Effective October 4, 2018
HasOffers by TUNE (“HasOffers”, “TUNE”, “we”, “us”, “our”) provides solutions for performance marketers.
For privacy practices on TUNE’s corporate websites, please CLICK HERE.
For information on TUNE’s approach to and preparation for GDPR, please CLICK HERE.
Ad Serving is the process of delivering an ad to be shown in a web page or a mobile app.
Advertisers Companies (apps, brands) that have an product or service they want to promote.
Ad Identifiers are unique character strings associated with user devices that help monitor and measure user interactions with advertisements and apps. Examples of Ad Identifiers include IDFA (developed by Apple for the iPhone), Google Ad ID (developed by Google for Android), and Windows advertising ID (developed by Microsoft for Windows Phone). Each of these Ad Identifiers can be reset by the user.
Affiliate: An Affiliate is any website that displays advertisements on behalf of an Advertiser. The terms Affiliate and Publisher can be used interchangeably.
Clicks refers to when a User “clicks” on the advertisement and goes to the offer’s page.
Clients are HasOffers clients, and may include individual employees of a HasOffers client.
Conversions happen when the User completes the “offer” (e.g. making a purchase on an e-commerce site, installing a mobile app, filling out a survey, or doing some other action).
Cookies are small text image files stored on your computer either temporarily or permanently to allow websites to recognize users and keep track of their preferences.
Geographic Location Data can either be precise (identifying the end user’s precise location) or imprecise (identifying the end user’s city or country). In HasOffers we collect imprecise geographic data through IP address and/or wifi networks in the end user’s vicinity. We collect this data to help our clients provide more relevant advertisements and content, and to ensure we comply with country specific requirements.
Impressions occur when a User sees an ad for an Advertiser on a Publisher’s site or app.
Inventory is website or mobile app traffic from Users that can be used for advertising
IP Address is a numerical label attached to any device that connects to the Internet. Most IP addresses are dynamic i.e. the device’s IP address changes and is not persistently tied to any one device. HasOffers clients may opt to obfuscate IP addresses from certain jurisdiction. Learn more here.
Network are brokers between mobile advertisers and publishers.
Pixel Tracking are website based and usually work in conjunction with cookies. They register when the User visits a particular page.
Postbacks are server-to-server communications between parties (generally through an API).
Publishers have Inventory and display ads on behalf of Advertisers.
Users are end users, specifically individuals on websites or mobile apps that see and potentially interact with HasOffers.
What Is HasOffers And Why Do Our Clients Use Us?
HasOffers is the leading performance marketing platform, used by the world’s top mobile and desktop networks to manage their online advertising relationships. Clients use HasOffers to assess the effectiveness of their Affiliate and Publisher relationships – by measuring User clicks and conversions.
Pursuant to the TUNE Data Pledge, our clients determine the data that they provide to and collect through HasOffers. Clients’ use, collection, exportation, or any other use of end user data, including the use of TUNE products and services, is governed by their own privacy policies and applicable laws, rules, or regulations.
How Do Clients Collect User Information Using HasOffers?
At the direction of our clients, who act as data controllers, HasOffers collects the following types of information from Users to help clients optimize and measure their advertising network, affiliate and publisher relationships:
- Ad Identifiers
- IP address
- Pixel Tags
- Imprecise Geographic Location Data derived from IP address and/or wifi networks
HasOffers also collects this information from employees of Clients who access information using their Hasoffers accounts to maintain up-to-date contact information.
Clients can also choose to view and measure information provided by other third-party sources in the HasOffers platform. Those sources may include: Advertisers, Publishers, Affiliates, and other Networks and analytics partners. Affiliates may sign up with Advertisers through the HasOffers platform or through their own customer website. Affiliate information provided to our Advertisers will be used by TUNE for fraud prevention purposes and to fulfill contractual requirements with our Advertisers.
Clients own the data that they provide to and collect through the HasOffers platform. When clients remove or export their data from the HasOffers platform, their use of data is governed by their own privacy policies and applicable laws, rules, or regulations. HasOffers by TUNE serves as a data processor, acting at the direction of our data controller clients. Specific fields that likely contain personal data, such as IP address or device ID, may be obfuscated or blanked, respectively, by the HasOffers client. Additional information on how we categorize and treat data is available here.
How Do Clients Use HasOffers To Collect Information From Users?
Clients use HasOffers for pixel or server postback tracking to collect information about Users. Pixel tracking (also called “cookie-based tracking” and “client-side tracking”) methods store a HasOffers session identifier in a user’s browser cookie on click. In postback tracking (also called “server-side tracking”), HasOffers directly sends a session identifier to the advertiser on click. On conversion, the advertiser then communicates that identifier to HasOffers for validation.
HasOffers 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 a Client chooses to monitor, HasOffers collects information from the User’s computer or device, including but not limited to IP and Ad Identifiers.
How Do Clients Use HasOffers To Process Information From End Users?
- 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 – HasOffers 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).
What Information Does HasOffers Collect From Clients?
Signing up as a Client requires setting up a HasOffers account. To do this, we will need contact details – including mailing and/or billing address, email address, company name, and website URL. Clients will also need to provide a user name and password to set up a HasOffers account. Please note that TUNE treats all Client contact details as confidential business information that will only be used to service Client accounts and respond to Client, Affiliate or Publisher inquiries in accordance with a contractual agreement or applicable agreement by and between the parties.
In Which Instances Might HasOffers Share End User Data With Third Parties?
HasOffers may disclose end user data in the event we reasonably suspect fraudulent, malicious, or unlawful activity, or invalid traffic, or believe that we are legally required to do so. HasOffers may also share anonymous aggregated data derived from the HasOffers platform, including, for example, statistics about HasOffers platform activity. Finally, we may transfer such data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.
Can Users Disable Cookie And Id Tracking Through HasOffers?
End users can disable cookies in most internet browsers. An overview of the process is available here. 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 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.
End users should also note that TUNE collects information on behalf of its clients. To opt out, please see optoutmobile.com or contact the data controller directly. We will actively work with our clients to fulfill such requests as reasonable and required by law.HasOffers is a participant of the Google Third Party Serving Compatibility Program. Clients that choose to advertise with Google must abide by Google’s Third-Party Ad Serving Policy available at https://support.google.com/adspolicy/answer/94230, as well as privacy principles to which HasOffers ascribes, including with regard to data collection, functional cookie opt-outs, and ad identifier tracking.
How Does TUNE Adhere to GDPR Principles?
TUNE serves as a data processor under the GDPR, and adheres to the principles and rules of the GDPR. Specifically, TUNE 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 subprocessors 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.
EU To U.S. Transfers
TUNE has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. See TUNE's Privacy Shield Statement here. To learn more about Privacy Shield, please visit www.privacyshield.gov.
TUNE 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.
What Happens If This Privacy Statement Is Changed?
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
2200 Western Ave., Suite 200
Seattle WA, 98121
CEO: Peter Hamilton
TUNE has also appointed an external ePrivacy GmbH as its external Data Protection Officer. For all requests concerning the security of your data, you can contact our data protection officer at "firstname.lastname@example.org." If you have a particularly sensitive request, please contact our data protection officer by postal mail (available below).
External Data Protection Officer
represented by Prof. Dr. Christoph Bauer
Große Bleichen 21, 20354 Hamburg