Shanghai MetaX Software Co., Ltd. (“MetaX”) is a data-driven
Connected TV (CTV) advertising and operation company. We know how important
privacy is to our users, and we strive to be clear about how we collect, use,
disclose, transfer, and store (collectively, “process”) your personal
information.
This Privacy Policy (“Privacy Policy”) explains
our personal information processing practices, and applies to all MetaX products,
software, services and websites (collectively, the “Services”) and our
corporate website at www.MetaXSoft.com (“Site”).
This Privacy Policy applies regardless of whether you use a computer, mobile
phone, tablet, TV, set-top box or other smart device (“Device”) to access our
Services or our Site.
It is important that you read the Privacy
Policy carefully because it provides information on how your personal
information is processed anytime you use our Services.
It is also important that you check back often
for updates to the Privacy Policy. If we update the Privacy Policy we will let
you know in advance of any material changes, by placing a notice on the
relevant Services or by e-mailing you, when appropriate. The most current
version of the Privacy Policy will always be available here https://www.metaxsoft.com/privacy-policy. You can
check the “Last Updated Date” posted at the top to see when the Privacy Policy
was last updated.
Controller of Personal Information
Shanghai MetaX Software Co., Ltd., with its
principal business address at F6, Guoyang Building, Guoquan Road No. 98, Yangpu
District, Shanghai, China, is the data controller of personal information
processed through MetaX’s Services and Site. Details can be found at https://www.metaxsoft.com.
Description of Processing Activities
and Legal Grounds for Collection
We collect your personal information for the
purposes listed and explained here below for the purposes listed and explained
here below.
1.
Contact Information We Collect To Provide Services
We collect and store any information you directly give to
us in relation to our Services. The information you may provide is listed as
follow:
If you want to subscribe our newsletters to get our
latest news, we will collect your e-mail address and name.
If you contact our Data Protection Officer to discuss
your personal information issues, we will collect information from you
regarding the service you require from MetaX. Such information collected may
include your name, e-mail address, home address, telephone number, or other
unique identifiers that would allow us to identify you.
This personal information is used to provide the Services
you request and in order to communicate with you in relation to MetaX Services
via different channels (e.g., by phone, e-mail, online chat).
This type of data processing is necessary for the
performance of your contract (or necessary to conclude the contract) with
MetaX.
To the extent permitted by any applicable mandatory laws
and regulations, this type of personal information is stored for as long as you
are a user of MetaX Services and then Two (2) years thereafter for evidentiary
reasons and in accordance with the applicable statute of limitations.
You can choose not to provide certain information, but
then you may not be able to take advantage of many of our Services. Any
information required by law or contract will be marked with an asterisk.
2.
Statistics
We generate statistical metrics based on some application events,
such as daily active users (DAU), daily new users (DNU), etc. Its purpose is to understand
the use of our application. We may collect certain information including the following:
Unique Device ID (“UUID”), or other unique identifiers of your Device;
Events for the application, such as open/exit application, and so on;
Information processing in this regard is based on MetaX’s
legitimate interest in knowing how our products are being used (article 6.1.f GDPR).
To the extent permitted by any applicable mandatory laws
and regulations, this type of personal information is stored for as long as you
are a user of MetaX Services and then Two (2) years thereafter for evidentiary
reasons and in accordance with the applicable statute of limitations.
3.
Information We Collect To Provide Services and
Advertising
Our technology enables our partners to show application
users more relevant advertising that is based on users’ interest in
applications. If you are a user that uses application or software containing
our Services, or downloads and uses an application which contains the MetaX SDK
or otherwise interacts with the Services, we may collect certain information
including the following:
Device make, model and operating system;
Device properties related to screen size &
orientation, resolution, audio volume and battery, device memory usage;
Name and properties of application through which a user
interacts with the Services;
Country, time zone and locale settings (country and
preferred language);
Network connection type and speed;
Live streaming data: channel ID, channel name, and
program name;
IP Address and MAC Address;
Internet browser user-agent used to access the Services;
Identifier for advertisers (IDFA); and
Clickstream
data, which is a record of advertising content (which might be web pages,
videos or images) you have viewed.
This Device information may be collected across
apps and websites over time. We may also combine information we collect with
other information we derive through analytical techniques, and we use that
combined information to offer
the Services. This type of information may include data related to a consumer’s
interaction with an application, such as information about the actions taken in
an application by end users, like purchases within MetaX’s applications, or end
user’s application installations.
Ads
can be served based on your general location. This can include location derived
from the Device’s IP address. This includes activity stored in your web & app
activity, which can be used for more useful ads.
Using the abovementioned information we
collect, we are able to deliver the Services (including advertising contents),
improve them, and research and develop new ones. Such information can make your experiences across
MetaX more relevant and helpful.
Any such processing will be based on if you
consent to it. You can choose not to provide certain information, but then you
may not be able to take advantage of many of our Services.
To the extent permitted by any applicable
mandatory laws and regulations, this type of personal information is stored for as long as
you are a user of MetaX Services and then Two (2) years thereafter for
evidentiary reasons and in accordance with the applicable statute of
limitations.
4.
Provide,
Troubleshoot, and Improve MetaX Services
In
order to improve our Services’ functionalities and to rectify any problems in
connection or the provision of Service. We may collect the following
information:
device and software
characteristics such as SoC model, TV brand, software version number, operating system version, and settings of the
Device you use to access the Services;
We
use your personal information to provide functionality, analyze performance,
fix errors, and improve usability and effectiveness of MetaX Services.
This
data processing is necessary for the performance of the contract and based, in
part, on MetaX’s legitimate interest to improve its Services and provide
optimal Services to clients.
To
the extent permitted by any applicable mandatory laws and regulations, this
type of personal information is stored for as long as you are a user of MetaX Services
and then Two (2) years thereafter for evidentiary reasons and in accordance
with the applicable statute of limitations.
In
certain cases, we will have a legal obligation to collect and process your
personal information. You will be informed of the specific purposes, when the
case arises.
Does MetaX Share Your Personal
Information?
We
may disclose your information internally within our business to the relevant
teams, such as, without limitation the customer services team, the legal team,
the finance team, the sales team and where you have chosen to receive marketing
messages, to the marketing teams. We may only disclose your information to a
third party under one of the following conditions:
Sharing With Affiliates
We may share the information we collect
through the Services to our affiliates or subsidiaries for the purposes
described in this privacy policy; however, if we do so, their use and
disclosure of your personal information will be subject to this Privacy Policy.
Sharing with Third Party Partners:
We may share information we collect or
derive with advertising clients and business partners, such as to deliver
relevant advertising, and to provide attribution. For example, we may share
your Device ID, IP address and MAC address with our business partners (e.g. Ads
exchanges and demand side platforms). Advertising clients using these Ads
exchanges or demand side platforms will buy our ad placements through
programmatic ad auctions. Those companies are responsible as independent
controllers of the data used to deliver their ads on MetaX’s network.
In addition, we employ other companies
and individuals to perform functions on our behalf. Examples include
cloud-based data storage, sending postal mail and e-mail, analyzing data,
providing marketing assistance, providing search results and links (including
paid listings and links), processing payments, transmitting content, and
providing customer service. These third-party service providers have access to
personal information only as needed to perform their functions, but may not use
it for other purposes. Further, they must process the personal information in
accordance with and as permitted by applicable data protection laws.
Advertising,
Measurement and Analytics Services (Non-Personally Identifiable Information
Only):
We may also provide our affiliates and
third party partners with information about the reach and effectiveness of
their advertising without providing information that personally identifies you,
or if we have aggregated the information so that it does not personally
identify you. For example, we may tell an advertiser how its ads performed, or
how many people viewed their ads or installed an app after seeing an ad.
Business Transfers:
As we continue to develop our business,
we might sell or buy other businesses or services. In such transactions, user personal
information generally is one of the transferred business assets but remains
subject to the promises made in any pre-existing Privacy Policy (unless, of
course, the user consents otherwise). Also, in the unlikely event that MetaX or
substantially all of its assets are acquired, user personal information will of
course be one of the transferred assets.
Protection of MetaX and
Others:
We release certain personal information
when we believe such release is appropriate to comply with the law; in response
to subpoenas, court orders, or other
legal processes; enforce or apply our Terms of Use and other agreements; or
protect the rights, property or safety of MetaX, our users or others. This includes exchanging information
with other companies and organizations for fraud protection and credit risk
reduction.
Other
than as set out above, you will receive notice when personal information about
you might be shared with third
parties and you will have an opportunity to choose not to share the information.
Transfers out of the European
Economic Area
WE
MAY TRANSFER AND STORE YOUR DATA OUTSIDE THE EUROPEAN UNION (“EU”) AND EUROPEAN
ECONOMIC AREA (“EEA”) IN ORDER TO PROVIDE YOU WITH OUR SERVICES (49.1(B) GDPR).
More
specifically, we may transfer your data to our headquarters at Shanghai MetaX
Software Co., Ltd., with its principal business address at F6, Guoyang
Building, Guoquan Road No. 98, Yangpu District, Shanghai, China for the
purposes outlined in this Privacy Policy. We will ensure that the information
is transferred in accordance with this Privacy Policy and as permitted by the
applicable laws on data protection. In particular we will ensure an adequate
level of protection and implement the necessary safeguard measure, such as the
conclusion of EU standard clauses (for a copy of these clauses please write to:
dpo@metaxsoft.com).
How Secure is Information about Me?
We
take protection of your data seriously, we use reasonable administrative,
logical, physical and managerial measures to safeguard your personal
information against loss, theft and unauthorized access, use and modification.
These measures are designed to provide a level of security appropriate to the risks
of processing your personal information.
We use the method of
pseudonymization when processing some of your personal information. After
pseudonymization, your personal information can no longer be attributed to you
without the use of additional information, and such additional information will
be kept separately and is subject to technical and organizational measures to
ensure that the personal information are not attributed to you;
We maintain physical,
electronic and procedural safeguards in connection with the collection, storage
and disclosure of personal information. Our security procedures mean that we
may occasionally request proof of identity before we disclose personal
information to you or respond to any of your requests relative thereto;
Our Services offer security
features to protect them against unauthorized access and loss of data. You can
control these features and configure them based on your needs;
We restrict access to
personal information to MetaX employees, contractors, and agents who need that
information in order to process it. Anyone with this access is subject to
strict contractual confidentiality obligations and may be disciplined or
terminated if they fail to meet these obligations; and
It is important for you to
protect against unauthorized access to your password and to your Devices, and
applications.
However,
please note that although we take reasonable steps to protect your information,
no website, Internet transmission, computer system or wireless connection is
completely secure. You should take steps to protect against unauthorized access
to your password and Device by, among other things, choosing a robust password
that nobody else knows or can easily guess, and keeping your log-in and
password private. We are not responsible for any lost, stolen, or compromised
passwords or for any activity on your account via unauthorized password
activity.
What about Third-Party Advertisers
and Links to Other Websites or Applications?
MetaX
Services may include third-party advertising and links to other websites or
platforms. These third parties may collect information about you when you
interact with their content, advertising, and services. Please note that these
third parties have separate and independent privacy or data policies, privacy
statements, notices and terms of use, which we recommend you read carefully,
and we are not responsible for the security or privacy of any
information collected by them.
Additional Disclosures for
Individuals in Europe
If
you are located in the European Economic Area or Switzerland, you have certain
rights and protections under the law regarding the processing of your personal
data.
Legal
Basis for Processing. When we process your personal data, we will do so, e.g., on
the following basis:
The data processing is
necessary for the performance of your contract (or necessary to conclude the
contract) with MetaX (6.1.b GDPR);
The data processing is based
on if you consent to it (article 6.1.a GDPR);
This data processing is based
on MetaX’s legitimate interest to improve its Services and provide optimal
Services to clients (article 6.1.f GDPR).
In certain cases, we will
have a legal obligation to collect and process your personal data. You will be
informed of the specific purposes, when the case arises (article 6.1.c GDPR).
Data
Subject Requests.
You have the right to access personal data we hold about you and to ask that
your personal data be corrected, erased, or transferred. You may also have the right to object to, or
request that we restrict, certain processing. If you would like to exercise any
of these rights, you may contact us as indicated below.
Opt-Out From MetaX Personalized Advertising
Depending on the Device, application, web browser and
service you use, you may be able to opt out from our personalized ads. Please
follow the below instructions:
To opt-out from your web browser in
any devices:
If you opt-out, you will still see
ads, including contextually tailored ads (i.e., ads tailored to the current
website or app you are viewing) and ads based on your current location; they
just may not be relevant to your interests.
The opt-out mechanism will only opt
you out of personalized advertising delivered by MetaX in this browser or in
applications on this Device. It will not opt you out on other devices or in
other browsers you use.
Most web browsers are set to accept
cookies by default. If you prefer, you
can usually choose to set your browser to remove or reject browser
cookies. Please note that if you choose
to remove or reject cookies, this could affect the availability and functionality
of our Services. Opt-out information is stored in a cookie If you delete your
cookies, this information will also be deleted, and you will need to renew your
opt-out choices.
To opt-out from an in an app
environment:
If you opt-out, you will still see
ads, including contextually tailored ads (i.e., ads tailored to the current
website or app you are viewing) and ads based on your current location, they
just may not be relevant to your interests.
If you want to disable MetaX
personalized ads, please refer to your operating system settings.
Some Device system software are
providing mechanisms that allow users to opt-out of the use of information
about their usage of apps to deliver targeted ads to their Device. For more
information, or to opt-out using these mechanisms, you may consult your Device
settings, contact the manufacturer or retailer of your Device, or the operator
of the application. Please note that a Device setting may disable personalized
ads from all providers, and not just for MetaX.
If your Device’s advertising
identifier is reset, you will need to renew your opt-out choice for that
device.
Are Children Allowed to Use MetaX Services?
You must be 18 years of age or older to use our Service. In certain
jurisdictions, the age of majority may be older than 18, in which case, you
must satisfy that age. While individuals under the age of 18 may utilize our Service,
they may do so only with the involvement, supervision, and approval of a parent
or legal guardian.
How Long Does MetaX Keep Your
Personal Information?
We
will not keep your personal information for longer than is necessary for the
purpose it was collected. This means
that data will be destroyed or erased from our systems when it is no longer
required.
Personal
information is held:
at least the duration for
which the information is used to provide you with Services;
as may be required under law,
a contract, or with regard to our statutory obligations; or
only for as long as is
necessary for the purpose for which it was collected, is processed, or longer
if required under any contract, by applicable law, or for statistical purposes,
subject to appropriate safeguards.
For
more detail see the description of our activities.
Changes to This Privacy Policy
We
will update this Privacy Policy from time to time in response to changing
legal, regulatory or operational requirements. We will provide notice of any
such changes (including when they will take effect) in accordance with the law.
Your
continued use of the MetaX Services after any such updates take effect will
constitute acknowledgement and acceptance of those changes. If you do not wish
to acknowledge or accept any updates to this Privacy Policy, you may stop your
use of MetaX Services.
At
the beginning of this Privacy Policy, you can see when this Privacy Policy was
updated and when it took effect.
Contacting Us
If you have any concern about privacy or questions related to data protection at MetaX, please contact our data protection officer, in doing so please include a thorough description of your issues and we will try to resolve them for you. The data protection officer mentioned above can be contacted at dpo@metaxsoft.com. If you are an individual in European Economic Area, you can also contact our representative at european-representative@metaxsoft.com.
Please
note that if you contact us to assist you, for your safety and ours we may need
to authenticate your identity before fulfilling your request.
You
may lodge a complaint with the relevant supervisory authority if you consider
that our processing of your personal information infringes applicable law.