Privacy
Policy
Effective Date: 10, November, 2020
Rocket10 (hereinafter referred to as “Company”, “Rocket10”, “we”, “us”, “our”) is a mobile advertising company that provides customers with Advertising Services. We enable our clients to show mobile applications and websites users relevant advertising that is based on users’ interests and behaviors. In order to provide these services, we collect and use certain information about user activity and preferences. We understand that our users care about their personal data and how it is used and shared, and we take their privacy very seriously.

We have created and enacted this Privacy Policy to help to understand our privacy practices.

Please read this policy carefully to understand our policies and practices regarding information and how we will treat it. By using our services in any manner, you acknowledge that you accept the privacy practices and policies we outline in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the ways outlined in this policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
1. What does this privacy policy cover?
This Privacy Policy applies to www.rocket10.com and the online services consisting of providing advertising services in accordance with our Terms of Use. This Privacy Policy describes how Rocket10 collects, uses, shares and secures the Personal Data, users’ choices regarding the use, access and correction of User’s Personal Data. This Privacy Policy also describes how we treat Personal Data that we gather when users are accessing or using our services.

Please note that this policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

This Privacy Policy covers the following:
  • The information we collect;
  • How we use and share Personal Data;
  • Users’ options for opting out of these practices.
2. The information we collect
We collect two main types of information through the Services — Personal Data and anonymous information and we may also generate a third type of information, aggregate information. Aggregate Information means information that describes usage patterns and/or collective data of Users as a group but does not indicate the identity of any particular User, and information about an individual User presented in a form distinguishable from information relating to other Users but not in a form that enables the recipient to personally identify any User.

Depending on Users interaction with the Services, Rocket10 may collect information automatically and/or when our Users voluntarily choose to provide it. We may also acquire information from other trusted sources to update or supplement the information that our Users voluntarily provide to us or that we collect.
3. Information we collect from advertising partners
Legal basis for processing Data, received from Advertising Partners is Performance of a contract. We process data, received from Advertising Partners to perform our obligations under Agreements, concluded with our Advertising Partners.

From our Advertising Partners, we receive the following categories of information:
  • Registration information that is provided when an Advertising Partner concludes an agreement with Rocket10. In order to conclude an agreement, we require all Advertising Partners provide us with basic contact information (such as first and last name, email address and company name).
  • Transaction information that an Advertising Partner provides when an Advertising Partner requests the information from Rocket10, submit a payment to us in connection with the use of the Services, or receive a payment from us in connection with the use of the Services. Examples of transaction information include basic contact information, bank or financial account information, credit card or debit card numbers and similar details required to process an Advertising Partner`s payments or respond to an Advertising Partner`s request.
  • Technical, viewing and usage information that relates to an Advertising Partner`s interaction with the Site, such as physical location and the amount of time spend viewing certain portions of the Site. Also, this includes collecting unique mobile device ID or the internet protocol (IP) address online identifiers, which can uniquely identify a specific computer or other network device on the internet. This information is linked to a cookie ID, which we receive and process. More information on our use of cookies you may find in section Cookies and Tracking Technologies below.
We may also collect certain types of information automatically through the use of Cookies as outlined below and other similar tracking technologies. These tracking technologies enable us to personalize experience with the services and improve the services for the Advertising Partners.

In case of any breach of data Advertising Partners will be notified within 72 hours of becoming aware of the leak.
4. Information we collect from end users
End Users are those individuals who download, use or otherwise interact with a mobile apps and/or websites of our Advertising Partners and/or 3rdparties that work directly with mobile apps developers.

Legal basis for processing Data from our End Users is Performance of a contract. We process End Users data, received from our Advertising Partners to perform our obligations under Agreements, concluded with our Advertising Partners.

If you are an End User that uses or otherwise interacts with our website or the services, we may collect and transfer non-sensitive device Data provided by our advertising exchange partners that may consist of the following:

  • clicks, actions and impressions data;
  • http headers;
  • Publisher details (such as site ID, publisher ID, publisher name);
  • IP Address;
  • Identifier for advertiser (e.g. Google Advertiser ID or Apple Advertiser ID);
  • Device identifier;
  • Mobile application name or web-site.
Please note that the listed Data is not collected by Rocket10, we receive it directly from mobile app owners or developers, sources, agencies, partners.  By downloading or opening a website and using an advertising partner mobile application, End User grants permission to the mobile application developer to collect device information and share it with us in accordance with our agreement with the advertising partner. We may track this information and may also combine the device information with anonymous information from other sources in order to deliver advertisements through the Services. In addition, Rocket10 may collect information from End Users through use of a Cookie or similar tracking technologies if the End User accesses advertisements from a browser or is redirected to a browser by advertisements provided through the Services. Certain advertisements may redirect to a browser where we may use a Cookie to track an End User activities. In case of any breach of data data-controllers and End Users shall be notified of the breach without undue delay.
5. Information you provide to us
Legal basis for processing Data You provide to us is your Consent. We receive and store any information you knowingly provide to us. For example, we collect Personal Data such as your name, email address, browser information. You have an opportunity not to provide us with certain information, but then, unfortunately we will not be able to register you or provide you with advantage of some of our features.

If you have provided us with a means of contacting you, we may use such means to communicate with you. For example, we may send you promotional offers on behalf of other businesses or communicate with you about your use of the Services. Also, we may receive a confirmation when you open a message from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by emailing us at: hello@rocket10.com. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the services, and you are responsible for reviewing such legal notices for changes.

Additionally, you may sign up to receive reports and communications from us. If you would like to discontinue receiving any information that you receive from us, you may email us at: hello@rocket10.com.
6. Information collected automatically:
Passive Collection: Cookies and Tracking Technologies

The legal basis for the Cookies and Tracking Technologies processing is Legitimate interest. Our legitimate interest follows from the above listed purposes for data processing. Under no circumstances do we use the collected data, except for the purposes listed above.

As is true of most websites and advertising companies, we gather certain information automatically. This information may include Internet protocol (IP) addresses, location (country or town), OS type and version, browser type and version, type of device and its display resolution, traffic source for the visitor, OS and browser language, which buttons are being clicked and what pages are being opened, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

Rocket10 and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.

Cookies are small text files placed on Users computer by websites that Users visit. They are widely used in order to make websites work, or work more efficiently, as well as provide information to the owners of the site.

Users can control the use of cookies at the individual browser level, but if a User choose to disable cookies, it may limit User`s use of certain features or functions on our website or service. We follow guidelines set forth by the Information Commissioner’s Office with regards to European Union rules on cookie use. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org.

Please be advised that in some countries data such as cookie IDs and IP-/MAC- addresses are considered to be personal information. To the extent we process such data that is considered personal information, this will be done in accordance with our Privacy policy.

Our site uses the following types of cookies:

STRICTLY NECESSARY COOKIES

These cookies are essential in order to enable Users to move around the site and use its features. These are known as “First Party” cookies. Without these cookies, services like enabling appropriate content based on your type of device cannot be provided. GTM Cookie. Helps make tag management simple, easy and reliable by us to deploy website tags all in one place. In this case, tags are most often JavaScript and non-JavaScript code.

PERFORMANCE COOKIES

These cookies provide information about how visitors use the site so that we can analyze traffic and understand how our Users and/or visitors use our site. We use cookies issued by a third parties: Yandex.Metrica, Google Analytics, Facebook, Twitter and LinkedIn. For example, Google Analytics, for this purpose (“Third Party” cookies). Google Analytics uses its own cookies. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the site works.

FUNCTIONALITY COOKIES

These cookies allow our site to remember choices our Users and/or visitors make (such as the region they are in) and provide enhanced, more personal features. These cookies will also be used to remember changes our Users and/or visitors have made to text size, fonts and other parts of web pages that they can customize. They may also be used to provide services our Users and/or visitors have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track our Users and/or visitors browsing activity on other websites.

SOCIAL MEDIA COOKIES

These cookies are used when our Users and/or visitors share information using a social media sharing button or when they link their account or engage with our content on or through a social networking site such as Facebook, Twitter or Google+. The social network will record that our Users and/or visitors have done this. This information may be linked to targeting/ advertising activities.  

How to reject cookies?

If you don’t want to receive cookies, you can alter your browser settings. The procedure for doing so varies from one browser application to another. If you wish to reject cookies from our site, but wish to accept those from other sites, you may choose the option in your browser settings to receive a notice before a cookie is stored on your device. Please consult the “Help” section of your browser for more information.

To find out more about cookies, please visit the relevant website set out next to your country of origin below:
United Kingdom
Your Online Choices:
www.youronlinechoices.com/uk
Other European Countries
Your Online Choices:
www.youronlinechoices.com
Any
All About Cookies:
www.allaboutcookies.org
Most browsers accept cookies automatically, however some people prefer not to allow cookies. You may change the security settings of your web browser in order to stop your device receiving and storing cookies, to allow receiving and storing cookies from selected websites you trust, or to be notified before receiving cookies. You may also delete cookies stored in your browser at any time. Information stored in such cookies will be removed from your device. However, that these settings may have negative effects on the web sites usability.

Browser manufacturers usually provide help pages relating to cookie management in their products. Please see below for more information:

— Google: https://support.google.com/chrome/answer/95647?hl=en–GB;
— Internet Explorer: https://support.microsoft.com/en–us/help/260971/descriptio–of–cookies;
— Mozilla Firefox: https://support.mozilla.org/en–US/kb/cookies–information–websites–store–on–your–computer;
— Safari (Desktop: https://support.apple.com/kb/PH5042?locale=en_US;
— Safari (Mobile): https://support.apple.com/en–us/HT201265;
— Android-браузер: https://support.google.com/nexus/answer/54068?visit_id=1–636585517588941681–639659396&hl=en&rd=1;
— Opera: https://www.opera.com/help;
— Opera Mobile: https://www.opera.com/help/mobile/android#privacy.

For other browsers, please consult the documentation that your browser manufacturer provides. Please note that by disabling cookies, you may be prevented from accessing some features of our site or certain content or functionality may not be available.

User Data Supplementation

We receive information from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have. This helps us to update, expand and analyze our records, identify new customers, deliver our marketing services and provide products and services that may be of interest to Users. If Users provide us Personal Data about others, or if others give us Users information, we will only use that information for the specific reason for which it was provided to us.

Advertising Partners wishing to opt out from information from Rocket10 can click “UNSUBSCRIBE” in marketing emails or email us at
hello@rocket10.com.

Examples of the types of Personal Data that may be obtained from public sources or purchased from third parties and combined with information we already have, may include purchased marketing data from third parties that is combined with information we have been provided by business partners, to create more tailored advertising and products.


Behavioral Targeting

We cooperate with a third party to display advertising to manage our advertising on other sites and/or apps. Our third-party partner may use cookies or similar technologies in order to provide Users advertising based upon Users browsing activities and interests. If you are a User and you wish to opt out of interest-based advertising click http://preferences-mgr.truste.com or if located in the European Union click http://www.youronlinechoices.eu.  Please note that you will continue to receive generic ads. If you do not want to receive generic ads contact us at hello@rocket10.com.
7. Information we collect from person replied to the contact form
If you are the person who replies to our contact form located at https://rocket10.com/contact-en we collect the following categories of information from you:
  • Your Company name
  • Your last name
  • Your first name
  • Your email
We use this categories of information solely for the purpose of getting in touch with persons, who replied to our contact form. If you reply to this form you give us express consent to contact you directly.
8. What does rocket10 use the personal data for?
Uses of Information We Collect

Rocket10 uses the information we collect to provide the Services and to gain a better understanding of the products and services that may interest our Users. For example, we use information in order to:
  • Operate, manage and improve the Services;
  • Fulfill Users requests for certain products and services;
  • Provide Users with requested services;
  • Communicate with Users about their Rocket10 accounts, interactions with the Services, etc;
  • Protect the rights or property of Rocket10 or third parties;
  • Deliver targeted advertisements on behalf of our Advertising Partners and Clients;
  • Analyze how users utilize the Services.
The Services may link to third party websites, non-Rocket10 Apps and/or other third-party content. Please note that Rocket10 cannot control the treatment of Users information by such third parties, and that the privacy practices of third parties likely differ from those described in the Policy. We also may share certain types of Personal Data with third parties, as described below.
9. Will rocket10 share any of the personal data it receives?
We have implemented measures designed to secure Users Personal Data from accidental loss and from unauthorized access, use, alteration and disclosure. The safety and security of Users information also depends on Users themselves. We ask Users not to share passwords with anyone.

Sharing of Information We Collect

We neither rent nor sell Users Personal Data to anyone. However, we do share Users Personal Data with third parties as described in this Privacy Policy.

Affiliated Businesses and Third-Party Websites We Do Not Control.

In certain situations, businesses or third-party websites we’re affiliated with provide services to our Users (either alone or jointly with us). A User can recognize when an affiliated business is associated with such a transaction or service, and we will share User`s Personal Data with that affiliated business only to the extent that it is related to such transaction or service.

We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if our User choose to take part in any transaction or service relating to an affiliated website or business, this User is advised to review all such business’ or websites’ policies.

Service Providers

We employ other companies and people to perform tasks e.g., provide computer and network infrastructure services on our behalf and need to share Users Data with them to provide products or services to Users. Unless we tell Users differently, our agents do not have any right to use the Personal Data we share with them beyond what is necessary to assist us.

Legal Notice

We also disclose Users Personal Data as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect Users safety or the safety of others, investigate fraud, or respond to a government request.
10. How can a user opt-out of seeing interest-based advertising from rocket10?
To opt-out please email us at hello@rocket10.com.

Opting-out just means that the advertisements Users do receive from us will not be targeted in any sort of way. If you are a User, note that even if you opt-out, you may still receive content and advertising from us and more over:
  • You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.
  • You may limit the disclosure of certain Non-Personal data by your mobile Device to us and Partners by adjusting the settings on your mobile Device.
  • You may opt out of certain cookies and browser-enabled, interest-based advertising. Please note that these opt outs apply to interest-based advertising by participating advertisers. You may still receive other types of online advertising from participating partners, and the websites you visit may still collect information for other purposes. In addition, the opt-out choices you select are stored in opt-out cookies only in the browser that you use to visit the opt-out websites, so you should separately set your preferences for other browsers or Devices you may use. Deleting browser cookies can remove yours opt-out preferences, so you should visit these opt-out websites periodically to review your preferences or update your preferences to apply to new participating advertisers.
  • Partners may also provide ways for you to opt out from or limit their collection of information from and about you. Please note, however, that we are not responsible for the privacy practices of Publishers, Advertisers, and other third parties.
11. Security
The security of Users Personal Data is important to us.  We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and once it is received. If you are a User and you have any questions about the security of Personal Data, you can contact us at hello@rocket10.com.

Access

Upon request, Rocket10 will provide you with information about whether we hold any of your Personal Data. If you are a User, you may access, correct, or request deletion of your Personal Data by contacting us at hello@rocket10.com. We will respond to a request within a reasonable timeframe.

Data Retention

We will retain User`s Data for as long as it is needed to provide services. We will retain and use User`s Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

The use of information collected through our service shall be limited to the purpose of providing the service for which a User have engaged Rocket10.

Rocket10 collects information under the direction of Users and its customers and has no direct relationship with the individuals whose Personal Data it processes. If a User is a client of one of our customers and would no longer like to be contacted by one of our customers that use our service, such User is advised to contact the customer that it interacts with directly.

We may transfer Personal Data to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.

Rocket10 acknowledges that Users have the right to access their Personal Data. Except for the Rocket10 Clients, Rocket10 has no direct relationship with the individuals whose Personal Data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the data controller of the relevant Personal data. If requested to remove data, we will respond within a reasonable timeframe.

Please be sure to include name, address and email address in any correspondence to us so that we can respond in a timely manner.

We will retain Personal Data we process on behalf of our customers for as long as needed to provide services to our customer. Rocket10 will retain this Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Children’s privacy

We do not knowingly collect or solicit Personal Data from anyone under the age of 13 or knowingly allow such persons to register for the Services. If a User is under 13, it is required not attempt to register for the Services or send any information about itself to us, including name, address, telephone number, or email address. No one under age 13 may provide any Personal Data to us or on the Services. In the event that we learn that we have collected Personal Data from a child under age 13, we will delete that information as quickly as possible. If a User believe that we might have any information from or about a child under 13, please contact us at hello@rocket10.com.
12. Changes to this privacy policy
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify our Users by email (sent to the e-mail address specified in User`s account) or by means of a notice on this website prior to the change becoming effective. We encourage our Users to periodically review this page for the latest information on our privacy practices.
13. Contact information
Since we are committed to protecting Users privacy as set forth in this Policy, if a User think we are not in compliance with our Policy, or if a User have any question or if a User wish to take any other action concerning this Policy or User`s Personal Data, we encourage our Users to contact us at hello@rocket10.com. We will investigate User`s complaint, take appropriate action and report back within 45 days.

Rocket10 is a brand name, represented by legal entity Ironspace Inc, having its address at 1401 Brickell Ave Ste 330, Miami, FL 33131, StoneBird Inc, having its address at Suite 21&22, 2nd Floor, Oliaji Trade Centre, Francis Rachel Street, Victoria, Mahe, Seychelles, and CGINM Operations OÜ, having its address at Harju maakond, Tallinn, Kesklinna linnaosa, Jõe tn 3-301, 10151. hello@rocket10.com.