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 we in fact require the business to fully comply with COPPA.

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

 

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.
  • 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, parents can review and have deleted personal information collected from children under the age of 13, and can refuse to permit further collection or use of the child’s information. To exercise these 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. Therefore, inquiries from parents 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 COPPA practices of Singular (as opposed to the COPPA 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: COPPA Compliance

181 South Park Street, Unit 2

San Francisco, CA 94107

 

 

Last updated: September 2017