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Privacy Policy


Effective June 2, 2011

Last revised: April 28, 2014

Rhythm NewMedia, Inc. ("Rhythm", "our", "we" or "us") provides a mobile video ad network and related services to connect advertisers that are part of our network ("Advertisers") with publishers of mobile applications and mobile websites ("Publishers"), by facilitating the sending of video, display and rich media advertisements ("Ads") to end-users ("End-Users") through Publishers' mobile applications and mobile websites (collectively, "Mobile Media").  This Privacy Policy is made available on our website at www.rhythmnewmedia.com (the "Rhythm Site"), and provides information on our policies and procedures regarding the use and disclosure of personal information that we collect through the Rhythm Site and our services ("Services").  This Privacy Policy may be updated from time to time.  We will notify you of any material changes by posting the new Privacy Policy on the Rhythm Site.  You are advised to consult this policy regularly for any changes.

As used in this policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally

Data Collection and Use

  • If you are an End-User using a mobile application or visiting a mobile website, we may collect various non-identifying information, such as your mobile device type, device name, device properties, IP address, video views, ad views, ad clicks, search queries, photo views, and page views. If we ever inadvertently collected personally identifiable information, then we will not use this personally identifiable information for ad targeting. If you use a mobile application, we may also collect the device identification codes, such as IDFA, Android ID or other similar codes (collectively, "Unique Identifier"). We may also combine all of this non-identifying information with other non-identifying information to infer interests or demographic characteristics.
  • If you are an End-User visiting a mobile website, we may also use cookies.   In this context, a cookie is a small data file transferred to your mobile device's memory for record-keeping purposes when you are served an Ad. Cookies help us track session-based information and also better understand the effectiveness of an Ad (for example, by tracking the way in which you respond to, select and interact with an Ad or any content provided therein, or the location and context in which you view an Ad). Our cookies do not contain any personally identifiable information and they can help control the number of times you view an advertisement.
  • The information described above does not personally identify you. It may be used to send you advertisements for products and services that are relevant to your interests, including based on your demographics, and to measure the effectiveness of the Ads. If you would like to opt-out of receiving interest-based ads, please see below.
  • In addition, End-Users may choose to provide feedback through the Rhythm Site, for instance, with respect to the Mobile Media that they used. If you decide to do so, we may share your feedback with the applicable Publisher. In addition, feedback may occasionally include personally identifiable information, such as your email address and name. To the extent that you decide to provide personally identifiable information as part of your feedback, such personally identifiable information may be shared with third party service providers and used to help us get a better understanding of our user base, including its demographics, with the goal of improving the user experience from a content and advertising perspective.
  • Finally, we may collect from Publishers or Advertisers certain basic personally identifiable information such as business contact details of their personnel or representatives. We use such information to provide the Services, complete transactions, administer inquiries, and contact Publishers or Advertisers with respect to activities or communications relevant to the Services we provide them. 



You may choose to opt out of targeting that relies on the unique identification of your mobile device.  This may be done by performing one of two steps.  1) By manually disabling the tracking by electing to limit ad tracking as part of your mobile device settings  OR  2) By sending an opt-out email to [email protected], along with your Unique Identifier. Once your opt-out has been processed, you will still receive advertising messages.  These advertisements, however, will not be targeted via the former unique device identification. 

Use of Cookies on the Rhythm Site

  • When you visit the Rhythm Site, our servers automatically record information that your browser sends whenever you visit a website ("Log Data").  This Log Data may include information such as your computer's IP address, browser type or the webpage you were visiting before you came to our Rhythm Site, pages of our Rhythm Site that you visit, the time spent on those pages, information you search for on our Rhythm Site, access times and dates, and other statistics.  We use this information to monitor and analyze use of the Rhythm Site and the Services and for the Rhythm Site's technical administration, to increase our Rhythm Site's functionality and user-friendliness, and to better tailor it to our visitors' needs.
  • Like many websites, we may use cookies to better understand how you interact with the Rhythm Site, to monitor aggregate usage by our users and web traffic routing on the Rhythm Site, and to improve the Rhythm Site and our Services. In addition, please be aware that other parties may also place their own cookies on the Rhythm Site, and may collect or solicit personal information from you. As described above, most Internet browsers automatically accept cookies.  You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.


Information Sharing and Disclosure.

We may share and/or disclose information that we collect under this Privacy Policy in the following instances (in addition to those described above):

Non-Identifying Information and Aggregate Information

We may share with third parties aggregated information, that does not include either individual information or any personally identifiable information, for industry analysis, demographic profiling and other purposes.

Service Providers.

We may employ third party companies and individuals to facilitate our Services, to provide the Services on our behalf, to perform Rhythm Site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Rhythm Site's features) or to assist us in analyzing how our Rhythm Site and Services are used.  These third parties have access to any information collected under this Privacy Policy, whether personally identifiable or not, only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Business Transfers.

Rhythm may sell, transfer or otherwise share some or all of its assets, including your information, whether personally identifiable or not, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Compliance with Laws and Law Enforcement.

Rhythm cooperates with government and law enforcement officials and private parties to enforce and comply with the law.  We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Rhythm or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.


We are very concerned with safeguarding your information, and employ reasonable measures designed to protect your information from unauthorized access.

International Transfer.

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.  If you are located outside the United States and choose to provide information to us, Rhythm transfers personally identifiable information to the United States and processes it there.  Your consent to this Privacy Policy followed by your submission of such information, or your submission of such information to us or one of our Publishers represents your agreement to that transfer.

Links to Other Sites.

The Mobile Media and the Rhythm Site may contain links to other websites or media property.  If you choose to click on a third party link, you will be directed to that third party's website or media property.  The fact that we link to a website or media property is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices.  We do not exercise control over third party websites or media property.  These other websites or media property may place their own cookies or other files on your computer, collect data or solicit personal information from you, and may follow different rules regarding the use or disclosure of the personal information you submit to them.  We encourage you to read the privacy policies or statements of the other websites or media property you visit.

Our Policy Toward Children.

The Rhythm Site and the Services are not directed to children under 13.  We do not knowingly collect personally identifiable information from children under 13.  If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at [email protected]. If we become aware that a child under 13 has provided us with personally identifiable information, we will delete such information from our files.

Contacting Us.

If you have any questions about this Privacy Policy, please contact us at [email protected].



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