AppCloud, AppAdvisor, and DiscoveryHub Privacy Policy

Effective Date: October 2024

Table of Contents:

1. About Us.
2. Scope.
3. Information We Collect.
4. How We Use the Information We Collect.
5. Maximum Information Retention Period.
6. How We Share Information.
7. How to Control Information.
8. Children.
9. State Privacy Rights.
10. Changes to This Privacy Policy.
11. Contact Us.

1. About Us

AppCloud, AppAdvisor, and DiscoveryHub (the “Apps”) are apps operated by ironSource Ltd. (a Unity company) on behalf of AT&T Services, Inc. (“Partner”), and offer individuals who uses devices operated by Partner with the following services:

1. AppCloud – App recommendations service.

2. AppAdvisor – App manager that lets users manage their apps.

3. DiscoveryHub – A widget that provides users with app recommendations and an app that provides you with news and content.

We collect information in either of 2 ways:

1. Directly – from the Apps.

2. Indirectly - through app developers that promote their apps through the Apps (“Demand Partners”) for optimizing their campaigns, as detailed below.

2. Scope

This Privacy Policy describes our privacy practices with respect to information we process through the Apps.

The App is meant to be used only by individuals residing in the US.

If you are a resident of California, Colorado, Connecticut, Utah, Virginia, Florida, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey or Tennessee, please see the “State Privacy Rights” section of this privacy policy for information related to privacy laws in these states.

For purposes of the California Consumer Privacy Act (the “CCPA”), this Privacy Policy serves as both the Privacy Policy and Notice at Collection of Personal Information.

3. Information We Collect

1. Information we collect directly from through the Apps -

Device identifiers: Advertising ID, IMEI and IP address. The term Advertising ID refers to the Google Advertising ID. The Advertising ID is a resettable persistent identifier generated by Google.

Device information: The Apps collect technical information about a device, such as the device CPU, device manufacturer, device model, device RAM, device available storage, device locale, network type (wifi/cellular data), operating system version, SIM MCC MNC, network operator name, and other general technical details about a device, and the list of apps installed on the device.  

App usage: AppAdvisor collects the frequency on which you use apps in order to recommend you how to manage your apps.

Age and Gender: We may ask you for your general age and gender. You are not required to provide this information in order to use the Apps, but this may allow us to provide you with more relevant app recommendations.

Your Interests: We may ask you to provide your content preferences, to present you with content that fits your interests.

Interaction with the Apps: We collect information about the use of the Apps, including interactions with the Apps, whether you chose to install any app through the Apps, content that you choose to consume,and other analytical information.

Precise geo-location (if permission was granted) – Such information is not stored on our servers. We use it to display weather information in the DiscoveryHub app, relevant for your location.

2. Information we may receive from Demand Partners (“Demand Partner Information”):

Device identifiers: The device’s advertising ID.

Campaign information: an indication that a Demand Partner’s app was installed following a recommendation on the Apps; information about actions performed within such Demand Partner’s app following such an install, including in-app purchases, level in the game, and the number of times the app was opened; and other information that the Demand Partner decides to share with us.

4. How We Use the Information We Collect:

In order to provide the service, we use the information we collect in different ways. Below is a general description of how we use information across our services:

1. Providing you with the services included in the Apps – we use information to provide you with services, and content offered by the Apps, and to improve your experience.

2. Delivery of recommendations to a device - we use information to technically enable the delivering of recommendations to a device, for frequency capping, optimization of recommendations, personalizing the recommendations based on age and gender that you provide the apps that you installed and interactions with the service, and including/excluding recommendations.

3. Customization and improvement of the Apps - We use information collected from a device to ensure that the experience delivered via our Apps is customized to a device type, country, and the Partner, including the apps we dynamically preload upon first activation of the device. We also use the information to improve and optimize the Apps and our users’ experiences. 

4. Advertising - To allow third parties (as specified below) to provide you with ads within the DiscoveryHub app.

5. Reporting and billing - We use information to generate reports for and bill Demand Partners and the Partner.

6. Internal Operations - We use information for internal operations, such as debugging, support, security, providing updates to our application and improving our services.

7. Compliance with legal obligations - We may use information to comply with applicable legal obligations.

5. Maximum Information Retention Period:

We retain information for as long as necessary to fulfill the purposes for which we collected such information, except if required otherwise by law. We may store information for longer periods for archiving or statistical purposes in which case we will take appropriate measures to ensure that the information is used solely for this purpose.

6. How We Share Information:

1. Our corporate affiliates - from which we receive services, such as IT, security, storage, delivery of campaigns, and other internal operations.

2. Demand Partners - for the purposes of billing Demand Partners, and fraud prevention and detection.

3. Service providers - We share information with our service providers for the purpose of receiving services such as reporting, and storage.

4. Partner – If Partner instructs us to provide them with the information collected on their behalf.
5. Advertising partners – We share information through third party libraries integrated in the DiscoveryHub app with the following advertising partners.

We may also disclose information if we have a good faith belief that disclosure of such information is reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our agreements and policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights; or (vii) when we are undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of our assets.

7. How You Can Control Information:

1. Disabling the Apps - You may disable the Apps at any time following completion of initial setup of your device by following the instructions set forth below or by contacting the respective Partner. If you choose to disable the Apps, we will stop collecting any information from your device. In order to disable the Apps, please go to Settings -> Apps -> Application List -> AppCloud/AppAdvisor/DiscoveryHub  -> Disable.

2. Erasure and access requests – You may submit deletion and access requests through the following process: Go to Settings -> Apps -> Application List -> AppCloud/AppAdvisor/ -> Personal Data. Please note that we will process your request subject to verification and authentication of your identity.

8. Children 

Our services are not intended for children. If you are aware that our services are otherwise collecting Personal Information about children, please contact us at DPO@unity3d.com.

If you believe your child has provided us with Personal Information, you may contact us at DPO@unity3d.com and we will make reasonable efforts to delete the information from our records.

9. State Privacy Rights

California, Colorado, Connecticut, Utah, Virginia, Florida, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey and Tennessee residents have certain rights under state privacy laws with respect to personal data we collect.  If you are a resident of such states, this section of the privacy policy contains disclosures required by law and explains rights that may be available to you.

This section applies only to personal data that is subject to the state laws noted above.

In many cases, we act as a service provider or processor to collect personal data on behalf of the Partner. The Partner has its own privacy policies that describe how they use information. To the extent that we are processing personal data subject to state privacy laws on behalf of a customer in our role as a service provider or processor, we may also act as point of contact for your rights under state privacy laws with respect to the information processed by us as part of the operation of the Apps.

Personal Data Collected and Disclosed: In the past 12 months, we have collected, and disclosed for business purposes, on behalf of the Partner, the following categories of personal data. We do not knowingly sell, nor do we knowingly share or process for targeted advertising purposes, personal data about consumers under the age of 16. Although we do not sell personal data for monetary consideration, we do sell and share (as such terms are defined in applicable laws) personal data as part of the DiscoveryHub App for targeted advertising purposes, subject to users’ choices.

Categories of Sources – As described in the “About Us” section above, we collect personal data from the following categories of sources:

1. Directly through the Apps.
2. Demand Partners.
3. Analytics platforms
4. Advertising partners for the DiscoveryHub App

Our Purposes for Processing Personal Data – We use and disclose the personal data we collect for the Partner’s commercial and business purposes, as further described above in the “How We Use the Information We Collect” and the “How We Share Information” Sections.  

Recipients of Personal Data – We share personal data with the following third parties:

App developers

Advertising Partners for the DiscoveryHub App.

Service Providers.

Your Rights Regarding Personal Data – Subject to applicable law, you may make the following requests:

1. You may request to know whether we process your Personal Information, and to access such Personal Information.

• If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The business or commercial purpose for collecting or sharing Personal Information about you;
• The categories of Personal Information about you that we shared (as defined under the applicable privacy law) and the categories of third parties to whom we shared such Personal Information; and
• The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).

2. You may request to correct inaccuracies in your Personal Information;
3. You may request to have your Personal Information deleted;
4. You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format;
5. You may request to opt out of the “sale” of your Personal Information; and
6. You may request to opt out of targeted advertising, including the “sharing” of your Personal Information for purposes of cross-context behavioral advertising.

We will not unlawfully discriminate against you for exercising your rights under applicable privacy law.

While some states provide residents with rights related to “sensitive” personal data,  ironSource does not collect this type of personal data. 

Exercise your rights – To exercise any of the above rights, please contact us at the following email address: DPO@unity3d.com

Further, you may submit deletion and access requests through the following process: Go to Settings -> Apps -> Application List -> AppCloud/AppAdvisor/ -> Personal Data. Please note that we will process your request subject to verification and authentication of your identity.

To opt out of sale or share of personal data, please click on the “do not sell” (or, “do not sell/share”) link in the DiscoveryHub app settings.

Depending on your state, if you have submitted a request that you believe we have not fulfilled, you may contact us to appeal our decision by replying to our response to your request, or by contacting us at DPO@unity3d.com.

Verification Process and Required Information – Note that we may need to request additional information from you to verify your identity or process your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your email address and state of residence. We will also collect information that identifies your device when you submit a request, in order to help verify your identity.

Authorized Agent – You may designate an authorized agent to make a CCPA request on your behalf by verifying your identity and providing the agent with written permission to make the request on your behalf.

10. Changes to This Privacy Policy:

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our processing of your information and can be found by going to Settings -> Apps -> Application List -> AppCloud/AppAdvisor/ -> Privacy Policy or by contacting the respective Partner directly. By continuing to access or use an app containing our services after those changes become effective, you agree to be bound by the revised Privacy Policy.

11. Contact Us – Data Protection and Privacy

Unity Technologies

DPO@unity3d.com with a copy to: discoveryhub@unity3d.com 

30 3rd Street, San Francisco, CA 94103