PRIVACY POLICY

Overview 

Crisp Mobile is committed to clearly informing users about the collection and use of their information when using our web site and our services.  As a result, we have put together this Privacy Policy to explain how we collect, use and disclose certain information.

This Privacy Policy applies to: (1) our website located at www.crispmobile.com (the “Web site”) and (2) our mobile advertising and content services provided through various mobile web sites and applications (the “Mobile Services”).

  1. DISCLOSURES REGARDING THE WEB SITE

Collection of Personal Information on the Web site

When using the Web site, you may choose to provide certain personally identifiable information about yourself (“Personal Information”).  Personal Information can include your name, email address, physical address and other information that specifically identifies you.  We will never collect Personal Information directly from you unless you have voluntarily provided it to us.

Collection of Non-Personal Information on the Web site

In addition, we may also collect non-personally identifiable information on the Web site which does not specifically identify you (“Non-Personal Information”), such as IP host address, pages viewed and similar data.  Non-Personal Information may be automatically collected by us from you without any separate notice other than this Privacy Policy.

Cookies

Crisp Mobile and certain third parties (such as analytics providers, like Google) may use cookies, web beacons, clear gifs and similar technology to customize your visit to the Web site, enable certain functions on the Web site and collect Non-Personal Information.  “Cookies” are pieces of information that may be placed on your device by a site or application for the purpose of facilitating and enhancing your communication and interaction with that site or application and collecting certain data.

You may stop or restrict the placement of cookies on your device or flush them from your browser by adjusting your browser preferences, but this may interfere with some functionality of the site or application. Please see the help section or instruction manuals for your browser and device to do so.  We do not use cookies to automatically retrieve Personal Information from you without your knowledge.

Use of Personal Information collected on the Web site

Except as described below, we do not share your Personal Information with any third party.

  • We may use your Personal Information from time to time to send you newsletters and other information about Crisp Mobile.
  • We may use your Personal Information to respond to your questions or to provide you with a service that you have specifically requested.
  • We may provide your Personal Information to our contractors, however they are only permitted to use such information in connection with services they are performing on our behalf.
  • We may transfer your Personal Information in connection with the sale or merger, in whole or in part, of Crisp Mobile, its assets or the division responsible for the applicable services.
  • We reserve the right to access and/or disclose any information we gather as required by courts or administrative agencies and to the extent required to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Web site’s policies, or the rights of third parties or to investigate any suspected conduct which we deem improper.

Use of Non-Personal Information collected on the Web site

We may use and share Non-Personal Information to improve and enhance your experience on the Web site and for any other business activities.  For example, we may share Non-Personal Information with unaffiliated third parties, such as business partners.

  1. DISCLOSURES REGARDING THE MOBILE SERVICES

Through the performance of the Mobile Services, Crisp Mobile may deliver advertising or content to the mobile web sites and mobile applications of various mobile companies, content providers, advertisers and other third parties (the “Publisher/Advertiser”).  We are therefore acting as a service provider to the Publisher/Advertisers.

Collection and Use of Personal Information through the Mobile Services

Personal Information is only collected through the Mobile Services when you affirmatively elect to provide such information to a Publisher/Advertiser.  We only collect such information for the benefit of the Publisher/Advertiser and will pass it on to the Publisher/Advertiser.  You should review the Publisher/Advertiser’s posted privacy policy to understand how they will use the information.  We will not permanently store or use such information for our own benefit.

However, we may access and/or disclose such information as required by courts or administrative agencies and to the extent required to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Publisher/Advertiser’s policies, or the rights of third parties or to investigate any suspected conduct which we deem improper.

Collection and Use of Location-Based Information through the Mobile Services

If you affirmatively opt-in to permit a Publisher/Advertiser to know your location based upon your mobile device, we may collect this information and pass it to the Publisher/Advertiser.  You should review the Publisher/Advertiser’s posted privacy policy to understand how they will use the information.   We will not permanently store or use such information for our own benefit.  We may disclose such information in the same manner as described above for Personal Information collected through the Mobile Services.

Collection and Use of Non-Personal Information through the Mobile Services

When you interact with our Mobile Services, we may collect Non-Personal Information such as the time spent viewing an ad, the number of ads clicked and other information about your interaction with the ads or content.

We may also place cookies on your device, to the extent possible, to collect Non-Personal Information.  You may remove cookies from your device by following the process described above in the section entitled “Cookies.” Some third party providers and mobile Web sites place cookies on your device for the purpose of relevant advertising.  If you would prefer to opt out of these programs, to the extent the browser on your mobile device allows, please click here.

We use such Non-Personal Information to provide reports to our Publisher/Advertisers, to develop aggregate and anonymous statistics for distribution and to disclose and to share such information for any other business reason.  We do not use such Non-Personal Information for building user profiles to deliver targeted ads, but may do so in the future.  If we do, we will update this Privacy Policy.

III.        GENERAL DISCLOSURES

Security Practices

We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect.  However, due to the inherent open nature of the Internet and our lack of control over wireless carriers, we cannot guarantee that all information will be completely free from unauthorized access by third parties.  Your use of the Web site and Mobile Services demonstrates your assumption of this risk.

No Children under age 13

We have no intention of collecting Personal Information from children under the age of 13.  When we become aware that Personal Information from a child under 13 has been collected  without such child’s parent or guardian’s consent, we will use all reasonable efforts to delete  such information from our database.

Changes to policy; Opt-Out Process

We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time.  However, if at any time in the future we plan to use Personal Information in a way that differs from this policy, we will post such changes here and provide you the opportunity to opt-out of such differing uses.  Your continued use of the Web site and Mobile Services following the posting of any changes to this policy means you accept such changes.

We give you the option to remove your Personal Information from our list of active users completely. All unsubscribe or opt-out requests should be sent to us at www.crispmobile.com/optinout and we will process your request within a reasonable time after receipt.  However, we are not responsible for removing your Personal Information from the lists of any third party (such as a Publisher/Advertiser) who has previously been provided with your information in accordance with this policy.

Contact

For questions or concerns relating to privacy, we can be contacted at:

Crisp

545 8th Avenue, 20th floor

New York, NY 10018

www.crispmobile.com/optinout

Effective Date

This Privacy Policy was last updated on January 1 , 2017.