. We urge you to refer the privacy policies of the respective Sources that you may interact with, to exercise your opt-out options.

We do not interact directly with users or their devices, unless a user sends us a deletion request along with their Ad ID or IP below.

California Residents: Additional rights for residents of the State of California (in the United States) effective the later of (i) January 1, 2020 or (ii) the date on which CCPA comes in effect:

  • You have a right to exercise certain consumer rights such as request to know/ disclose/ access/ delete your data, collected in the last 12 months, by writing to us at privacy@adumu.com.
  • You have the right to opt out of selling of your data by clicking on the following link: – Do not sell my data.

You may reach out to privacy@adumu.com for any further assistance in this regard. Where device identifiers or subscriber id or advertising identifiers or such similar identifiers are not available with us in a raw format, we may not be in a position to address your request.

9. PRIVACY OF CHILDREN

Adumu does not operate any websites, applications, or SDKs. Adumu does not knowingly target, use, store, or share information on users under 18.

Our site and our Products are not designed for or directed at children under 18. We will not intentionally collect or maintain personal information from children under 18 years of age. If we learn we have collected or received personal information from a child under 18 years without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18 years please contact us via email at privacy@adumu.com

10. OTHER WEBSITES

Our website may contain links to other websites. You should be aware that we are not responsible for the privacy practices of such other websites as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these links and we shall not be responsible for any use of such websites.

11. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time. The amended Privacy Policy will be displayed on our site with the date of the most recent change. If we make any material changes to our practices, we will notify you by means of an updated notice on this page at least one month prior to the change becoming effective. Please check our Privacy Policy regularly to ensure you have read the latest version. You are responsible for ensuring that you are aware of the most recent version this Policy.

12. YOUR INTERACTION WITH ADUMU WEBSITE

12.1 WHAT INFORMATION DO WE COLLECT?
We do not have the ability to make accounts or interact with our website and services other than normal Internet browsing. We collect information on weblogs in order to support our services as long as is reasonably necessary to monitor and secure our resources.

Please do not share any personal or sensitive information with us if you do not have the right to share the same or if you are not interested in conducted business with us. Kindly note that this Section is solely intended for business communications. We may use information about how you leave our site (e.g. which website you visit immediately after visiting our site). We may use cookies to help us collect and store this information.

12.2 HOW DO WE USE THE INFORMATION WE COLLECT?

From time to time, we may need to disclose your information to third parties such as to law enforcement authorities or our legal advisers, where it is necessary to comply with the law or regulation; enforce or apply our user terms and conditions; to protect our rights, or to preserve the safety of our resources.

We may also share your personal information with companies that provide services to help us with our business activities (e.g. processing payments or submitting emails to you on our behalf), in connection with any merger, a sale of assets, or a financing or acquisition of all or a portion of our business to another company. Whenever we share your personal information for this reason, we will ensure that the recipient is bound by all appropriate confidentiality obligations and that it is committed to using your personal information only for the purposes for which you originally provided it.

If you interact with social media features on our site, such as the Facebook Like button, or use your social network credentials to comment on our blog, these features may collect information about your use of this site as well as post information about your activities on this site to your profile page. Your interactions with these features are governed by the privacy policy of the company providing it.

12.3 HOW DO WE KEEP INFORMATION SECURE?
We use appropriate technical and organizational security measures to protect the information we collect. We use multiple electronic, procedural, and physical security measures to protect against unauthorized or unlawful use or alteration of information, and against any accidental loss, destruction, theft, or damage to information throughout the entire use cycle starting from the initial receipt until deletion. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.

12.4 HOW LONG DO YOU KEEP INFORMATION?
Considering this Section is intended for business communications and marketing only, we retain information for as long as it is necessary to fulfill the purposes outlined here and/or for engaging with you as a business partner, unless otherwise required by law.

13. CONTACTING US

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