Vpon Privacy Policy

Vpon Big Data Group (“Vpon” or “we”) is a leading big data company specializing in data analytics built with cutting-edge technologies to provide its customers and partners with the broadest set of data across Asia in delivering effective data-driven marketing solutions. To deliver our online advertising service and data services (collectively as the “Services”), Vpon provides its business partners (including advertising demand partners, data demand partners, publisher partners, data partners, and fraud and measurement partners, collectively as the “Partners”) with technologies to enable these Partners to display advertisements to the users who use their mobile applications (“App(s)”) or visit their websites (the “User” or “Users”, or as “you” interchangeably).

The following describes how we may collect, use, store and disclose information relating to Users collected through Vpon AD Software Development Kit (AD SDK) when we deliver the Services (“Vpon Privacy Policy”). Vpon collects, uses, and discloses information to provide its Services to its Partners, and also collects, uses and discloses information for its own purposes (as elaborated below).

How Vpon’s Advertising Technology Works

A.How We Collect Information
Vpon provides a platform to connect mobile application and site publishers with advertisers. These services provide efficient serving of advertisement and data service to our demand partners and help our publisher partners to fill in their inventory slots with effective advertising. When you use Apps or websites that have integrated Vpon’s AD SDK, through AD SDK, we collect your information to deliver, tailor and report on ads being run across our platforms and services. The information we collect is mainly non-personal data, which means that we don’t know and can’t ascertain your identity as a natural person, but it helps us to process and use this information to better understand your interests and preferences in order to deliver most relevant ads to you.

B.Information We Collect
The information we/our Partners collect through our technologies is mainly non-personally identifiable information.

Personally Identifiable Information (“PII”) is the data that can directly or indirectly identify a specific individual, and may include, but is not limited to, your name, phone number, email address and home address, whereas non-personally identifiable information (“non-PII”) is the information that, by itself, does not directly or indirectly identify a specific individual. When providing its Services, Vpon does not collect PII and will take all precautions to avoid collecting or receiving PII from any partners. If Vpon is made aware that it received PII from its partners, it will use all efforts to remove that information from its records.

Based on your consent, Vpon may collect information while you are visiting the websites or Apps of our publisher partners integrated with Vpon’s AD SDK. The information collected includes but not limited to the following:

• Device ID: Device identifiers, including iOS identifier for Advertising (IDFA), iOS identifier for Vendor (IDFV), Android Advertising ID, and Vpon specific identifier.
• Brower Information: Information about your browser, including the type of browser, browser language, user agent, and Vpon specific cookie ID.
• Device Information: Information about your device, including the type and model, manufacturer, operating system (e.g., iOS or Android), carrier name, mobile browser (e.g., Chrome, Safari), and screen size.
• Internet Environment: Information about your internet environment, including your IP address, connection type (Wi-Fi, Cellular) and Wi-Fi access points.
• Geolocation: Device’s geo-location when location services are enabled in the Apps you use with your permission. Note that when location services are not enabled, we may still infer your relative location based on IP address.
• App/Website Usage: Information about your App or website usage, including the applications on your device, your current browsing content, your current time zone, and the time web pages or Apps were visited or used.
• Advertisement Information: Information about ads served, viewed, or clicked on, including the type of ad, where the ad was served, whether you clicked on it, and whether you visited the advertiser’s website or downloaded the advertiser’s application.

To improve the quality of its Services, on some occasions, Vpon receives users’ non-PPI from third parties, such as users’ device identity, device characteristic, device connection, device location, user engagement, etc. While Vpon will do its best to request the third parties to confirm that the collection of this information complies with laws, Vpon is not responsible for the practices of these third parties.

C.Purpose of the Information We Collect
The information collected is mainly used for the following purposes:

• To allow advertising demand partners to show their ads in media inventory offered by our publisher partners and serve ads to App/website users;
• To serve personalized Ads using information collected and/or information from our data partners to infer what ads you may be interested in, and what ads you are more likely to engage with (depending on your location, we may also create a profile about you in order to help our Partners to serve the best ads to you. Vpon prohibits our Partners from serving targeting advertisements based on information that we consider sensitive or is prohibited by law, including race, religion, politics or health);
• To customize ads shown to you based on your current or prior location;
• To serve contextual ads to you based on the content you are viewing;
• To prevent you from seeing the same ad or the same type of ad too many times;
• To analyze and report on campaign and ad performance, such as reporting to advertisers about when and how you have been exposed to ads or clicked on ads, and reporting to Publisher Partners the information about when and how ads were shown on their digital properties and whether they were clicked on;
• To detect and identify invalid clicks (or ad queries) and protect Vpon and demand partners from fraudulent behavior.
• To audit, research and analyze data in order to maintain, protect, and improve our Services and to ensure that our technologies function properly;
• To create data derivatives including but not limited to segments, reports, insights, modelling, research, and statistical analytics from the information, in order to provide Services to our data demand partners, to understand market trend and/or user behavior etc. (in order to deliver the Services, we may license and/or otherwise transfer data derivatives in an aggregated and/or anonymized format to our demand partners);
• To fulfill requests and obligations related to the contractual relationship with our Publisher Partners; and
• To fulfill our legal and compliance functions or obligations.

D.Parties We May Share the Information With
The parties Vpon may share information with include the following:

• Publisher Partners: We may share your information with them to help understand how users interact with their Apps and sites and advertisements on their Apps and sites.
• Demand Partners: We may share your information with demand partners, clients, brands and advertisers who use our platform services, to allow them to understand the performance of their campaigns; and/or to help them better target their campaigns, products or offerings.
• Data Partners: We may share your information with data partners who help us with better understanding your preference by providing data enrichment services, so that they may create audience segments to help advertising demand partners choose the best ad for you.
• Fraud and Measurement Partners: We may share your information with them in order to help to ensure the safety, security, privacy, and accuracy of Vpon’s Services and the broader advertising ecosystem.
• Service Providers: We may share your information with service providers who help us to process your information. These service providers will be subject to the equivalent obligations in this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that they will only use your information for the processing purpose for us and pursuant to our instructions.
• Affiliates: We may share your information with our affiliated corporate group entities (“Affiliates”) to provide or improve our Services, and their use of such information will comply with this Privacy Policy so as to protect your information.
• Parties involved in reorganization or reconstruction: Upon bankruptcy, dissolution or other liquidation or insolvency events or in the event of merger, sale or transfer of all or a portion of our assets or shares or other reorganization or reconstruction in our ongoing business, the information that we collect or receive may be shared with or transferred to, that respective entity to the extent strictly necessary for continued provision of Services, provided that it will undertake to be bound by the provisions of this Privacy Policy, with reasonably necessary changes taken into consideration.

E.Processing and Storage of the Information We Collect
To provide Services in a reliable and flexible manner, Vpon uses industry well-known cloud service providers to process and store the information collected, so the data may be transferred to and processed in multiple places, such as Taiwan, Hong Kong, Japan, and US.

F.Retention of the Information We Collect
Vpon retains information collected and received only for the length of time necessary for the fulfilment of the above applicable purposes (including any directly related purposes) for which the data is or is to be used, and for compliance with applicable laws, regulations, or legal obligations.

G.Privacy Control Procedures of Your Device
If you do not want Vpon or our Partners to deliver targeted ads to you based on interests or preferences inferred from information we have about you, you can opt out using procedures described below and Vpon will stop collecting your information:

1.Online web environment: (desktop, tablet, and smartphone browsers)
You can opt out by clicking HERE. Please note that these platforms allow you to opt out from interest-based advertising delivered by registered members on the current browser you are using. The opt-out process will place an opt-out cookie on your computer. Please note that if you delete, block, or otherwise restrict cookies, you may need to opt-out again, or if you use a different computer or Internet browser, you may need to opt-out on each browser.

2.Mobile applications: Device ID
Both Apple iOS or Google Android provides mechanisms that allow users to control the privacy options for the collection of iOS advertising identifier “Identification for Advertisers” (“IDFA”) and Android advertising identifier “Android Advertising ID (“AAID”)”. When we see these settings on your device, we treat these as a request to opt out from interest-based advertising and as a request to opt out from usage in data services.

• Android Users (version 3 and above)
  To use the “opt-out of interest-based advertising” option, follow the instructions provided by Google HERE.Open “Google Settings” →“Ads Setting” →“Opt out of Ads Personalization”

  If you turn off “Opt out of Ads Personalization”, mobile applications are able to track your device’s AAID. On the other hand, if you turn on “Opt out of Ads Personalization”, AAID will not be tracked.

  Please note that this is a device setting and will disable interest-based ads from all providers, and not just from Vpon.

• iOS Users
  To use the IDFA tracking option, follow the instructions provided by Apple HERE.
  • iOS (prior to version 14)
    Prior to iOS 14, iOS system offers two methods for users to opt out the tracking of IDFA.(1) Limit Ad Tracking (LAT): If users turn off LAT, mobile applications will be allowed to see and track user’s IDFA and/or provide personalized Ads for users. On the other hand,     if users turn on LAT,  mobile applications will not be able to track user’s IDFA.

    (2) Reset Advertising Identifier (IDFA): Users are able to reset IDFA by turning off LAT and then turn it on again to avoid being targeted in the setting page of the device.

    LAT and Reset Advertising Identifier page can be accessed via Setting → Privacy→Advertising.

  •  iOS (version 14 and above)
    Starting with Apple’s iOS 14 update, LAT was replaced with ATT.
    (1) App Tracking Transparency (ATT): Apple’s opt-in privacy framework requires all iOS Apps to ask users for permission to share their data. App users must agree with the data tracking via a popup (prompt) that App displays to authorize the permission of the collection of IDFA. Without the consent, valid IDFA will not be collected.

    (2) Reset Advertising Identifier (IDFA): In the Privacy setting page, turn off “Allow Apps to Request to Track”, and then turn it on to reset IDFA.

    ATT setting page can be found via Setting→Privacy →Tracking.

3.Mobile applications: Geolocation information
Users can choose to grant permission for geolocation data collection. Please refer to the procedures described below.

• Android Users
  For Android users, the first time a mobile application tries to access your location, a pop-up (prompt) will show to explain which application is asking for permission to use your location and provide options for you to control the access to your device’s location data. When the “Deny” option is selected, applications will not be able to track your location data. Users can also adjust the location permission of respective mobile applications or change the relevant settings via Setting→ Location→ App location permission.
  
  For more information about the use of your Android device’s location, please reach out to Google Support HERE.
• iOS Users
  For iOS, the first time a mobile application tries to access your location, a pop-up (prompt) will show to explain which application is asking for permission to use your location as well as the reason for requesting it and provide options for you to control the access to your device location data. When the “Don’t allow” option is selected, applications will not be able to track your location data. Users can also turn Location Services on or off or change the relevant settings of each mobile application via Setting → Privacy → Location Services.For more information about iOS Location Services, please reach out to Apple’s official website HERE.

H. Your Rights
You have the right to ascertain whether Vpon holds your information, to request to review the information held by Vpon, to request to obtain a copy of your information, to request to supplement and correct any information that is inaccurate, to request to delete the Information, and to request to stop the collection, processing, and use of your information.

If you would like to exercise the above rights or request for information regarding policies and practices, please send your request in writing to: privacy.support@vpon.com.

Vpon will endeavor to reply to your request in 15 working days and fulfill your request within 30 working days upon your further confirmation and if such request is legitimate.

For Users in EEA or UK

Please note that Vpon does not collect or intend to collect any information from members of the European Economic Area (“EEA”) and United Kingdom (“UK”). If Vpon is aware of any information incidentally collected that is associated with any IP address in EEA or UK, Vpon will delete the information from its database. If you are a user in EEA or UK and subject to the protection of GDPR, but are aware that Vpon collects your information, please contact Vpon immediately or opt out from the services following the opt-out procedure mentioned in Section G.

Third Parties’ Websites

Vpon’s Services may contain links to other websites. If you choose to visit a website of a Partner or a third party by clicking a banner ad or other type of advertisement or a link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement of their products or services, nor is it an endorsement of their privacy or information security policies or practices. Vpon is not responsible for the privacy practices or the content of these websites. These websites may place their own cookies or other files on your computer, to collect data or solicit personal information from you. This Privacy Policy addresses the use and disclosure of information that we collect from you through our Services. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the websites you visit.

Children’s Privacy and Sensitive Information

Vpon is very sensitive about the issue of the privacy rights of children. Vpon’s Services generally are neither developed for, nor directed at, children. We do not knowingly collect information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy.support@vpon.com. If we become aware that a child under 13 has provided us with information, we will delete such information from our files.

Vpon does not collect, nor does it permit the targeting of advertising based on sensitive information regarding medical and health-related matters.

Security Precautions

Vpon makes significant efforts to maintain the security of its network and the data we collect. We use various technologies, including, in certain instances, encryption, to ensure high security standards. Any data that is stored on Vpon’s servers is treated as confidential and is not available to the public. Please keep in mind, however, that the Internet is not a 100% secure medium. Therefore, although we use reasonable efforts to protect information, the possibility of an individual defeating our security measures does exist.

Compliance with Laws and Law Enforcement

Vpon may release information (including PII) when necessary to government and law enforcement officials, to enforce and comply with the law. We will disclose any information about you to government or to law enforcement officials when we, at our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or to protect Vpon’s rights, property, or other interests, including those of its customers or users, or to prevent illegal activities.

Acceptance of Privacy Policy

You acknowledge that you have read this Privacy Policy. Your use of our Services, our Partners’ services, and access or interaction with our Partners’ Apps and websites are subject to this Privacy Policy. BY USING, ACCESSING, INTERACTING WITH OUR SERVICES, AND OUR PARTNERS’ SERVICES, APPS, AND WEBSITES, YOU ACCEPT THE PRACTICES SET OUT IN THIS PRIVACY POLICY.

Changes to Privacy Policy

We may find it necessary or be legally obligated to update this Privacy Policy from time to time. When we do, we will update the effective date so that you are always aware of the information we collect, how we use it, and under what circumstances we disclose it. Your continued use, access, and interaction with our Services and our Partners’ services, Apps, and websites following posting of the updated Privacy Policy will constitute your acceptance of the changes, unless your consent to the changes is required by applicable law.

Effective Date

This Vpon Privacy Policy has become effective as of 4 December 2020.
The latest revision was made on 5 October 2023.
For more information, or to ask questions about our Privacy Policy, please contact us at:

【Vpon Holdings, Inc】
AMBRE 6F, 3-15-7, Sendagaya, Shibuya-ku, Tokyo, 151-0051, Japan

privacy.support@vpon.com