Privacy Policy

LAST UPDATED: November 28, 2018

Tenjin, Inc. is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. The first section of this document describes our practices in connection with information that we collect from our customers and potential customers through the websites operated by us from which you are accessing this Privacy Policy (the “Websites”), and from users of the Websites (whether or not such users are our customers). The Websites include tenjin.io, tenjin.com, blog.tenjin.io, blog.tenjin.com, docs.tenjin.io, docs.tenjin.com, help.tenjin.io, help.tenjin.com, track.tenjin.io, and track.tenjin.com. The second section describes the information we collect in the course of providing services to our customers (the “Services”).

Tenjin provides tools and services to mobile app developers so that they can track and analyze certain End User actions in the context of mobile marketing. Tenjin does not collect any data directly (except from the companies and people that sign up for Tenjin or request marketing info, which is described in the Website Privacy Policy below). With regard to Tenjin’s Services, under the EU’s General Data Protection Regulation (the “GDPR”), Tenjin is a data processor. As a data processor, Tenjin processes, and may store, information sent by Tenjin customers from their mobile apps. Tenjin’s customers may send information about the End Users of their apps, and the users' devices, to Tenjin for processing and storage. The mobile app developers must receive your consent in order for Tenjin to process, and perhaps store, your data. Tenjin recognizes your right of access under Section 15 of GDPR. If you are a user of a Tenjin customer’s mobile app, and you wish to exercise your right of access, you must contact the owner or operator of the mobile app (the data collector).

EU–U.S. Privacy Shield and Swiss–U.S. Privacy Shield

Tenjin complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively. Tenjin has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Tenjin is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Tenjin may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Tenjin is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Tenjin complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Tenjin commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Tenjin at: privacy@tenjin.io.

Tenjin has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

The above applies to both Section 1 and Section 2 below.

SECTION 1: WEBSITE PRIVACY POLICY

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable person. We collect Personal Information, such as name, organization name and email address, from our customers and potential customers when they provide it to us through the Services (such as by creating an Account), through the Website, or via email sent to a Tenjin email address.

How We May Use Personal Information

We may use Personal Information:

  • To respond to your inquiries and fulfill your requests.
  • To send administrative information to you, such as information regarding our services and changes to our terms, conditions and policies.
  • To provide you with customer service.
  • To send you marketing communications that we believe may be of interest to you.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  • As we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed:

  • To our affiliated and third-party service providers and consultants who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services.
  • To a third party 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).
  • As we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as browser and device information; information collected through cookies, pixel tags and other technologies; and aggregated information.

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

  • Using cookies: Cookies are pieces of information stored directly on the device that you are using to access the Websites. Cookies allow us to collect information such as browser type, time spent on the Websites, pages visited and other anonymous traffic data. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Websites. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your hard drive. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.
  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Websites to, among other things, track the actions of users (including email recipients), measure the success of our marketing campaigns and compile statistics about use of the Websites.
  • Using a third-party analytics provider: We use Google Analytics and Tenjin for our Website analytics. These providers use cookies and similar technologies to analyze how users use the Websites, compile statistical reports on Website activity, and provide other services related to the Websites. They may also collect information about Website visitors’ use of other websites. For more information about Google Analytics, including how to opt out, please go to: https://tools.google.com/dlpage/gaoptout. For more information on Tenjin’s privacy practices, please go to: https://legal.hubspot.com/privacy-policy.
  • IP Address: Your IP Address is a number that is automatically assigned to your computer by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Websites, along with the time of the visit and the page(s) visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Websites.
  • By aggregating information: Aggregated Personal Information does not personally identify you (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Websites link. The inclusion of a link on the Websites does not imply endorsement of the linked site or service by us or by our affiliates.

SECURITY

We take reasonable administrative, physical and electronic measures designed to protect Personal Information and Other Information from unauthorized access, use or disclosure. Data collected from your device is encrypted using SSL or other technologies. 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.

CROSS-BORDER TRANSFER

The Websites are controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Websites you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

MODIFYING INFORMATION

Customers can access and modify their billing address by emailing privacy@tenjin.io. If customers want to delete their own Customer Data or their Account from the Services, customers can contact us at privacy@tenjin.io with a request. We will delete the Customer Data but some information may remain in archived/backup copies for our records or as otherwise required by law. If a customer ceases subscribing to the Services, please email privacy@tenjin.io and we’ll automatically delete the customer’s Account and take steps to delete that customer’s Customer Data from the Services.

Tenjin acknowledges that EU and Swiss individuals have the right to access the personal information that we maintain about them. An EU or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to privacy@tenjin.io. If requested to remove data, we will respond within a reasonable timeframe.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Websites. Your use of the Websites following these changes means that you accept the revised Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us at privacy@tenjin.io.

SECTION 2: SERVICES PRIVACY POLICY

CUSTOMER DATA

Our customers are advertisers. On behalf of a customer, we receive data about its advertising campaign on a particular advertising network directly from that network. “Customer Data” means advertising campaign data or information made available to Tenjin or the Tenjin Platform by or on behalf of a customer or any Authorized User, or via a customer’s use of the Tenjin Platform. We format and otherwise process the Customer Data, to help our customer understand and analyze the effectiveness of and costs associated with its advertising campaigns across various advertising networks.

HOW WE COLLECT CUSTOMER DATA

We collect Customer Data through Tenjin’s software development kit (“Tenjin SDK”) that customers have a license to use. We may also collect Customer Data from our customers’ third party mobile marketing partners, to the extent that the customer has authorized us to do so.

HOW WE USE CUSTOMER DATA

We use Customer Data to provide the Services to the relevant customer. We may also use it to improve the Services and develop new products and services.

We do not share Customer Data with any customer other than the customer to which it relates, unless we have received the prior express written consent of the customer to do otherwise. Without consent, we may disclose Customer Data:

To our affiliated and third-party service providers; and To a third party 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).

In addition, we may use or disclose Customer Data as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Unless prohibited by applicable law or advertising network terms, we may aggregate Customer Data such that it is not reasonably identifiable with or to the customer to which it relates, or the customer’s end users (“Aggregate Data”). We may share Aggregate Data with third parties for industry research and analysis, demographic profiling and other similar purposes.

HOW WE COLLECT AND PROCESS END USER DATA FOR CUSTOMERS

Customers may send information about individuals using their app (“End Users”) to Tenjin for processing and storage. This information may include Vendor ID (if available), IP address, Apple Search attribution (if enabled), Bundle ID, SDK Version, App Version, OS Version, Device Type, Device Model, Device Locale, Device Country, OS Platform, Limit Ad Tracking setting, and Advertising ID. Advertising IDs are user-specific, unique character strings that can be reset by the user and are used to track an End User’s device for advertising purposes. Examples include Google Ad ID and IDFA.

Tenjin customers must abide by all applicable laws and obtain all applicable consents before sending End User data to Tenjin. If you feel that your data has been collected by a Tenjin customer without your consent, please contact the Tenjin customer directly.

Tenjin also recognizes the Right to Erasure under Article 17 of GDPR. For erasure requests, since Tenjin is a data processor, please contact the Tenjin customer to have your personal data erased.

HOW WE PROCESS AND SECURE DATA

Tenjin is a SaaS company whose solutions are built on the AWS platform. Data is processed by Tenjin in secure locations operated by Amazon (AWS) in the United States.

Tenjin uses appropriate and reasonable measures to protect data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, while taking into account any inherent risks and the nature of the data. Additional details on AWS security certifications and procedures can be found here: https://d1.awsstatic.com/whitepapers/Security/AWS_Security_Whitepaper.pdf.

QUESTIONS

Please contact us at privacy@tenjin.io if you would like to contact Tenjin’s Data Protection Officer (DPO), EU representative under GDPR Article 27, or if you have any questions about our Privacy Policy.