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  • Privacy Policy

    Here you can find information about the technologies and services we provide to our partners,
    as well as the policies regarding data collection and privacy.

    Privacy Policy

    Here you can find information about the technologies and services we provide to our partners, as well as the policies regarding data collection and privacy.

    CONSUMER CONTROL AND OPT-OUT OPTIONS

    In most cases, consumers have control over whether or not they would like to receive relevant ads and marketing email from our Clients.


    Opting Out of Online Interest-Based Advertising

    You can opt out of many of the platforms and service providers we work with that support online interest-based advertising by visiting the Digital Advertising Alliance’s consumer education and opt-out page at http://www.aboutads.info

    (Or the European Interactive Digital Advertising Alliance’s opt-out page at http://www.youronlinechoices.eu if you are in the European Union).

    This type of opt out is cookie-based, which means that if you replace or upgrade your browser, or delete your cookies, you will need to opt out again.

    Opting out in this way will not prevent you from receiving ads; rather, the ads you see will be less customized to you.


    Opting Out of Cross-App Advertising on Mobile Devices


    Mobile Ad Identifier
    Momento can collect ADID, the advertising identifier of mobile app users. Momento uses ADID to provide ads based on your information and relevant to your interests. 


    You can opt out of having your mobile advertising identifiers used for certain types of interest-based mobile advertising (also called “cross-app advertising”), including those performed by Momento, by accessing the settings on your Apple or Android mobile device, as follows:

    You can opt-out of interest-based ads by following instructions below.



    For Android users:
    Settings > Google (Google services) > ads > Delete advertising ID > Press the button ‘Delete advertising ID’ for once again

    For iOS users:
    Settings > Privacy & Security* > Apple Advertising > Turn off personalized ads.
    *In earlier versions of iOS and iPadOS, this setting is called "Privacy."

    Additional Choices

    Advertisers may also provide ways for you to opt out from, or limit their collection of, certain information from and about you.

    Please refer to the privacy policies for retailers, apps, and mobile websites to learn more about their privacy practices.

    You may opt out from receiving promotional emails from us, such as emails to inform you about events and new services, by following the “unsubscribe” instructions in any promotional email you receive, or by contacting us at contact@Momento.team.

    Please note, however, that we may still send you non-promotional emails relating to your relationship with us.

    Momento Privacy Policy 

    Momento, Inc. (“Momento,” “we,” “our,” or “us”) provides this privacy policy to explain how we collect, use, and share information.


    This privacy policy (“Policy”) covers Momento’s handling of two types of information:

    1. Information we receive about end users (“End Users”) of third-party mobile applications (“apps”) that use our Software Development Kit (“SDK”), the Momento Ad Exchange (“Momento ADX”) (collectively, the “Momento Ad Services”)

    2. Information we receive through our website at https://Momento.team or any other website on which this Policy is posted, as well as information we get through other corporate services and web portals, we make available to clients and business partners (“Momento Websites”).


    We encourage consumers to learn about how information (including information we collect) can be used to market to them, and how to exercise their choices to permit or limit such marketing.

    We describe ways consumers can exercise that choice or opt out of marketing in Section 4 below, entitled “Consumer Control and Opt-Out Options.”



    INTRODUCTION

    Momento provides mobile advertising technology services that facilitate transactions among advertisers, app developers, publishers of mobile apps, and ad exchanges (collectively, “Clients”), and service providers and other data partners (collectively “Partners”).


    We do this by making available the Momento Ad Services and other tools to Clients.

    Clients use the Momento Ad Services and other tools to deliver advertising to End Users, and we in turn provide our services to help Clients (and their own customers) to deliver ads that are of interest to End Users.


    We explain our tracking technologies on Section 3

    1. PRIVACY PRACTICES FOR THE MOMENTO AD SERVICES

    2. INFORMATION COLLECTED THROUGH THE MOMENTO AD SERVICES


    Through the Momento Ad Services, we may (but do not necessarily, or always) collect a variety of information about End Users (whether through our SDK or through other partnerships and tools such as Client-facing APIs).


    Below is the information we collection for Momento Ad Services


    1. Browser and device information

    - Device Type: phones, smart tv, tablet, pc,

    - Device Manufacturer: Device make (e.g., “Apple”).

    - Device Model: Device model (e.g., “iPhone”).

    - Device OS: Device operating system (e.g., “iOS”) along with the version (e.g., “10”)

    - Device Language: Device’s Language (e.g., “ko”)

    - Device carrier code: Mobile Country Codes(e.g., “45123”).

    - Network connection type (e.g., “WIFI”, “Cellular”).

    - Device IFV: identifier of the device dedicated to an app publisher.

    - Device country: Device’s located country (e.g., “KOR”)

    - For DSP’s user-profiling and advertisement purpose


    2. IP addresses

    - including both IPv4 and IPv6 (shared with DSPs (Demand Side Partners)

    - For advertisement


    3. Geo-location data (town level)

    - For geo-targeting advertisement


    4. UserIDs

    - For DSP’s user-profiling


    5. Mobile device identifiers (IFDA, AAID)

    - For DSP’s mobile traffic tracking and ad-personalization


    6. Data

    - Metrics regarding ad performance, for instance Whether the user has seen the ad or not, Whether the user has clicked the ad or not, etc

    - For DSP’s ad performance and statistics measurement



    We may combine and merge the various types of information collected from the Momento Ad Services

    and may also enhance it (or permit our Clients to enhance it) with information collected from third parties.


    We refer to all the above information as the “Service Information.”



    How We Use Information Collected Through Momento Ad Services

    We use the Service Information for various advertising and marketing-related services including


    1. Delivering ads: Publishers and app developers offer ad inventory, which advertisers and buyers (DSPs) bid on and fill with relevant ads.

    2. Providing and improving Momento Ad Services: Offer customer, technical, and operational support; detect and protect against errors, fraud, or criminal activity; resolve disputes and enforce terms and conditions.

    3. Information and analytics: Provide Clients with information and analytics about the use of app features or help create/enhance user profiles for marketing or analytics purposes.

    4. Developing data models: Predict End Users' future behavior and interests on a per-device basis or across devices.

    5. Analyzing ad performance: Attribute app installations or mobile web visits to ad campaigns.

    6. Data validation and fraud prevention: Match End-User information across multiple devices to validate data, filter out invalid impressions, clicks, installs, or ad queries, and prevent fraudulent activity.

    7. Other essential usage: Comply with legal processes, government authority requirements, protect our business, rights, privacy, and safety, conduct audits, and enforce terms and conditions.


    We may combine Service Information to perform the above functions or provide advertising, marketing, or analytics services. This may involve aggregating data and creating data models to predict common interests among End Users.



    How We Share Information Collected Through Momento Ad Services

    We generally share Service Information with Clients and Partners for providing Momento Ad Services.


    This includes sharing with

    1. Clients and their marketing/service providers for targeted content and advertising to End Users on mobile apps.

    2. Other third parties for targeted advertising, such as demand-side platforms, analytics companies, data  management platforms, proximity solution providers, and other ad technology providers.

    These companies may  provide targeted content and advertising on third-party mobile apps or other media (e.g., email, direct mail, display media).

    3. Clients and their marketing/service providers for measuring marketing effectiveness or analyzing End Users' likely interests or demographics.

    We may continue to use and share your information even if you no longer access our SDK.


    The processes often involve cookies or similar technologies, associated with other information

    about End Users, such as interests, demographics, or transactions.

    For controlling or learning about interest-based advertising, see Section4, "Consumer Control and Opt-Out Options."

    We may also share Service Information with third parties: Upon an End User or Client request or authorization In good faith to comply with applicable laws, regulations, requests, orders, or subpoenas, including national security and law enforcement, enforce terms and conditions, protect interests, rights, property, or safety, or investigate suspected/actual unlawful activity.

    When information is aggregated or de-identified; and During business transactions (e.g., purchase, sale, merger, consolidation, investment, change in control, asset transfer, reorganization, liquidation, bankruptcy),

    or steps taken in anticipation of such events (e.g., due diligence).



    Tracking Technologies

    Momento, our Clients, and third-party partners collect and use information about End-Users through cookies and other tracking technologies, as described below. End-Users may opt-out by following the process in Section 4. EU End-Users' consent is required for tracking technologies.



    Mobile Device Identifiers and SDKs

    We, our Clients, or Partners may use mobile SDKs (including our SDKs) to collect information, such as mobile identifiers (e.g., iOS IDFAs, Android Advertising IDs), and data on mobile device interactions with our Momento Ad Services. SDKs are computer codes that enable ads, data collection, and related services.

    Clients or Partners may use these technologies to coordinate identifiers across platforms, browsers, or devices for efficient advertising analysis or targeting.

    This technology may also be used to analyze advertising through apps based on information associated with your mobile device.

    For opting out of tailored ads on mobile devices, see Section 4, "Consumer Control and Opt-Out Options."



    Cookies

    Cookies are small data files with unique browser identifiers. Stored on your device, they identify your browser.

    Our servers may deploy a cookie on your browser when you visit our website at https://Momento.team, subject to EU End Users' prior consent.



    APIs

    An application programming interface (API) is used to call or request information, like an SDK.



    Pixel Tags

    Pixel tags, or web beacons, are small blocks of code on a webpage that can read and place cookies.

    They enable us to collect information, such as IP addresses, access time, and browser type.



    ADHERENCE TO THE TCF IAB FOR EU RESIDENTS ONLY

    As part of our commitment to respecting EU end-user privacy and data protection rights,

    we adhere to the IAB Europe Transparency & Consent Framework (IAB TCF).


    Momento, Inc. participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Our identification number within the framework is 1211.


    You can also find our VendorID here.


    The IAB TCF utilizes a tool known as the TC String to gather explicit user consent or refusal for the usage of tracking technologies for advertising. This information is shared with Momento, as well as our clients and partners, to ensure they can process end-user data in line with GDPR regulations.


    According to a ruling by the Belgium data protection authority on February 2nd, 2022, the IAB Europe operates in joint controllership with Consent Management Platforms (CMPs), publishers, and vendors in collecting and distributing TC Strings. This process is based on a legitimate interest legal basis, with an opt-out system in place.


    Furthermore, the IAB Europe is considered a joint controller alongside CMPs, publishers, and vendors in the subsequent processing of personal data for advertising purposes, as per the same ruling.


    Given that this joint controllership status was established by a ruling, we will periodically update this section to reflect any changes the IAB Europe implements in response to the data protection authority’s decision, which is currently under appeal.

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    HOW DO WE USE THESE TECHNOLOGIES FOR ADVERTISING PURPOSES?

    We use these tracking technologies to collect information automatically from EndUsers’ devices, subject to prior consent from EU End-Users, collected by publishers who work with us.

    They help us identify unique browsers or devices used by an End-User and to perform functions like limiting the same ad from continuously reappearing, ensuring that ads are properly displayed on our publishers’ apps and websites, and serving relevant ads to the End-User.

    Subject to prior and express consent from EU End-Users, our Clients will use information that we share with them to establish connections among related devices (such as smartphones, tablets, and computers) for personalized advertising by Advertisers and agencies, and for analytics, and reporting purposes.

    They may match End User’s devices if the End User logs into the same online service on multiple devices or web browsers, or if the End User’s devices share similar attributes that support an inference that they are used by the same person or household.

    This means that information about an End User’s use of websites or applications on his or her current browser or device may be combined and used with information from the End User’s other browsers or devices.

    For example, this allows Advertisers and Agencies to deliver ads on an End User’s tablet-based on activities the End User engaged in on his or her smartphone. To opt-out of cross-device targeting practices, please follow the instructions in the section below.



    HOW WE SHARE THE INFORMATION COLLECTED ABOUT END USERS

    Below, we detail when information is shared:

    - To Buyers and Advertisers

    We share information we collect on End Users in connection with our Ad Services to allow them to           make decisions regarding buying advertising inventory on our publishers’ digital properties and other websites and applications, and for billing purposes, dispute resolution or fraud prevention. Moreover, this information, such as a device’s physical location, is also needed to analyze the effectiveness and performance of their advertising campaigns via our services.

    This also enables buyers and advertisers to provide End-Users with more personalized and relevant content.


    - To Our Clients’ Attribution and Analytics Partners

    We may share end-user information, such as cookie ID, mobile device ID, or other unique identifiers with our clients’ attribution and analytics partners to validate and measure the success and effectiveness of ads delivered via our Ad Services


    - To Clients (Agencies and Advertisers, or Demand Side Partners acting on their behalf)

    They may provide targeted content and advertising to End Users on mobile websites and/or apps. They also may use the data along with analytics companies, data management platforms that help DSPs maintain and use data, proximity solution providers, and other advertising technology providers, such as fraud prevention and performance measurement providers. These companies may, for example, provide targeted content and advertising to End-Users and others on third-party mobile websites and/or apps or other advertising media (such as email, direct mail, and display media).


    - To Execute Business Transfers

    In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), the information may also be shared with a third party, as strictly necessary for the purpose of executing business transfers.

    - To Comply with Legal Requirements.


    If deemed necessary and appropriate, information may be shared

    - in line with applicable law, including laws outside the End-User’s country of residence

    - to comply with legal processes, such as subpoenas, warrants, and others

    - as required by government authorities, including, and excluding government authorities of End-Users’        country of residence

    - to protect our business, rights, privacy, and safety, and those of our subsidiaries and Clients

    - to ensure our terms and conditions are enforced, (v) to pursue legal action and contain damages we          may sustain in relation to such activities



    PRIVACY INTENDED FOR OUR CLIENTS AND PROSPECTS

    Information may also be collected while using Momento Ad Services such as our website.



    WHAT CLIENT INFORMATION DO WE COLLECT?

    Information Directly Provided by You

    Visitors and Service users may be asked to voluntarily provide personal information.

    This might occur when visitors contact us via our website. Often, the information we collect include contact details (name, email, phone number), personal information (company, job title, office location), messages detailing the nature of communication, and any attachments visitors may include in relation to this.


    Information That’s Automatically Collected

    We use cookies or pixels to collect information that may be considered as personal data in some countries including those under the EU.

    This information allows us to keep track of visitor interactions, optimize our services, customize user experience.

    More information is provided on Section 2. PRIVACY PRACTICES FOR THE MOMENTO AD SERVICES.



    HOW WE USE THE INFORMATION COLLECTED FROM OUR CLIENTS AND PROSPECTS

    The information we collect on Momento Ad Services are be used for:

    - Account management.Create access to an Momento publisher account and provide specific data related to the use of our Ad Services

    - Service messages.Sometimes, we may need to use this information to send out messages for administrative purposes such as to communicate changes in our terms of service, product policies, and other related updates.

    - Customer service and support.The information you provide may also be used to contact you in response to a request for customer service or support or to provide more information as needed.

    - Analytics and Advertising. We use QUV analytics in our website to collect data for the purpose of research, analysis, and reporting.

    - Improving our products and services.Information collected will also be used to optimize user experience, improve the content we provide, deliver more effective marketing campaigns, and manage our client relations.

    - Legal purposes and risk management.When necessary and under applicable laws, including those outside the End-Users’ country of residence, we may use this information to comply with legal requirements, mitigate risks and damages to our business and that of our clients, and fulfill other similar requirements.


    END USERS / CLIENTS / PROSPECTS RIGHTS

    End-Users and Clients have the right to request access to, change, update, or delete personal information as required.

    End-Users can withdraw consent allowing us to collect and process personal information at any time.

    Doing so will not affect the lawfulness of any data processing we may have done before the consent is withdrawn or impact any processing done within the bounds of applicable laws that previously depended on that consent.


    European Economic Area (EEA) residents also have rights mentioned below.

    - Object to the processing, limit the processing or request portability of their personal information according to GDPR regulation.

    - Complain to a data protection authority about data collection and use of personal information.



    To exercise those rights, email us at contact@momento.team



    PRIVACY PRACTICES FOR THE MOMENTO WEBSITES

    Information We Collect Through the Momento Websites

    The Momento Websites provide information regarding Momento and our products and services. Through the Momento Websites, we collect information you voluntarily disclose to us, and we may also obtain automatically collected information.


    - Information You Disclose to Us

    We collect information you voluntarily disclose to us, such as your name, mailing address, email address, telephone number, and other billing information. You may also provide us with certain information about your business or other individuals.


    - Automatically Collected Information

    When you visit the Momento Websites, we may use cookies and pixel tags that we associate with unique identifiers to keep track of visitor interactions and personalize your experience on the Momento Websites. For more information, please see Section 3 above, entitled “Cookies, Pixel Tags, and SDKs.”


    We may also use third party-services, such as Google Analytics, that gather information such as your IP address, browser type, the web page from which you came to the Momento Websites, and the times of your visit.


    In addition, as you browse the Momento Websites, advertising cookies may be placed on your computer so that we can “remember” your interests


    Our display advertising partners may then help us retarget ads to you on other sites based on your interactions with the Momento Websites.


    To opt out of such interest-based mobile advertising, please see Section 4 above, entitled “Consumer Control and Opt-Out Options.” Opting out in this way will not prevent you from receiving ads; rather, the ads you see will be less customized to you.



    How We Use Information We Collect Through the Momento Websites

    In addition to the uses described elsewhere in this Policy, we use the information we collect through the Momento Websites (alone or in combination) to provide, market, improve, and operate the Momento Websites, Momento Ad Services, and any other products or services we have or may develop.


    This includes use of the information to:

    - Fulfill your requests

    - Send information about our products and services, including marketing communications.

    - Respond to your questions, concerns, or customer service inquiries.

    - Create aggregated or de-identified information.

    - Comply with applicable laws, prevent fraud, mitigate risk, and perform similar purposes.

    - Understand usage trends and preferences.

    - Analyze, improve, and provide products and services.

    - Customize the content and advertising you see on the Momento Websites, across the Internet, and elsewhere and/or perform other purposes at your request.



    DATA ACCESS AND RETENTION

    We retain the information collected from the Momento Websites and Momento Ad Services for as long as necessary to achieve our objectives as detailed in this Policy, and to comply with our legal obligations, resolve disputes, and enforce our agreements.

    If you are a resident of the European Union, you may obtain a copy of the information we have about you by contacting us at contact@Momento.team.

    Please be advised that, due to the way we collect information, we will only be able to provide you with such information if we can determine that the information is identifiable to you.

    Under extenuating circumstances, we reserve the right to charge a fee for providing you with such information, and that fee will be based on costs and fees we incur to fulfill your request.



    DATA SECURITY

    We have administrative, technical, and physical safeguards in place in our physical facilities and in our computer systems, databases, and communications networks that are designed to protect the information from loss, misuse, or alteration.

    No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your information.

    To assist with data security, you understand that YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF ANY ACCOUNT CREDENTIALS THAT CAN BE USED TO ACCESS ANY ACCOUNT WITH MOMENTO. ANY ACTIONS TAKEN USING YOUR ACCOUNT CREDENTIALS ARE YOUR SOLE RESPONSIBILITY.



    THIRD-PARTY WEBSITES AND APPS

    This Policy only applies to the Momento Websites and the Momento Ad Services.

    We are not responsible for the privacy practices or disclosures of websites, developers, or apps that access or use the Momento Websites or Momento Ad Services.

    Likewise, when you access the Momento Websites, you may be directed to other websites that are also beyond our control.

    We encourage you to read the applicable privacy policies and terms and conditions of such third parties and websites, and the industry tools that we have referenced in this Policy.



    USERS FROM OUTSIDE THE REPUBLIC OF KOREA

    The Momento Websites and Momento Ad Services are provided, supported, and hosted in the Republic of Korea, and their operation is governed by Republic of Korea law.

    If you are using the Momento Websites or Momento Ad Services from outside Republic of Korea, be aware that your Information may be transferred to, stored, and processed in Republic of Korea and other countries where our facilities are located.

    Moreover, Momento Ad Services are hosted in both the United States and Singapore. Your data may be transferred to, stored, and processed by us in our facilities and our partners in locations where data protection laws may differ from the laws of your country of residence.

    The data protection and other laws of Republic of Korea might not be as comprehensive as those in your country.

    By using the Momento Websites or Momento Ad Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share your information as described in this Policy.



    CHANGES TO THIS PRIVACY POLICY

    We may update this Policy to reflect changes to our privacy practices. The revised Policy will be displayed on the Momento Websites. Please check the Policy occasionally to ensure you have read the latest version and to stay informed of our privacy practices. Your continued access to and use of the Momento Websites and Momento Ad Services constitute your acknowledgement of this Policy and any updates.



    CONTACTING US

    If you have any questions regarding this Policy, please contact us at

    contact@momento.team

    You may also write a mail at:

    Momento, Inc.

    903, 354, Gangnam-daero, Gangnam-gu, Seoul, Republic of Korea

    Phone: +82 10-5801-1902


    Here’s our Data Protection Officer (DPO)’s contact information to protect personal information of end-users and deal with issues regarding personal information.

    You can also contact our DPO at contact@momento.team

    DPO: Sang Bum Han

    903, 354, Gangnam-daero, Gangnam-gu, Seoul, Republic of Korea

    Phone: +82 10-5801-1902



    모멘토 개인정보 처리방침

     

    모멘토 타겟팅 광고

    모멘토는 광고 식별자를 수집하여 모바일 사용자에게 맞춤 광고를 표시할 수 있습니다. 광고 식별자 및 수집 거부 방법은 아래와 같습니다.

     

    모바일 광고 식별자

    모멘토는 모바일 앱 사용자의 광고 식별자인 ADID를 수집할 수 있습니다. 모멘토는 ADID를 이용하여 사용자에게 관심 기반의 맞춤 광고를 제공합니다.

     

    광고 식별자 수집 거부 방법

    사용자는 ADID 수집 거부를 통해 모멘토의 맞춤 광고를 수신하지 않을 수 있습니다. ADID 수집을 거부하는 방법은 다음과 같습니다.

     

    * Android : 설정 > Google 설정 > 광고 > 광고 맞춤 설정 선택 해제

     

     

    * iOS 13 : 설정 > 개인 정보 보호 > 광고 > 광고 트래킹 제한 옵션 활성화 
    * iOS 14.5 이상 : 설정 > 개인 정보 보호 > 추적 > 앱이 추적을 요청하도록 허용 해제

     

     

     

    CONSUMER CONTROL AND OPT-OUT OPTIONS

    In most cases, consumers have control over whether or not they would like to receive relevant ads and marketing email from our Clients.

     

    Opting Out of Online Interest-Based Advertising

    You can opt out of many of the platforms and service providers we work with that support online interest-based advertising by visiting the Digital Advertising Alliance’s consumer education and opt-out page at http://www.aboutads.info

    (Or the European Interactive Digital Advertising Alliance’s opt-out page at http://www.youronlinechoices.eu if you are in the European Union).

    This type of opt out is cookie-based, which means that if you replace or upgrade your browser, or delete your cookies, you will need to opt out again.

    Opting out in this way will not prevent you from receiving ads; rather, the ads you see will be less customized to you.


    Opting Out of Cross-App Advertising on Mobile Devices


    Mobile Ad Identifier
    Momento can collect ADID, the advertising identifier of mobile app users. Momento uses ADID to provide ads based on your information and relevant to your interests. 

     

    You can opt out of having your mobile advertising identifiers used for certain types of interest-based mobile advertising (also called “cross-app advertising”), including those performed by Momento, by accessing the settings on your Apple or Android mobile device, as follows:

    You can opt-out of interest-based ads by following instructions below.



    For Android users:
    Settings > Google (Google services) > ads > Delete advertising ID > Press the button ‘Delete advertising ID’ for once again

    For iOS users:
    Settings > Privacy & Security* > Apple Advertising > Turn off personalized ads.
    *In earlier versions of iOS and iPadOS, this setting is called "Privacy."

    Additional Choices

    Advertisers may also provide ways for you to opt out from, or limit their collection of, certain information from and about you.

    Please refer to the privacy policies for retailers, apps, and mobile websites to learn more about their privacy practices.

    You may opt out from receiving promotional emails from us, such as emails to inform you about events and new services, by following the “unsubscribe” instructions in any promotional email you receive, or by contacting us at contact@Momento.team.

    Please note, however, that we may still send you non-promotional emails relating to your relationship with us.

    Momento Privacy Policy 

    Momento, Inc. (“Momento,” “we,” “our,” or “us”) provides this privacy policy to explain how we collect, use, and share information.

     

    This privacy policy (“Policy”) covers Momento’s handling of two types of information:

    1. Information we receive about end users (“End Users”) of third-party mobile applications (“apps”) that use our Software Development Kit (“SDK”), the Momento Ad Exchange (“Momento ADX”) (collectively, the “Momento Ad Services”)

    2. Information we receive through our website at https://Momento.team or any other website on which this Policy is posted, as well as information we get through other corporate services and web portals, we make available to clients and business partners (“Momento Websites”).

     

    We encourage consumers to learn about how information (including information we collect) can be used to market to them, and how to exercise their choices to permit or limit such marketing.

    We describe ways consumers can exercise that choice or opt out of marketing in Section 4 below, entitled “Consumer Control and Opt-Out Options.”

     

     

    INTRODUCTION

    Momento provides mobile advertising technology services that facilitate transactions among advertisers, app developers, publishers of mobile apps, and ad exchanges (collectively, “Clients”), and service providers and other data partners (collectively “Partners”).

     

    We do this by making available the Momento Ad Services and other tools to Clients.

    Clients use the Momento Ad Services and other tools to deliver advertising to End Users, and we in turn provide our services to help Clients (and their own customers) to deliver ads that are of interest to End Users.

     

    We explain our tracking technologies on Section 3

    1. PRIVACY PRACTICES FOR THE MOMENTO AD SERVICES

    2. INFORMATION COLLECTED THROUGH THE MOMENTO AD SERVICES

     

    Through the Momento Ad Services, we may (but do not necessarily, or always) collect a variety of information about End Users (whether through our SDK or through other partnerships and tools such as Client-facing APIs).

     

    Below is the information we collection for Momento Ad Services

     

    1. Browser and device information

    - Device Type: phones, smart tv, tablet, pc,

    - Device Manufacturer: Device make (e.g., “Apple”).

    - Device Model: Device model (e.g., “iPhone”).

    - Device OS: Device operating system (e.g., “iOS”) along with the version (e.g., “10”)

    - Device Language: Device’s Language (e.g., “ko”)

    - Device carrier code: Mobile Country Codes(e.g., “45123”).

    - Network connection type (e.g., “WIFI”, “Cellular”).

    - Device IFV: identifier of the device dedicated to an app publisher.

    - Device country: Device’s located country (e.g., “KOR”)

    - For DSP’s user-profiling and advertisement purpose

     

    2. IP addresses

    - including both IPv4 and IPv6 (shared with DSPs (Demand Side Partners)

    - For advertisement

     

    3. Geo-location data (town level)

    - For geo-targeting advertisement

     

    4. UserIDs

    - For DSP’s user-profiling

     

    5. Mobile device identifiers (IFDA, AAID)

    - For DSP’s mobile traffic tracking and ad-personalization

     

    6. Data

    - Metrics regarding ad performance, for instance Whether the user has seen the ad or not, Whether the user has clicked the ad or not, etc

    - For DSP’s ad performance and statistics measurement



    We may combine and merge the various types of information collected from the Momento Ad Services

    and may also enhance it (or permit our Clients to enhance it) with information collected from third parties.


    We refer to all the above information as the “Service Information.”

     

     

    How We Use Information Collected Through Momento Ad Services

    We use the Service Information for various advertising and marketing-related services including

     

    1. Delivering ads: Publishers and app developers offer ad inventory, which advertisers and buyers (DSPs) bid on and fill with relevant ads.

    2. Providing and improving Momento Ad Services: Offer customer, technical, and operational support; detect and protect against errors, fraud, or criminal activity; resolve disputes and enforce terms and conditions.

    3. Information and analytics: Provide Clients with information and analytics about the use of app features or help create/enhance user profiles for marketing or analytics purposes.

    4. Developing data models: Predict End Users' future behavior and interests on a per-device basis or across devices.

    5. Analyzing ad performance: Attribute app installations or mobile web visits to ad campaigns.

    6. Data validation and fraud prevention: Match End-User information across multiple devices to validate data, filter out invalid impressions, clicks, installs, or ad queries, and prevent fraudulent activity.

    7. Other essential usage: Comply with legal processes, government authority requirements, protect our business, rights, privacy, and safety, conduct audits, and enforce terms and conditions.

     

    We may combine Service Information to perform the above functions or provide advertising, marketing, or analytics services. This may involve aggregating data and creating data models to predict common interests among End Users.

     

     

    How We Share Information Collected Through Momento Ad Services

    We generally share Service Information with Clients and Partners for providing Momento Ad Services.


    This includes sharing with

    1. Clients and their marketing/service providers for targeted content and advertising to End Users on mobile apps.

    2. Other third parties for targeted advertising, such as demand-side platforms, analytics companies, data  management platforms, proximity solution providers, and other ad technology providers.

    These companies may  provide targeted content and advertising on third-party mobile apps or other media (e.g., email, direct mail, display media).

    3. Clients and their marketing/service providers for measuring marketing effectiveness or analyzing End Users' likely interests or demographics.

    We may continue to use and share your information even if you no longer access our SDK.

     

    The processes often involve cookies or similar technologies, associated with other information

    about End Users, such as interests, demographics, or transactions.

    For controlling or learning about interest-based advertising, see Section4, "Consumer Control and Opt-Out Options."

    We may also share Service Information with third parties: Upon an End User or Client request or authorization In good faith to comply with applicable laws, regulations, requests, orders, or subpoenas, including national security and law enforcement, enforce terms and conditions, protect interests, rights, property, or safety, or investigate suspected/actual unlawful activity.

    When information is aggregated or de-identified; and During business transactions (e.g., purchase, sale, merger, consolidation, investment, change in control, asset transfer, reorganization, liquidation, bankruptcy),

    or steps taken in anticipation of such events (e.g., due diligence).

     

     

    Tracking Technologies

    Momento, our Clients, and third-party partners collect and use information about End-Users through cookies and other tracking technologies, as described below. End-Users may opt-out by following the process in Section 4. EU End-Users' consent is required for tracking technologies.

     

     

    Mobile Device Identifiers and SDKs

    We, our Clients, or Partners may use mobile SDKs (including our SDKs) to collect information, such as mobile identifiers (e.g., iOS IDFAs, Android Advertising IDs), and data on mobile device interactions with our Momento Ad Services. SDKs are computer codes that enable ads, data collection, and related services.

    Clients or Partners may use these technologies to coordinate identifiers across platforms, browsers, or devices for efficient advertising analysis or targeting.

    This technology may also be used to analyze advertising through apps based on information associated with your mobile device.

    For opting out of tailored ads on mobile devices, see Section 4, "Consumer Control and Opt-Out Options."

     

     

    Cookies

    Cookies are small data files with unique browser identifiers. Stored on your device, they identify your browser.

    Our servers may deploy a cookie on your browser when you visit our website at https://Momento.team, subject to EU End Users' prior consent.

     

     

    APIs

    An application programming interface (API) is used to call or request information, like an SDK.

     

     

    Pixel Tags

    Pixel tags, or web beacons, are small blocks of code on a webpage that can read and place cookies.

    They enable us to collect information, such as IP addresses, access time, and browser type.

     

     

    ADHERENCE TO THE TCF IAB FOR EU RESIDENTS ONLY

    As part of our commitment to respecting EU end-user privacy and data protection rights,

    we adhere to the IAB Europe Transparency & Consent Framework (IAB TCF).

     

    Momento, Inc. participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Our identification number within the framework is 1211.

     

    You can also find our VendorID here.

     

    The IAB TCF utilizes a tool known as the TC String to gather explicit user consent or refusal for the usage of tracking technologies for advertising. This information is shared with Momento, as well as our clients and partners, to ensure they can process end-user data in line with GDPR regulations.

     

    According to a ruling by the Belgium data protection authority on February 2nd, 2022, the IAB Europe operates in joint controllership with Consent Management Platforms (CMPs), publishers, and vendors in collecting and distributing TC Strings. This process is based on a legitimate interest legal basis, with an opt-out system in place.

     

    Furthermore, the IAB Europe is considered a joint controller alongside CMPs, publishers, and vendors in the subsequent processing of personal data for advertising purposes, as per the same ruling.

     

    Given that this joint controllership status was established by a ruling, we will periodically update this section to reflect any changes the IAB Europe implements in response to the data protection authority’s decision, which is currently under appeal.

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    HOW DO WE USE THESE TECHNOLOGIES FOR ADVERTISING PURPOSES?

    We use these tracking technologies to collect information automatically from EndUsers’ devices, subject to prior consent from EU End-Users, collected by publishers who work with us.

    They help us identify unique browsers or devices used by an End-User and to perform functions like limiting the same ad from continuously reappearing, ensuring that ads are properly displayed on our publishers’ apps and websites, and serving relevant ads to the End-User.

    Subject to prior and express consent from EU End-Users, our Clients will use information that we share with them to establish connections among related devices (such as smartphones, tablets, and computers) for personalized advertising by Advertisers and agencies, and for analytics, and reporting purposes.

    They may match End User’s devices if the End User logs into the same online service on multiple devices or web browsers, or if the End User’s devices share similar attributes that support an inference that they are used by the same person or household.

    This means that information about an End User’s use of websites or applications on his or her current browser or device may be combined and used with information from the End User’s other browsers or devices.

    For example, this allows Advertisers and Agencies to deliver ads on an End User’s tablet-based on activities the End User engaged in on his or her smartphone. To opt-out of cross-device targeting practices, please follow the instructions in the section below.

     

     

    HOW WE SHARE THE INFORMATION COLLECTED ABOUT END USERS

    Below, we detail when information is shared:

    - To Buyers and Advertisers

    We share information we collect on End Users in connection with our Ad Services to allow them to           make decisions regarding buying advertising inventory on our publishers’ digital properties and other websites and applications, and for billing purposes, dispute resolution or fraud prevention. Moreover, this information, such as a device’s physical location, is also needed to analyze the effectiveness and performance of their advertising campaigns via our services.

    This also enables buyers and advertisers to provide End-Users with more personalized and relevant content.

     

    - To Our Clients’ Attribution and Analytics Partners

    We may share end-user information, such as cookie ID, mobile device ID, or other unique identifiers with our clients’ attribution and analytics partners to validate and measure the success and effectiveness of ads delivered via our Ad Services

     

    - To Clients (Agencies and Advertisers, or Demand Side Partners acting on their behalf)

    They may provide targeted content and advertising to End Users on mobile websites and/or apps. They also may use the data along with analytics companies, data management platforms that help DSPs maintain and use data, proximity solution providers, and other advertising technology providers, such as fraud prevention and performance measurement providers. These companies may, for example, provide targeted content and advertising to End-Users and others on third-party mobile websites and/or apps or other advertising media (such as email, direct mail, and display media).

     

    - To Execute Business Transfers

    In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), the information may also be shared with a third party, as strictly necessary for the purpose of executing business transfers.
     

    - To Comply with Legal Requirements.

     

    If deemed necessary and appropriate, information may be shared

    - in line with applicable law, including laws outside the End-User’s country of residence

    - to comply with legal processes, such as subpoenas, warrants, and others

    - as required by government authorities, including, and excluding government authorities of End-Users’        country of residence

    - to protect our business, rights, privacy, and safety, and those of our subsidiaries and Clients

    - to ensure our terms and conditions are enforced, (v) to pursue legal action and contain damages we          may sustain in relation to such activities

     

     

    PRIVACY INTENDED FOR OUR CLIENTS AND PROSPECTS

    Information may also be collected while using Momento Ad Services such as our website.

     

     

    WHAT CLIENT INFORMATION DO WE COLLECT?

    Information Directly Provided by You

    Visitors and Service users may be asked to voluntarily provide personal information.

    This might occur when visitors contact us via our website. Often, the information we collect include contact details (name, email, phone number), personal information (company, job title, office location), messages detailing the nature of communication, and any attachments visitors may include in relation to this.

     

    Information That’s Automatically Collected

    We use cookies or pixels to collect information that may be considered as personal data in some countries including those under the EU.

    This information allows us to keep track of visitor interactions, optimize our services, customize user experience.

    More information is provided on Section 2. PRIVACY PRACTICES FOR THE MOMENTO AD SERVICES.

     

     

    HOW WE USE THE INFORMATION COLLECTED FROM OUR CLIENTS AND PROSPECTS

    The information we collect on Momento Ad Services are be used for:

    - Account management.Create access to an Momento publisher account and provide specific data related to the use of our Ad Services

    - Service messages.Sometimes, we may need to use this information to send out messages for administrative purposes such as to communicate changes in our terms of service, product policies, and other related updates.

    - Customer service and support.The information you provide may also be used to contact you in response to a request for customer service or support or to provide more information as needed.

    - Analytics and Advertising. We use QUV analytics in our website to collect data for the purpose of research, analysis, and reporting.

    - Improving our products and services.Information collected will also be used to optimize user experience, improve the content we provide, deliver more effective marketing campaigns, and manage our client relations.

    - Legal purposes and risk management.When necessary and under applicable laws, including those outside the End-Users’ country of residence, we may use this information to comply with legal requirements, mitigate risks and damages to our business and that of our clients, and fulfill other similar requirements.
     

     

    END USERS / CLIENTS / PROSPECTS RIGHTS

    End-Users and Clients have the right to request access to, change, update, or delete personal information as required.

    End-Users can withdraw consent allowing us to collect and process personal information at any time.

    Doing so will not affect the lawfulness of any data processing we may have done before the consent is withdrawn or impact any processing done within the bounds of applicable laws that previously depended on that consent.

     

    European Economic Area (EEA) residents also have rights mentioned below.

    - Object to the processing, limit the processing or request portability of their personal information according to GDPR regulation.

    - Complain to a data protection authority about data collection and use of personal information.

     

     

    To exercise those rights, email us at contact@momento.team

     

     

    PRIVACY PRACTICES FOR THE MOMENTO WEBSITES

    Information We Collect Through the Momento Websites

    The Momento Websites provide information regarding Momento and our products and services. Through the Momento Websites, we collect information you voluntarily disclose to us, and we may also obtain automatically collected information.

     

    - Information You Disclose to Us

    We collect information you voluntarily disclose to us, such as your name, mailing address, email address, telephone number, and other billing information. You may also provide us with certain information about your business or other individuals.

     

    - Automatically Collected Information

    When you visit the Momento Websites, we may use cookies and pixel tags that we associate with unique identifiers to keep track of visitor interactions and personalize your experience on the Momento Websites. For more information, please see Section 3 above, entitled “Cookies, Pixel Tags, and SDKs.”

     

    We may also use third party-services, such as Google Analytics, that gather information such as your IP address, browser type, the web page from which you came to the Momento Websites, and the times of your visit.

     

    In addition, as you browse the Momento Websites, advertising cookies may be placed on your computer so that we can “remember” your interests

     

    Our display advertising partners may then help us retarget ads to you on other sites based on your interactions with the Momento Websites.

     

    To opt out of such interest-based mobile advertising, please see Section 4 above, entitled “Consumer Control and Opt-Out Options.” Opting out in this way will not prevent you from receiving ads; rather, the ads you see will be less customized to you.

     

     

    How We Use Information We Collect Through the Momento Websites

    In addition to the uses described elsewhere in this Policy, we use the information we collect through the Momento Websites (alone or in combination) to provide, market, improve, and operate the Momento Websites, Momento Ad Services, and any other products or services we have or may develop.

     

    This includes use of the information to:

    - Fulfill your requests

    - Send information about our products and services, including marketing communications.

    - Respond to your questions, concerns, or customer service inquiries.

    - Create aggregated or de-identified information.

    - Comply with applicable laws, prevent fraud, mitigate risk, and perform similar purposes.

    - Understand usage trends and preferences.

    - Analyze, improve, and provide products and services.

    - Customize the content and advertising you see on the Momento Websites, across the Internet, and elsewhere and/or perform other purposes at your request.

     

     

    DATA ACCESS AND RETENTION

    We retain the information collected from the Momento Websites and Momento Ad Services for as long as necessary to achieve our objectives as detailed in this Policy, and to comply with our legal obligations, resolve disputes, and enforce our agreements.

    If you are a resident of the European Union, you may obtain a copy of the information we have about you by contacting us at contact@Momento.team.

    Please be advised that, due to the way we collect information, we will only be able to provide you with such information if we can determine that the information is identifiable to you.

    Under extenuating circumstances, we reserve the right to charge a fee for providing you with such information, and that fee will be based on costs and fees we incur to fulfill your request.

     

     

    DATA SECURITY

    We have administrative, technical, and physical safeguards in place in our physical facilities and in our computer systems, databases, and communications networks that are designed to protect the information from loss, misuse, or alteration.

    No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your information.

    To assist with data security, you understand that YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF ANY ACCOUNT CREDENTIALS THAT CAN BE USED TO ACCESS ANY ACCOUNT WITH MOMENTO. ANY ACTIONS TAKEN USING YOUR ACCOUNT CREDENTIALS ARE YOUR SOLE RESPONSIBILITY.

     

     

    THIRD-PARTY WEBSITES AND APPS

    This Policy only applies to the Momento Websites and the Momento Ad Services.

    We are not responsible for the privacy practices or disclosures of websites, developers, or apps that access or use the Momento Websites or Momento Ad Services.

    Likewise, when you access the Momento Websites, you may be directed to other websites that are also beyond our control.

    We encourage you to read the applicable privacy policies and terms and conditions of such third parties and websites, and the industry tools that we have referenced in this Policy.

     

     

    USERS FROM OUTSIDE THE REPUBLIC OF KOREA

    The Momento Websites and Momento Ad Services are provided, supported, and hosted in the Republic of Korea, and their operation is governed by Republic of Korea law.

    If you are using the Momento Websites or Momento Ad Services from outside Republic of Korea, be aware that your Information may be transferred to, stored, and processed in Republic of Korea and other countries where our facilities are located.

    Moreover, Momento Ad Services are hosted in both the United States and Singapore. Your data may be transferred to, stored, and processed by us in our facilities and our partners in locations where data protection laws may differ from the laws of your country of residence.

    The data protection and other laws of Republic of Korea might not be as comprehensive as those in your country.

    By using the Momento Websites or Momento Ad Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share your information as described in this Policy.

     

     

    CHANGES TO THIS PRIVACY POLICY

    We may update this Policy to reflect changes to our privacy practices. The revised Policy will be displayed on the Momento Websites. Please check the Policy occasionally to ensure you have read the latest version and to stay informed of our privacy practices. Your continued access to and use of the Momento Websites and Momento Ad Services constitute your acknowledgement of this Policy and any updates.

     

     

    CONTACTING US

    If you have any questions regarding this Policy, please contact us at

    contact@momento.team

    You may also write a mail at:

    Momento, Inc.

    903, 354, Gangnam-daero, Gangnam-gu, Seoul, Republic of Korea

    Phone: +82 10-5801-1902

     

    Here’s our Data Protection Officer (DPO)’s contact information to protect personal information of end-users and deal with issues regarding personal information.

    You can also contact our DPO at contact@momento.team

    DPO: Sang Bum Han

    903, 354, Gangnam-daero, Gangnam-gu, Seoul, Republic of Korea

    Phone: +82 10-5801-1902

     

     

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