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MoEngage, Inc. (“MoEngage,” “us” or “we”) provides SaaS (software as a service) (the “Service”) that enables the providers of mobile applications and websites (the “App Providers”) to understand how end users who download, access and/or interact with App Providers’ services (the “End Users”) interact with their services. This privacy policy (the “Privacy Policy”) describes how we collect, use, and disclose data collected through the MoEngage Platform (the “Platform”), as a part of our Service. European Union should be sure to read the important information provided under the section – “Additional Information for European Union Users” in this Privacy Policy. We might update our Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Platform or by sending you an email or other notification prior to the changes becoming effective. We will also indicate when the changes will become effective. Please review our Privacy Policy on a regular basis. Any information that we collect is subject to the privacy policy in effect at the time such information is collected. This Privacy Policy only applies to MoEngage and does not apply to the practices of companies that MoEngage does not own or control, or to people that MoEngage does not employ or manage. This Privacy Policy has some provisions that only apply to App Providers and End Users, respectively, and it also has provisions that apply to both App Providers and End Users. Please read the applicable Privacy Policy provisions carefully before proceeding.
We obtain information about End Users to provide App Providers with behavioral and analytics data related to how End Users interact with their products and services (the “Applications”). We do not directly get personal information from End Users; we collect information using tracking code technology that App Providers install in their Applications and share with us pursuant to their information collection practices, which are typically outlined in a privacy policy like this one and made available on the App Provider’s website. We encourage all End Users to read the privacy policies of the Applications they access or use. The App Providers provide us with the following types of information about End Users: When an App Provider embeds our tracking code into its Applications, we access or obtain Personally Identifiable Information (“PII”) such as an End User’s email address, name, and phone number, depending on the selections the applicable App Provider makes via the MoEngage Software Development Kits (the “SDKs”). We also access or obtain additional information about End Users’ use of App Providers’ Applications and End Users’ devices, such as the actions taken, content viewed, messages viewed, messages clicked, offers accepted, search terms entered, advertisements clicked, applications opened, applications sent to the background, transactions in which an End User engaged, application name, application version, application bundle identifier, operating system name, operating system version, unique device identifiers, IP addresses, and access date, time, and location information. Please ensure you read, understand, and accept the privacy policies, and any terms of use of the App Provider that uses the MoEngage Service. By using our Service, you expressly relieve MoEngage from any and all liability arising from your use of the App Providers service. We analyze and use this information to provide and improve the MoEngage Service. MoEngage collects information under the direction of our App Providers and has no direct relationship with the End Users whose personal data it processes. If you are a customer of one of our App Providers and would no longer like to be contacted by one of our App Providers that use the MoEngage Service, please contact the App Provider directly. If the App Provider fails to respond to your request within 30 days, you may contact us with your request at [email protected].
We will retain personal data we process on behalf of our App Providers for as long as needed to provide services to our App Providers. We will also retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. An End User who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to our App Providers. If requested by App Providers to remove or access data, we will respond within 30 days.
App Providers are able to send you, the End Users, push notifications, thought In-apps, or email communications through the MoEngage Service.
An End User who seeks to opt out must direct their query to their App provider. The App Providers may then request us to opt out of the said End User, which we shall do so within 30 days. Alternatively, the End User may contact us directly, by sending opt-out requests to [email protected].
We collect and use information from App Providers to provide our Service, improve our Service, administer your Account, and personalize the End User experience.
When you, as an App Provider, create an Account or when you request information about the MoEngage Service, we’ll collect certain information that can be used to identify you, such as your name and email address (“PII”). We may also collect information that cannot be used to identify you, such as Account preferences.
You can access and modify the PII associated with your Account by accessing the user settings in the MoEngage Service. MoEngage acknowledges that EU individuals have the right to access and delete the personal information that we maintain about them. If you want us to delete your PII and your Account, please contact us at [email protected] with your request. We will respond to your request to access within 30 days. We will retain your information for as long as your account is active or as needed to provide you with services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your information for as long as your account is active or as needed to provide you with services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
MoEngage uses “cookies,” which are small text files that are placed by web servers and used to remember your preferences and settings. We use cookies to:
We may receive reports based on the use of these technologies on an individual as well as aggregated basis. You can change your browser settings to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If your browser does not accept cookies, however, you may not be able to easily access all aspects of our Service. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use locally stored objects (LSOs) such as HTML5 to collect and store information.
Our partners may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason, you can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising:
We gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you, to improve marketing, analytics, or site functionality.
Sometimes we may transfer your PII to our Indian subsidiary to provide you with better service or for troubleshooting purposes. Our Indian subsidiary is bound by the principles of Standard Contractual Clauses and the obligations under this Privacy Policy. If you have any questions or concerns related to the transfer of PII to our Indian subsidiary, you contact us at [email protected].
We may engage third-party Service Providers to work with us to administer and provide the MoEngage Service such as sending you emails, storing data, etc. These third-party Service Providers have access to PII only for the purpose of performing the MoEngage Service on our behalf and are expressly obligated not to disclose or use your PII for any other purpose. The End Users may reach us at [email protected] if they require further information about the third-party Service Provider, the services that they are providing, or their privacy policy.
We may share aggregated information and non-identifying information with third parties for industry analysis, demographic profiling, and other similar purposes. We will not share the End User PII collected for one App Provider with third parties.
It is our policy to protect App Providers and End Users from having their privacy violated through abuse of the legal systems, whether by individuals, entities or government and to contest claims that we believe to be invalid under applicable law. However, it is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about App Providers or End Users to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary:
We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
We take reasonable measures to protect the information that we collect from or receive from App Providers or End Users (including PII) from unauthorized access, use, or disclosure. When you enter sensitive information (such as login credentials) on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL). Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) via email or conspicuous posting on our Platform in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Our Service may contain links to other websites and services. Any information that an App Provider or End User provides on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. Our Privacy Policy does not apply to such websites or services, and we are not responsible for the content, privacy, or security practices and policies of those websites or services. We recommend that App Providers and End Users carefully review the privacy policies of other websites and services that they access.
Our Platform includes Social Media Features, such as the Facebook button, and widgets, such as the “Share” button, or interactive mini-programs that run on our site. These features may collect your IP address, and which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Platform. Your interactions with these Features are governed by the privacy policy of the company providing them.
Our Service is not directed to children under the age of 13. MoEngage users must not be under the age of 13. We do not target any portion of our service to children under the age of 13, and we will delete any accounts or data of users that we believe to be under the age of 13 to be in compliance with the Children’s Online Privacy Protection Act. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at [email protected].
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact MoEngage via email at [email protected].
All references to “Personal Information”, “Personally Identifiable Information” or “Personal data” are equivalent to the definition of “personal data” under GDPR.
For App Providers and visitors of the MoEngage website, MoEngage Inc. is the controller of your personal information for purposes of European data protection legislation.
MoEngage processes the personal data of end users on behalf of the App Providers and acts as a Data Processor on behalf of App Providers, who act as Data Controller
Our Data Protection Officer can be reached at [email protected].
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to the personal information that we hold –
Opt-out: Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails. You can submit these requests by email to [email protected]. We may require some information to authenticate your request. We may reject your request as applicable under law in which case we will inform you of the legal basis for rejecting your request. . If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at [email protected]For End Users: MoEngage is a service provider that processes data on behalf of App Providers, any requests relating to European Users’ exercise of their rights of access, rectification, erasure, or restriction under the European General Data Protection Regulation (“GDPR”) must be provided to MoEngage by an App Provider. App Providers can notify MoEngage of these requests directly. You can refer to this article for more information. Moreover, MoEngage supports functionality to allow App Providers to respect granular controls regarding User data privacy rights. App Providers can flag in the MoEngage SDK that a particular User has requested that their data not be processed by MoEngage, in which case MoEngage will no longer process engagement data on behalf of the App Provider for that User. For App Providers: App Providers who are users of MoEngage Service and who are residents of the European Union may request get a confirmation in MoEngage is processing your data, access this, or request to rectify, or delete or restrict the processing of this information. For any such request, you may send an email to us at [email protected] after 25th May 2018. Use for a new purpose: We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.
“Personal Information” for the purpose of this section has the meaning given to this term in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information specifically excluded from within the scope of the CCPA.
Collection of Personal Information: Depending on your use/interaction with us, we may collect the following categories of Personal Information from you:
| Statutory Category of Personal Information Collected | Nature of the Personal Information Collected | Purpose for Collection | Source |
|---|---|---|---|
| Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Data about what an individual has purchased from MoEngage (including tickets to MoEngage-sponsored events)
· Data about what an individual has downloaded from the MoEngage Website |
Register for, attend and/or otherwise take part in our events webinars or contests |
|
| Identifiers. Real name, alias, postal address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers. |
|
Use our Services as an authorized user
Receive communications from us Responding to your requests for support or information; |
|
| Inferences. The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. |
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Enabling us to understand who is interested in learning about our products, services, content, and company-related initiatives; |
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| Online Identifiers. An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol (IP) address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology |
|
Analyzing overall trends on our Website to help us to provide and improve our Website and to ensure its security and continued proper functioning; |
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| Professional or Employment Information. information relating to a person’s current, past or prospective employment or professional experience (e.g., job history, performance evaluations) |
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Sending messages to the users of our Services with respect to technical alerts, updates, security notifications, and educational and administrative communications |
|
| Audio, electronic, visual, thermal, olfactory, or similar information. | Audio and video recordings. |
|
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| Protected Classification Characteristics. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | We do not intentionally collect this data, but certain characteristics may be revealed in identity data or other information we collect. |
We do not sell your Personal Information in any form. We do, however, use the Personal Information shared by you for the purpose of internet-based targeted advertising of our own services. We do not offer any financial incentive programs to our users.
We may share and disclose Personal Data to the following types of third parties and for the following purposes:
Exercising your Rights: You can request to exercise your information, access and deletion rights by writing to [email protected]. We will need to confirm your identity and California residency to process your information, access or deletion requests, and we reserve the right to confirm your California residency. Government identification may be required. If you wish to designate an authorized agent to make a request on your behalf, we will need to verify both your and your agent’s identities and your agent must provide valid power of attorney or other proof of authority acceptable to us in our reasonable discretion. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Response Timing: We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to forty-five (45) additional days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:
Please contact us at [email protected] if you have any questions about our Privacy Policy. Or you may mail us your questions or concerns at Attn: Privacy and Security Office
315 Montgomery Street, 10th floor,
San Francisco, 94104,
USA
Grievance Officer In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are published herewith.
Grievance Officer
1st Floor, #32, Salapuria Tower II,
Chikku Lakshmaiah Layout,
Luskar Hosur Road,
Koramangala,
Bangalore – 560034,
India
Email: [email protected]