Privacy Policy

  1. INTRODUCTION
    TorcAI is a Ad:Tech platform solution provider which provides advertising and monetization products/services including through digital media (whether owned or through its third party publishers), surveys, owned and operated application(s)/widgets, exchange(s) for demand/supply (owned or through its third party partners), marketing automation solutions and other services, such as, fraud detection, reporting, audiences, attribution, analytics, modelling, segments, measurement (“Marketing Platform”)
  2. SCOPE OF THIS PRIVACY POLICY
    2.1 APPLICABILITY
    This Privacy Policy explains how ION EXCHANGE collects, uses and shares information from individuals that interact with its services, offering or platforms comprising its Marketing Platform ( “Marketing Platform Services”) and its website.
  3. ION EXCHANGE AD EXCHANGE SERVICES
    TORCAI’s ION Exchange engages with third party publishers and app developers to serve ads on their digital properties on behalf of its demand side advertising partners through various channels of advertising solutions including exchanges, network, off-network etc. ION Exchange also engages in campaign planning, measurement (e.g. whether an advertisement was viewed, its timestamp etc.) and attribution of advertisements, whether by itself or through third party measurement partners.

    ION Exchange provides Media & Data market, including optimization of advertising campaigns, data analytics/enrichment, segment creation, user acquisition or re-engagement through various digital advertising channels. ION Exchange receives data into its Marketing Platform from various sources, including end user information collected by our systems, applications, partners or customers ( “Sources”), which may include third party apps and services that you use. ION Exchange is not responsible for how those third-party apps and services collect and use data.
  4. WHAT INFORMATION DO WE COLLECT?
    ION Exchange may also collect information about you when you elect to interact with our surveys or opinion-based applications.
    • (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
    • Identifier for Advertising on OTT and CTV platforms
    • International mobile equipment identity (IMEI), in certain jurisdiction as permitted by applicable law
    • (b) Location information, including:
    • Geo-location or precise location of your device if you have given the app or site permission to collect your location information
    • Location information we infer based on data collected through a WiFi identifier that your device is connected to, in accordance with applicable law and provided location access is permitted
    • Location information we infer from your device’s IP address
    • (c) Network information, including:
    • Mobile carrier
    • Network provider or ISP
    • Network type (e.g., WiFi or cellular)
    • IP address
    • IDs of WiFi access points to which your device is connected
    • Date and time of connection
    • (d) Information about apps or sites and our Software Development Kit (SDK), including:
    • App or site name or version
    • App identifier
    • SDK version
    • API key identifier
    • Other information about/on your device, including:
    • Device type (e.g., make and model)
    • Screen size
    • Operating system (e.g., iOS, Android, Windows, Blackberry)
    • Mobile browser used (e.g., Chrome, Safari, Firefox)
    • Language settings and time zone
    • App usage
    • Advertisement information. We collect information about the ad presented on your device, including: The content type of the ad (the advertiser and category, e.g. games, finance, entertainment, news)
    • The ad type (e.g. whether the ad is a text, image, video or other format based)
    • Where the ad is being served (e.g. the site, digital media or app on which the ad appears)
    • Whether you viewed, clicked or otherwise interacted with the ad
    • Survey information. We may ask users to voluntarily participate in online surveys. These surveys help brands improve their products and services offered to you. If you fill out a survey, we may collect your device information described above and information you provide, including your:
    • Age
    • Name
    • Email address
    • Phone number
    • Gender
    • Occupation and income range
    • Family size and other demographic information
    • Preference for brands, modes of travel, and other consumer choices.
  5. HOW DO WE USE YOUR INFORMATION?
    We use the information that we collect about your device to:
    • Display advertisements on your device, which may include interest-based advertising customized to your interests, preferences, locations
    • For bidding to serve advertisements and to determine which ads are most effective
    • To analyze and provide our demand partners or advertisers reports on the effectiveness of advertisements and campaigns, including across different types of devices based on our determination of devices that are related to the same person. We, or third parties whom we engage to provide this service, may use cross-device data to provide interest-based advertising services and to deliver tailored ads to users across multiple mobile devices including over the top applications and smart televisions
    • To avoid showing you the same ads too many times
    • To build custom audience segments to enable our customers and partners better target their advertisements and offers
    • To improve our Services and assist our customers and partners in improving their products and services
    • To detect, deter and prevent fraud, fraudulent traffic or to protect the security of our systems
    • We may process your survey responses and share the response data with the brands who are our customers/marketers
  6. WHO DO WE SHARE YOUR INFORMATION WITH?
    ION Exchange may share the information we collect or receive about you as described in this Policy as follows:
    • Publishers and Supply Partners. We may share your information with publishers (the app or site publishers) to help them understand how users interact with their apps and sites and advertisements on their apps and sites
    • Demand Partners and Advertisers. We may share your information with demand partners, brands and advertisers who use our Marketing Platform, to allow them to understand the performance of their campaigns; and to help them better target their campaigns, products or offerings
    • Marketing Partners. We may share your information with data partners who help us with better understanding your preferences by providing data enrichment services and measurement companies who help us with attribution and tracking of advertisements distributed through us ( “Marketing Partners”)
    • Service Providers. We may share personal information we collect about you with our third- party service providers. The categories of service providers (processors) to whom we entrust personal information include: IT and related services; fraud detection, information and services; payment processors; customer service providers; and vendors to support the provision of the Services
    • Affiliates. We may share personal information with our affiliates so that the Services of TORCAI and/or its Affiliates may be improved and otherwise to serve you and/or our customers better with all our offerings including effective content management
    • Disclosures to Protect Us or Others. 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
    • Disclosures 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.
    • International Data Transfers. Where applicable, we will protect information through other legally valid methods, including international data transfer agreements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
  7. HOW DO WE KEEP INFORMATION SECURE?
    TorcAI uses reasonable technical and organizational measures to protect the information it collects 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.
  8. HOW LONG DO WE KEEP YOUR INFORMATION?
    ION Exchange retains information collected in the context of our Marketing Platform for a period of up to thirteen (13) months, unless otherwise required by law or applicable contract. ION Exchange may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations. Further, the company may only retain and use your data: (i) in an aggregated or anonymized format; (ii) to comply with its legal obligations; (iii) to 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.
  9. OPTING OUT OF INTEREST BASED ADS
    Opting out of interest-based advertising: If you prefer not to receive interest-based advertising from TorcAI, you can opt out at any time by submitting your device ID or any other listed identifier via an email to privacy@torcai.com . If you opt-out of interest-based advertising you will still receive "generic" ads from TorcAI. To opt-out of our cross-device ad targeting, you must opt-out on every device browser and device using the appropriate opt-out methods.
    • 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@torcai.com
    • You have the right to opt out of selling of your data by clicking on the following link. To the extent the data protection laws applicable to our processing of your personal data, provides certain data subject/ consumer rights to you such as election to opt-out of sale of your data, please reach out to privacy@torcai.com
  10. COOKIES
    We use cookies and beacons to help us collect some of the information we have described above. This may be done when you interact with us or our third-party partners who enable TorcAI to collect data related to your interaction with their apps or sites for the purpose of serving relevant Ads to you and/or improve our services. We may also use cookies to provide website functionality and advertising to you, and to save you having to provide the information you have already given us on subsequent visits to our site.
    For more detailed information about the technologies we use and your ability to control those cookies, please visit our cookie policy listed on the website. We recommend that you review the privacy policies of the third-party apps, services or sites that you directly interact with to learn how those third parties use cookies.
  11. OTHER WEBSITES
    Our website and the ads we service 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.
  12. CHANGES TO THIS PRIVACY POLICY
    We may amend this Privacy Policy at any time. The amended Privacy Policy will be displayed on our site. If we make any material changes, we will notify you by means of a notice on this site prior to the change becoming effective. Please check our Privacy Policy regularly to ensure you have read the latest version.
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