Introduction

We, at Singular, Inc. (“we”, “our” or “us”) have developed and offer a technology platform that provides businesses the ability to administer, measure and monitor their mobile advertising activities.

Singular’s technology serves as a third-party plug-in (“Plug-In”) that is incorporated into the business’s online service (which may be a website or mobile app). Through the Plug-In, we collect and maintain certain personal information on the business’s behalf.

Depending on the nature of the business’s online service, it may be directed to children. Where this is the case, the business on whose behalf we collect the personal information is considered the primary operator liable for compliance with the requirements of the U.S. federal Children’s Online Privacy Protection Act and its regulations (COPPA) and GDPR, and we in fact require the business to fully comply with these regulations.

This document provides notice of our information practices with regard to the Plug-In, as it pertains to child directed services.

Compliant Solution for use in Child Directed Online Services

Singular has developed a solution that allows businesses to use its technology platform without sharing the personal information of users in a child directed online service (website or mobile app). Singular is a service provider and does not have actual knowledge of the age of users in an online service. The business is required to inform Singular if its online service is child directed and is required to implement the compliant solution in its website and or mobile app. If Singular becomes aware that a business has failed to implement the compliant solution in a child directed service, Singular will cease processing personal information on behalf of the business and will delete any personal information on record. Please also see the terms of service here: www.singular.net/terms

Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification & GDPRkids™

Singular Labs, Inc. (attribution solution for child directed apps) is a member of the PRIVO Kids Privacy Assured Program (“the Program”) for COPPA Safe Harbor Certification and GDPRkids™. PRIVO is an independent, third-party organization committed to safeguarding children’s personal information collected online.

COPPA Safe Harbor Certification

The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO COPPA certification Seal. The certification Seal posted on this page indicates Singular Labs, Inc.  has established a COPPA compliant solution and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at (415) 745-5933 or privacy@singular.net. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

GDPRkids™ Privacy Assured

The Program applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO GDPRkids™ Verified Shield. The PRIVO GDPRkids™ Privacy Assured Program supports child directed services known as Information Society Services under the General Data Protection Regulation (GDPR), to comply with the requirements of this legislation. It impacts any child directed service in an EU Member State and any service globally that collects and or processes the personal data of children and minors. There is no safe harbor for the GDPR to date, but to ensure this company’s services meet the program requirements, we conduct regular monitoring and consulting.

Information collected

Our Plug-In collects the following information:

Persistent identifiers that can be used to recognize a user over time and across different websites or online services, including IP address, Advertising ID for Android (AIFA) devices or Google Android ID. When a service is child directed this information is stripped from post backs sent to ad networks so that no personal information is shared with third parties and so that the end user cannot be tracked.

Where the Plug-In is used in a mobile app, we collect analytical data and metrics about the interaction with and use of the mobile app, such as on-screen finger taps.
Other categories and types of information as determined by and at the sole discretion of the business on whose behalf the information is collected.
We use the collected information for the following purposes:

Maintaining and administering the functioning of the Plug-In, and providing the features of the Plug-In to the business on whose behalf the information is collected.
Handling inquiries and complaints.
Complying with any applicable law and assisting law enforcement agencies and regulatory authorities, if we believe it is necessary or justified.
As otherwise may be mandated by law.
Our Plug-In does not enable a child to make his or her personal information publicly available.

We may disclose the information in the following instances:

To the business on whose behalf the information is collected.
With our third-party contractors and service providers that support us in the internal operations of the Plug-In.
In the event of our reorganization or a merger or acquisition or similar event which results in the Plug-In being provided by another party, then we may share the information with such other party, which in effect supports the continued operation of the Plug-In.
We may share information with our corporate group companies that support us in the internal operations of the Plug-In.

Reviewing and deleting the personal information and refusing to permit the further collection and use of the information

Under COPPA and GDPR, parents and users can review and have deleted personal information collected from children under the age of 13 or the age of consent in their respective EU member state, and can refuse to permit further collection or use of the child’s information. To exercise your rights, please contact the business operating the online service (a website or mobile app) that has incorporated our Plug-In, in accordance with that business’s privacy policy.

Inquiries

The business on whose behalf we collect the personal information is considered the primary operator liable for compliance with the requirements of COPPA and GDPR. Therefore, inquiries from parents and users concerning the use of children’s information should be addressed to the business operating the online service (the website or mobile app) that has incorporated our Plug-In, in accordance with that business’s privacy policy.

Inquiries regarding the privacy practices of Singular (as opposed to the privacy practices of the business operating the online service on whose behalf the Plug-In collects personal information), should be addressed specifically to the following email address: privacy@singular.net, or to the following mailing address:

Singular Labs, Inc.

Attn: Compliance

2345 Yale Street, First Floor

Palo Alto, CA 94306

Last updated: November 2020