Last updated: 22 Aug 2023
This privacy policy applies to Affinity Global Inc. and its AI driven platform named mCanvas’ (collectively, “mCanvas,” or “we”, “us”, “our”).
This Privacy Policy describes how mCanvas collects, uses and discloses information, and what choices you have with respect to the information.
Please read this Privacy Notice carefully. By visiting our website or using any of our services, you indicate your acceptance of our use of your personal data as set out in this Privacy Notice.mCanvas is involved in creating impactful mobile advertising experiences as well as distributing these mobile ads through high-impact display and video formats across premium mobile apps and websites to deliver branding outcomes. We make creatives, bundle the media and package it as programmatic guaranteed (PG) deal on various platforms.
It is our policy to respect your privacy regarding any information we may collect while using our services and websites, collectively called the Services.
For the purposes of this Policy, the term, “Websites”, shall refer collectively to uattest2.mcanvas.com as well as the other websites that the Affinity Group operates and that link to this Policy.
When do we collect Information?
We may collect personal data about you in several circumstances:
Information collected automatically: In certain cases, we automatically collect personal data when you use our website/services. This data is recorded in log files or other such files. Examples of such data include IP addresses.
Ad interaction data
We collect this data automatically from you when you interact with ads generated using the mCanvas Services. we may collect information on behalf of mCanvas’s customers which may be the advertiser, publisher, advertising agency, and/or their agents. We may also receive some of this data from third-parties:
Log Data
Our servers automatically collect information when you access or use our applications and services. This data is recorded in log files. Examples of such data include IP Address
Information provided by you: We collect personal data when you use our website/services or provide the personal data directly to us. For creation of user accounts, you provide your name, email address, password, telephone number and correspondence address. You also provide billing details for invoicing purposes.
Information from other sources - Apart from data that you provide us directly, we also may collect information about you from publicly available sources and third-party sources.
Cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information about your actions to the owners of the website.
We collect data through cookies:
mCanvas uses cookies to identify and track visitors, their usage of website, and their website access preferences. mCanvas website visitors can control cookies through Cookies Settings
The categories of cookies used are:
mCanvas website visitors can control cookies through cookie preference.
For more details about how we use these technologies, please see our Cookie Policy
How we use your personal data will depend on which Services you use and how you use those Services.
We may use the information we collect to:
We may combine or aggregate any of the information we collect through our Services for any of these purposes.
In addition, we may use information that we collect when we believe in good faith that disclosure is necessary (a) to protect our rights, the integrity of our Services, or your safety or the safety of others, or (b) to detect, prevent, or respond to fraud, intellectual property infringement, violations of Terms of Use related to the Service, or violations of law. For EU area users, our legal basis for use of information under these circumstances is the legitimate interest of mCanvas or our business partners. Such use is compatible with your legal rights, as no additional personal information is processed, and there is no effect on your web or app experience, or other intrusive processing.
We process your personal data only when we have a lawful basis.
Presently, we use the following:
Our publishers are responsible for obtaining and managing consent as per IAB TCF requirements.
For interactive Ads, user’s consent for any interaction is stored on user’s device. It is not controlled by mCanvas platform.
Users under 16 years of age
The Sites and Services do not knowingly collect personal information from users under the age of 16
If you are under the age of 16, you are not permitted to use the Sites and Services or to disclose Personal Information. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.
We will retain raw information collected in the context of our platform for a period of up to 3 months, unless otherwise required by law or applicable contract.
We may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations
After the applicable retention period, we may only retain and use your data:
Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.
mCanvas may retain other information pertaining to you for as long as necessary for the purposes described in this Privacy Policy.
Data Subjects have certain rights in respect of their personal data. The rights given with respect to your personal data include:
Whenever you use our services, we aim to provide you with easy means to access, modify, delete, object to or restrict the use of your personal information.
We strive to give you ways to access, update/modify your data quickly, or delete it unless we have to keep that information for legal purposes. These rights can be exercised by contacting us using the details set out in the "Contact Information" section below.
Website user’s rights
We provide same rights to the users of our services. We receive requests related to Website user’s rights from customers.
We keep some personal data even after account closure. Once you choose to close your account, we generally delete your personal information within 3 years of closure of your account. Some information that is necessary for statutory obligations such as records of payment processing, invoicing data will be retained as necessary.
Recipients of your data
Cross-Border Data Transfers
Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region. These countries may not have the same standard of data protection laws as your own country. These international transfers of your personal information are made pursuant to the appropriate safeguards.
Since we are an international company, your data will be processed outside of the EU region. Your data will be processed within Third Party Data Centres in Europe and India as well as Affinity data centre in USA. Some countries where we process data may not have as protective laws as your own country and there are risks associated with such transfer
mCanvas offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our publishers and advertisers that operate in the European Union, and other international transfers of data. These clauses are contractual commitments between parties transferring personal data (for example, between mCanvas and its Clients, suppliers or data processors outside the EU), binding them to protect the privacy and security of the data.
Links to other sites:Our website may contain links to the websites of other organizations. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. This Privacy Policy does not cover how those organizations process your personal information. We encourage you to read the Privacy Policies on the other websites you visit.
Security Measures
We implement security controls to prevent breaches and unauthorised access to your data.
We maintain reasonable and appropriate security measures to protect Website user’s data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Examples of security measures include physical access control, role-based access to data, monitoring for threats and vulnerabilities etc.
Protection of personal information
Our Sites and Services uses commercial efforts to maintain safeguards for protection of your Personal Information.
mCanvas takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.
Contact Information
You can contact us about this privacy policy or use of our services.
If you have questions or complaints regarding this Policy, you may contact us through email at compliance@affinity.com. You may contact us at our mailing address below
20 N. Wacker Drive, 12th Floor,
Chicago, IL 60606
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are aware of how and why we are using such information.
If you are a resident of the European Economic Area and we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you have additional rights. If you are not satisfied with the resolution, you can also lodge a complaint with the Supervisory Authority in the country of your residence.
mCanvas may change this Privacy Policy from time to time, at our sole discretion.
mCanvas encourages visitors and customers to frequently check this page for any changes to its Privacy Policy. We will notify you of material changes in advance by email or by notice when you log in to the Sites and Services or both. You confirm that your continued use of our services after any change in this Privacy Policy will constitute your acceptance of such changes and agree to be subject to the revised privacy policy.
California Privacy Rights Act (CPRA)
This CPRA Privacy Policy describes mCanvas practices regarding the collection, use, and disclosure of the personal information of California residents, describes the rights of California residents under the California Privacy Rights Act (“CPRA”), and explains how California residents may contact mCanvas to exercise those rights. This CPRA Privacy Policy only applies to the personal information of California resident.
CPRA Categories of Personal Data
| Categories of Personal data | Personal data collected |
|---|---|
| Identifiers |
Personal Data collected only for select Brand Campaigns. We delete this data after the campaign period.
IP Address: Collected except GDPR region Managed & Xandr Open Exchange Supply: Device IDs (GAID & IDFA) Collected Supply via Dv360 Open Exchange: Device IDs (GAID & IDFA) not Collected |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Name, signature, tax identification number (i.e., National Insurance Number), Government ID number etc. for individuals & businesses who are signing up as our partners and customers. |
| Financial Information | Bank details, payment information etc. are collected only for individuals & businesses for our customers & partners |
| Commercial Information | N/A |
| Protected Classification characteristics under California or federal law. | N/A - We do not collect information such as Gender, Age, national origin, marital status etc. |
| Biometric information | N/A - We do not collect Biometric information |
| Internet or other similar network activity. | Log data, session information, and Cookie Id are only for our mCanvas website visitors. |
| Geolocation data |
Such as your location information generated based on your IP address etc.
|
| Sensory data. | For Brand campaigns users choose to give consent and engage with specific sensors for respective ad creatives. Primarily such ads are catered in India. |
| Professional or employment-related information. | Employment status, previous employment details, salary details etc only for job applicants. |
| Inferences drawn from other personal information. | N/A |
| Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Only from job applicants only such as educational details, history, degree etc. |
No Sale of Personal Data:
mCanvas has not sold Personal Data in the preceding twelve (12) months.
Right To Opt-Out Of The Sale Of Personal Data:
mCanvas does not sell your personal data.
If in case, mCanvas ever changes its policy and choose to sell Personal Data, you would have the right to opt-out of the sale of your Personal Data by clicking on the Do Not Sell My Personal Info link.
Sensitive data:
We do not generally seek to collect sensitive data through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with California Privacy Rights Act("CPRA") requirements. If in case, mCanvas ever chooses to use Sensitive Personal Data, you would have the right to limit the use of your sensitive personal Data.
The term "sensitive data" refers to the various categories of personal data identified by CPRA as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical, or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
Disclosures of Personal Data for a Business Purpose:
In the preceding twelve (12) months, mCanvas has not disclosed Personal Data for business purposes.
Your Rights:
The CPRA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CPRA rights and explains how to exercise those rights.
You have the right to request that Affinity disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
You have the right to request Affinity delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
You have a right to request for correction of Inaccurate personal information. We shall use commercially reasonable efforts to correct the inaccurate personal information as directed by the consumer.
You have a right to request us information about what personal information is sold or shared by us and with whom. Once request received, we shall disclose the following:
You have a right to opt out of sale or sharing of personal information if we sell or share such personal information. We shall prohibit from selling or sharing the consumer’s personal information after its receipt of the consumer’s direction, unless the consumer subsequently provides consent, for the sale or sharing of the consumer’s personal information.
You have a right to request us to limit Use and Disclosure of Sensitive Personal Information. Upon such request we shall prohibit, from using or disclosing the consumer’s sensitive personal information for any other purpose after its receipt of the consumer’s direction unless the consumer subsequently provides consent for the use or disclosure of the consumer’s sensitive personal information for additional purposes.
We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you have any questions or concerns about mCanvas’s privacy policy and practices, please contact us by email at compliance@affinity.com , or by mail at:
20 N. Wacker Drive, 12th Floor,
Chicago, IL 60606
We will review and update this CPRA Privacy Policy periodically and will note the date of its most recent revision at the top of this CPRA Privacy Policy. If we make material changes to this Policy, we will post the revised Policy on our website and may take additional measures to inform you about such changes prior to such changes taking effect, if required by applicable data protection laws. We encourage you to review this Policy frequently to be informed of how mCanvas is protecting your information.