Privacy Policy

1. Information Collection

1.1 Personally Identifiable Information

While using the Services, we will ask you to provide us with certain personally identifiable information that can be used to contact or identify you and administer your account (“Personal Information”). Personal Information may include, but is not limited to, your name, country of residence, email address, financial information, and website address.

1.2 Non-Personally Identifiable Information

When you access the Site or use the Service, (whether such use is performed on the Site or on a website of one of our partners or other third parties), we collect the following:

Information regarding your use of the Service, including without limitation, the subject of your query, the search engines that you use, and all information collected by us in performing the Service for you (“Analytical Data”).

Information that your browser sends whenever you visit a website or online service (“Log Data”). This Log Data may include, but is not limited to, your computer’s Internet Protocol address, browser type, the web page you were visiting before you came to the Site and information you search for on the Site.

When you use a widget or any other tool offered by us, whether on the Site or on a third-party website, including a website owned or operated by you, we may record data related to that activity, the deployment of the widget or tool and any other account related data.

Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use “persistent cookies” to save your username and login password for future logins to the Site. We use “session ID cookies” to enable certain features of the Services, to better understand how you interact with the Services and to monitor web traffic routing on the Site and aggregate usage of the Services. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the website you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Services.

Third party websites which may advertise on the Site and other third parties that you interact with through your use of the Service may also place or read cookies on your computer’s browser, which enables them to collect information about users who view or interact with their advertisements and content. The collection and use of such information and access of any third-party websites are subject to such third party’s privacy policy.

1.3Information Collected from Others

We and our licensors allow you to place certain scripts and code which it has developed for installation and use on your website, so that certain Shoogloo Network applications can be used and accessed by visitors to your website. If you install and deploy an application made available by us, such as a widget (the “Application”), on a website and/or provide the Application for a third party to place on their website or social networking site web page, we may collect on your behalf certain tracking and usage data generated or provided by users (“End Users”) of the Application (“Usage Data”). This information includes general Application usage patterns, Analytical Data with respect to searches conducted through the Application, Log Data from users of your website and other information and statistics regarding your website or the domain in which the Application is located. You may also request that we receive or gather personally identifiable information as part of that Usage Data, including but not limited to email addresses of End Users. Other than as necessary to provide you with the Services and subject always to the express consent of an End User, we will not review, access, share or disclose Usage Data.

1.4Affiliated Sites

We offer and provide access to the Service in connection with other websites. Personal information that you provide to those sites may be sent to us to deliver the Service. We process such information in accordance with this Privacy Policy. The affiliated sites may have different privacy practices and we encourage you to read their privacy policies.

1.5Links

We may present links in a format that enables us to keep track of whether these links have been followed.

1.6Third Party Sites and Mobile Applications

This Privacy Policy applies only to the Service. We do not exercise control over the sites that provide administration of the Site and the Service (including without limitation bill and credit card payment processing, ranking or other information), or over banners, other advertisements, or links from within the Site or the Service. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the Personal Information that you submit. We encourage you to read the privacy policies and other terms of the other websites before using their services.

2. Affiliate Network Tracking Platform

Shoogloo Network uses the third-party affiliate tracking platform “Trackier” to process information from end-users. Trackier provides solutions for performance marketers and Trackier is used by mobile and desktop networks to manage their online advertising relationships. Shoogloo Network uses the following domains to redirect all traffic that is routed via its affiliate network tracking platform: “tsm.s3g6.com” and “shoogloo.gotrackier.com”.

2.1Usage

Shoogloo Network uses Trackier to assess the effectiveness of their Affiliate and Publisher relationships – by measuring user clicks and conversions, with a view to:

• Measuring the performance of ad campaigns
• Measuring the performance of Affiliates, Publishers, and Networks
• Creating customized performance reports (for example, how well a particular advertisement is performing in a particular geographic region)
• Determining when Users respond to ads.
• Ad serving – The platform uses data that does not personally identify users to target advertising for Clients. End users can be targeted by device type (OS, Make, Model) and imprecise geographic location (state and region).

2.2Types of Information

At the direction of Shoogloo Network, through Trackier collects the following types of information from users to help us optimize and measure our advertising network, affiliate, and publisher relationships:

• Ad Identifiers
• IP address
• Cookies
• Pixel Tags
• Imprecise Geographic Location Data derived from IP address and/or Wi-Fi networks.

2.3Third-Party Sources

Shoogloo Network can also view, and measure information provided by other third-party sources in the Trackier platform. Those sources may include Advertisers, Publishers, Affiliates, and other Networks and analytics partners. Affiliates may sign up with Advertisers through the Trackier platform or through their own client website. Affiliate information provided to our Advertisers will be used by Trackier for fraud prevention purposes and to fulfil contractual requirements with our Advertisers.

2.4Ownership of Data

Shoogloo Network owns the data that is collected through the Trackier platform. Specific fields that likely contain personal data, such as IP address or device ID, maybe obfuscated or blanked, respectively, by the Trackier client.

Trackier shares the device information along with advertising id on installation for analytics and advertising purposes to understand how users interact with our app and to measure ad performance.

2.5Client-side Tracking

Shoogloo Network uses Trackier for pixel or server post back tracking to collect information about users. Pixel tracking (also called “cookie-based tracking” and “client-side tracking”) methods store a Trackier session identifier in a user’s browser cookie on click. In post back tracking (also called “server-side tracking”), Trackier directly sends a session identifier to the advertiser on click. On conversion, the advertiser then communicates that identifier to Trackier for validation. Trackier also supports server-to-server measurement for some clients. With any of the mentioned methods, when an end-user clicks on an advertisement, goes to a specific web page or mobile app action that is being monitored, Trackier collects information from the user’s computer or device, including but not limited to IP and Ad Identifiers.

2.6Cookies

User can disable cookies in most internet browsers. Disabling cookies will not, however, stop receipt of all advertisements. If an end-user would like to opt-out of a particular ad network, publisher, or advertiser’s ads, they will need to contact those companies directly to inquire whether they have an opt-out option. End users can also disable the collection of Ad Identifiers for targeted advertising by enabling the Limit Ad Tracking setting on their smartphone. End users can also reset the Ad Identifier altogether using their smartphone’s privacy settings.

2.7Tracking Technologies

We partner with third parties to display advertising on our website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this site and other sites to provide you with advertising based on your browsing activities and interests. You may opt-out by visiting the website of that specific partner like Facebook, Google, LinkedIn, Twitter and Quora.

2.8Adherence to GDPR Policy

Trackier serves as a data processor under the GDPR and adheres to the principles and rules of the GDPR. Specifically, Trackier implements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, allows for appropriate third party audits, ensures data is only transferred internationally with a lawful basis, only contracts with sub-processors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners.

2.9Security

Trackier uses commercially reasonable efforts including a variety of security technologies and procedures to secure client and end-user data from unauthorized access, use or disclosure. Personal information, especially the sensitive information about users that is maintained on Trackier systems and is protected using industry-standard security measures. We maintain a variety of physical, electronic, and procedural safeguards to guard your personal information. You should be aware that Shoogloo Network and Trackier have no control over the security of other sites on the Internet you might visit, interact with, or from which you buy products or services. You should keep your username, password or other access information safe and confidential to protect against unauthorized access to your account information and services. And you must adopt passwords that others may not guess easily.

2.10Retention of Information

Shoogloo Network through Trackier shall not retain sensitive/personal data or information of providers for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under the User Agreement or any other law for the time being in force or unless ordered to the contrary by any order of court of law. The information collected shall be used for the purpose for which it has been collected.

3. Our Policy Towards Children

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 Personal Information without their consent, he or she should contact us at info@shoogloo.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.

4. How We Use Personal Information

Personal Information is used for the following purposes: (i) to provide the Services, (ii) to administer your use of the Services and your SHOOGLOO account, (iii) to personalize your experience, (iv) to provide to you service announcements, (v) to provide you with further information and offers from us or third parties that we believe you may find useful or interesting, such as newsletters, marketing or promotional materials, and (vi) on behalf of and according to instructions of a third party, such as our advertising partners. If you decide at any time that you no longer wish to receive such announcements, information or offers, please follow the unsubscribe instructions provided in the communication.

We use information that is not Personal Information for the above purposes and to

• Monitor and analyse use of the Services and for the technical administration of the Site.
• improve the Site and the Services.
• Generate and derive useful data and information concerning the interests, characteristics, and website use behaviour of our users.
• Verify that visitors and users to the Site and of the Services meet the criteria required to process their requests.

In addition, we post ancillary privacy notices with respect to specific services.

5. Contacting Us

If you have any concerns or questions about this Privacy Policy, please contact us at info@shoogloo.com