Ogury’s Data Usage Principles
Welcome to Ogury

Ogury cares about its users’ privacy and is committed to clearly describing and disclosing its data practices.

For the purposes of the United Kingdom Data Protection Act 1998 (the “Act”), the data controller of any Personal Data (as defined in the Act) comprised in User Data is Ogury Limited of Unit 211, The Screenworks, 22 Highbury Grove, London, N5 2EF (“Ogury”, “we” or “us”).

These Data Usage Principles (the “Principles”) explains how Ogury collects, stores, uses, and shares information (including Personal Data) from and about end users’ use of mobile applications into which publishers or developers have integrated the Ogury Product (“Partner Apps”) as well as information about the Partner Apps themselves – we call this information “User Data” and what it comprises is described at the section titled “Ogury’s privacy practices concerning User Data”, in particular the sub-section titled “What is User Data?”.

Ogury’s privacy practices concerning User Data


What is the Ogury Product and how does it work?

Ogury has developed and maintains software code that it integrates into Partner Apps operated by publishers and app developers (“Publishers”) – in these Principles this technology is called the “Ogury Product”. Once the Ogury Product has been integrated into a Partner App, with Users’ consent, Ogury may collect User Data from the tablet, mobile or handheld device (“Device”) on which a Partner App is installed in the manner described in these Principles.

For the purposes of these Principles, we refer to those individuals, on whose Device a Partner App integrating the Ogury Product has been installed, as “Users”.

How is User Data used?

In simple terms – User Data is used by Ogury, advertisers and advertising agencies and Publishers (together “Partners”), so Users can see adverts for products and services they actually want to see based on how they use their Device.

Adverts of this nature are commonly referred to as “interest-based advertisements” or “behavioural advertising”. For more information on interest-based advertising, how it works, and information on choices about how Users can interact with it, Users can go to http://www.youronlinechoices.com/uk/. This is a helpful guide made available by the European Interactive Digital Advertising Alliance a cross-industry coalition of European-level associations with an interest in delivering a responsible European Self-Regulatory Programme for Online Behavioural Advertising, which benefits internet users with greater transparency, choice and control.

Collecting User Data also allows us to effectively cap the number of times that Users see an Ogury Ad, so they do not see the same one too many times or too frequently.

We may also use User Data to create aggregated compilations of Users which is “de­identified” in a manner which prevents that User Data from being associated with, or capable of being associated with, any particular Device, Partner or Partner App (“Aggregated Data”).

In addition to the processes described above, Ogury also uses User Data for its internal purposes which may include:

  • performing analysis and research aimed at improving the Ogury Product and the services and products Ogury provides to its Partners; and
  • security and fraud detection.

What is User Data?

The Ogury Product allows Ogury to collect real-time information about Users, including the following categories of information which we collectively refer to as “User Data”:

Usage Data

Information and data about how Users use their Devices, together with the applications and systems on those Devices – this information includes:

  • What Users have bookmarked.
  • What applications Users have downloaded (including the nature and category of those applications).
  • Users’ usage levels of the applications they have downloaded.
  • The nature of any products or services viewed by Users on their Device, whether in‑app or via their browser.

The Usage Data collected by the Ogury Product is not limited to Usage Data that directly relates to the Partner App in which the Ogury Product is integrated. Rather, the Ogury Product collects Usage Data from all applications and systems on the Device on which a Partner App is installed.

Technical Information

Technical Information that is collected by the Ogury Product may include:

  • The type of Device being used (including manufacturer and model).
  • The version number of the Ogury Product used by the Partner App.
  • A User’s network status.
  • Other analytics and information about Users’ use of their Devices together with the applications and systems on that Device.

Identifiers

To allow Ogury to collect the Usage Data and Technical Information listed above and link it to individual Users, the Ogury Product also collects certain device and user identifiers, which may include a User’s:

  • Email address.
  • Google Advertising ID.
  • Android ID.
  • Users’ Device ID.

These are used by Ogury and its Partners to link individual Users with their Devices.

All User Data we collect is associated with these Identifiers, rather than their name or other personal information.

Ad Engagement Information

To enable Ogury and its Partners to provide personalised Ogury Ads to Users and to report back to our Partners on Users’ engagement and interaction with Ogury Ads, we collect information on how Users engage with Ogury Ads that are displayed to them, including:

  • What each Ogury Ad is about.
  • The format of each Ogury Ad (e.g., text, image, or video).
  • Where the Ogury Ad is displayed within the Partner App.

In addition, we combine the Ad Engagement Information with Usage Data collected about Users to determine what Users do when interacting with or after viewing each Ogury Ad – for example, did a User go on to buy the product or services that were displayed to them in an Ogury Ad?

Our policy towards children

In accordance with applicable European Union guidance on the practice, we do not use any User Data to target adverts to children. Accordingly, we do not use the User Data we collect to specifically target Ogury Ads to children under 13 years old.

Other Information

User Data includes any other information (including Personal Data) that may be submitted to us directly.

Users’ acceptance of our Principles

Ogury adheres to its obligations under the Privacy and Electronic Communications Regulations (as amended to implement the EU Cookie Directive). Accordingly, Users are required to give their consent before Ogury starts to collect any User Data from them. In addition, Users may opt-out of such collection at any time by following the instructions outlined at the section titled “Opting Out of Ogury Interest­based Advertising”.

Accordingly, when Users first open a version of a Partner App which contains the Ogury Product, a page is displayed which notifies them that, with their consent, certain User Data will be collected by the Ogury Product unless and until they opt-out from such collection. So that Users are fully and properly informed about our data usage practices and how their User Data is collected, stored, used and shared, they are also provided with a link to these Principles.

If Users do not provide accept the terms of these Principles, Ogury will not collect their User Data and will not deliver them targeted Ogury Ad’s. However, Users will still see advertisements in their Partner App, but the advertisements they see will not be tailored to them based on their User Data.

Opting Out of Ogury Interest-based Ogury Ads

Users can opt out of receiving targeted Ogury Ads and having their User Data collected by Ogury by:

Sending an email to privacy@ogury.co with their Google Advertising ID and opt-out from receiving interest-based Ogury Ads

When Users notify us of their desire to opt-out of receiving interest-based Ogury Ads, we will as soon as reasonably practicable stop collecting their User Data. If they opt-out, Users will still see advertisements in their Partner App, but the advertisements they see will not be tailored to them based on their User Data.

In addition, we will, as soon as reasonably possible, delete from our systems any Personal Data comprised in the User Data that we have already collected.

In addition to the opt-out process described above, if their Device permits, Users can opt out of interest-based advertising by changing the settings of their Google Advertising ID by clicking the button titled “opt out of interest-based advertising” in Settings > Google in their Device’s app menu. For more information on this, Users can follow the instructions provided by Google here: Google Play Help. Users should be aware that clicking this opt-out button will disable interest-based ads from all advertising networks that use Google Advertising IDs, although Users will still see untargeted advertisements.

How Ogury shares User Data

We share the User Data (including any Personal Data comprised therein) that we collect in the following ways and with the following parties:

Publishers and Advertisers

We may share User Data with our Partners to aid in their understanding of how Users are using Partner Apps and engaging with Ogury Ads.

Aggregated Data

We may share or sell compilations of Aggregated Data with third parties (including Data Management Platforms).

Service Providers

We may share User Data with the service providers who perform services on our behalf, such as providers of analytics, payment processing, product fulfilment, technical infrastructure, data services, engineering and other technical support, and email and customer support.

Business Transaction

We may share User Data in connection with any merger, reorganisation, a sale of some or all Ogury assets, or a financing or acquisition of all or a portion of our business by another company. In these circumstances, Ogury will endeavour to ensure that the parties with whom User Data is shared agree appropriate confidentiality terms to protect the User Data they receive.

Legal Purposes

We may share User Data for the following purposes:

  • To comply with laws or to allow us to enforce the terms of these Principles.
  • To respond to lawful requests and legal processes.
  • To protect the rights and property of Ogury, our agents, customers, and others.
  • To protect the safety of our employees and agents, our Partners or any other person.

Ogury Affiliates

We may share User Data with other companies within the Ogury group. For these purposes, this means other entities that Ogury controls or are under common control with Ogury. We share information in this way to allow Ogury to provide certain services to such companies and to allow them to perform services for Ogury. This allows us to better help our Partners provide Ogury Ads that are relevant to Users.

International Data Transfer

User Data, including any Personal Data therein, may be transferred to, stored at and processed by third parties in a country outside the EEA.

Users should be aware that the data protection and privacy regulations that apply in countries outside the EEA may not offer the same level of protection as provided for inside the EEA.

We require Users provide their consent to the storage, processing and transfer of their User Data in and to countries outside the EEA. We do this by requesting their consent to these practices in the notice that is displayed to them when they first use a Partner App containing the Ogury Product.

We will take all steps reasonably necessary to ensure that such Personal Data wherever it is held or processed is treated securely and in accordance with these Principles and the Act.

Data Management Platforms

We may share or sell User Data to data management platforms that are used by participants in the advertising industry as sources of data (“Data Management Platforms”). The User Data we may share or sell may include any or all of the User Data outlined above, including Users’ email addresses.

Data Management Platforms use the data Ogury. and many other participants in the advertising industry, sell to them to inform advertising targeting and the purchase of advertising space.

General

Security

We seek to use reasonable organisational, technical and administrative measures to protect User Data within our organisation. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If a User has any reason to believe that their interaction with us is no longer secure, they should notify us of this problem immediately by contacting us at privacy@ogury.co

Customer Support

If, while using one of our Partner Apps, a User recognises a problem with an Ogury Ad, they can notify us of the problem by contacting us via email at privacy@ogury.co. We will ask for their email address and other contact information so that they can receive a response.

Request Your Information

The Act gives any individual whose Personal Data we store, the right to access that data. If you wish to exercise this right in accordance with the Act, please contact us at privacy@ogury.co. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

Sensitive Information

We do not collect any sensitive Personal Data in the User Data. Examples of sensitive Personal Data include information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership.

Third Party Operations

If Users follow a link to any of third party websites via an Ogury Ad, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. We ask that Users please check these policies before they submit any information to these websites. The links to third party websites or locations are for convenience only and do not signify our endorsement of such third parties or their products, content, or websites. If Users disclose information to others, or authorise us to do the same under these Principles, the use and disclosure restrictions contained in these Principles will not apply to any third party. Ogury does not control the privacy policies of third parties.

Contact Us

If you have any questions or concerns regarding our data usage principles, please send us a message at privacy@ogury.co.