Effective Date: November 5, 2013

Do you want to opt-out of our services? This page is solely for Clients and Customers of HasOffers, Inc. d/b/a MobileAppTracking. If you are an End User and want to opt-out of our tracking and analytics services, you must go here:

Not sure if you are an End User or Client? Click here and scroll to the bottom of the page.

HasOffers has been awarded TRUSTe's Privacy and Children’s Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements and TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program only covers information collected through our site and our MobileAppTracking Platform. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at If you are not satisfied with our response you can contact TRUSTe here.

1. INTRODUCTION. HasOffers, Inc. (“HasOffers”, “we”, “us”), a Delaware corporation d/b/a MobileAppTracking™, is committed to protecting your privacy and the privacy of your end users (“End Users”). We recognize that privacy is an important issue to you. This policy describes our privacy practices on our site www.mobileapptracking and through our MobileAppTracking platform. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged HasOffers.

By visiting or any other web page owned by HasOffers, you are accepting the practices described in this Privacy Policy. By subscribing to use MobileAppTracking’s services (a “Subscription”), you are subject to certain additional terms as described herein.

When you use a different HasOffers Service (for example, and its associated platform) you will also be subject to the privacy policies of that HasOffers Service. If this Privacy Policy is inconsistent with the policies of another HasOffers Service, the other Service’s terms will control.

We design and operate our services with the protection of your privacy in mind. You can visit some of the pages on our Website without giving us any information about yourself. But sometimes we do need you to provide information and sometimes we need to track information on-line to provide services that you request. This privacy statement explains data collection, tracking, and use in those situations.

2. CONDITIONS OF USE. Your use of this Website and the Platform is governed by this Privacy Policy. Please read the following information carefully. You must agree to this Privacy Policy in its entirety in order to: a) access or use the Website, and/or (b) subscribe to and use HasOffers’ MobileAppTracking online management portal and the MobileAppTracking SDK (collectively the “Platform”). Your acceptance of this Privacy Policy in its entirety—including HasOffers’ use of cookies on the Website and Platform—shall be deemed a blanket acceptance of such Privacy Policy and cookie usage for all future attempts to access the Website and/or any Subscription on the Platform. If you do not agree to these terms and conditions in their entirety, do not use this Website, the Platform, or any other HasOffers Services.

Your acceptance of this Privacy Policy, in its entirety, shall inure to your employees, if any. You acknowledge and agree that any employee who accesses your Subscription account, or who visits your Subscription website under the scope of such employee’s employment with you (and any third party to whom you give rightful access to your Subscription account), agrees to the terms of this Privacy Policy, including, without limitation, our use of cookies and/or web beacons.

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If we make material changes to how we use Personal Information collected from children under age 13, we will notify parents by email in order to obtain verifiable parental consent for the new uses of the child's Personal Information.

3. COLLECTION OF YOUR PERSONAL INFORMATION. We collect the following personal information from you when you sign up for our service: Name, Company Name, Website, address, email address, phone number and mobile number.

We may also collect information about other users you wish to add to your account, such information includes: Name, title, office number and email address.

We may also collect certain information about your computer hardware and software. This information may include: your IP address, your Internet Service Provider, browser type, operating system, domain name, access times and referring Website addresses, your email address, and your passwords.

We may also collect information about your mobile devices, including your cell phone or other mobile device number and model, and your cellular carrier.

We may also collect information about which pages you visit on our Website.

If you apply for a job on our site we will collect your name, email address, phone number and resume. We use this information to contact you regarding the position in which you had applied and to determine if you are a good candidate for the position.

If you wish to share a job post with your friend, we will collect their name and email address. We use this information to send them a one-time email inviting them to view the invite. We do not store this information for any reason.

4. USE OF YOUR PERSONAL INFORMATION. We may use your personal information for the following purposes:

  • To ensure our Website is relevant to your needs and to make the Website easier for you to use.
  • To operate the Platform, maintain quality of the service, improve our Website and Services, and provide general statistics regarding use of our Website.
  • To deliver products and services, including newsletters and email notifications, confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages that you request or purchase, and to process payments that you have agreed to make for those products and services.
  • To help us create and publish content and offer products most relevant to you.
  • To alert you to our products and services, new products, special offers and promotions, updated information and other new or updated services that may be offered by HasOffers and our selected partners.
  • To allow you access to limited-entry areas of our Website as appropriate.

If you no longer wish to receive our newsletters, you may opt-out by following the unsubscribe link located at the bottom of each communication or by emailing is at

5. SHARING YOUR PERSONAL INFORMATION. Except as described in this Privacy Policy, and in the Agreement, HasOffers will not rent, sell, or share personally identifiable information collected on the Website or through the Platform with other people or nonaffiliated companies unless we have your consent, or under the following circumstances:

  • with third party vendors, consultants and other service providers who work for us and need access to your information to do their work such as providing customer support, processing payments, and storing data (e.g. Amazon Web Services). Any third-party vendor so used has agreed to protect the confidentiality of information provided by HasOffers;
  • to protect the rights and property of HasOffers, our agents, customers, users, and others including to enforce our agreements, policies and terms of use;
  • in an emergency to protect the personal safety of HasOffers, its customers, or any person;
  • We may occasionally allow other companies to offer our customers information about their products and services, but only when we believe that a significant number of our customers would be interested in receiving the information. If you do not want to receive email offers from us or from third parties, follow the procedure described in the emails or contact us at

We may also share aggregated or anonymized information in a form that does not directly identify you or your End Users with any third parties.

We may disclose your personal information if required to do so by law, such as to comply with a subpoena, or court order or in the good-faith belief that such action is reasonably necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In addition, information about our customers, including personal information, may be disclosed as part of any merger, acquisition, debt financing, or sale of company assets, as well as in the event of an insolvency, bankruptcy or receivership in which personally identifiable information could be transferred to third parties as one of the business assets of the company. You will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information

Parents are able to consent to our use of their child’s Personal Information without having also to consent to our disclosure of their child’s Personal Information to third parties as we will not share any information collected about a child through our client’s services with third parties.

6. ACCESS TO YOUR PERSONAL INFORMATION. If you wish to correct or delete any personal information we have collected, please log into your account and change the information. You may also remove your information from the viewable web pages by closing your account, or you may make a request to us by email at or postal mail at 2220 Western Ave., Seattle, WA 98121. We will process your requested changes, where possible and subject to the terms and conditions contained herein, within a reasonable time after receipt of the request, normally not to exceed three business days. We will respond to your access request within 30 days.

If you would like access, update or request deletion of your child’s personal information, please contact our Client that you or your child have been interacting with to do so. Parent’s may refuse further contact with their child by contacting our Client directly.

7. SECURITY OF YOUR PERSONAL INFORMATION. We are committed to protecting the security of your personal information. We use reasonable efforts including a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. When we transmit sensitive information (such as a credit card number or bank account information) over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol. However, we cannot guarantee that your personal information will be absolutely protected. For example, your personal information may be affected by actions outside of our control, such as computer "hacking" and physical theft. In these anomalous situations, we will try to rectify the anomaly as soon as we can.

You acknowledge that you provide your personal information to HasOffers with knowledgeable consent and at your own risk.

8. PROTECTION OF CHILDRENS' PERSONAL INFORMATION. We do not knowingly collect or solicit personal information from children or knowingly allow children to register on our Website. If you are a child, please do not attempt to register or send any information to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from a child we will delete that information as quickly as possible. If you believe that we might have any personal information from or about a child, please contact us at

If we engage in a contract with a client who we know wishes to collect information from users under the age of 13, we will ensure that our client represents and warrants that their collection practices comply with all legal requirements. Pursuant to our Terms of Service and this Privacy Policy, our Customers may not use the Platform or any other HasOffers Service in a manner that does not comply with federal, state, or international law, including but not limited to the Children’s Online Privacy Protection Act of 1998.

For the purposes of this provision, the definitions of “personal information” and “children” (and their translational and linguistic equivalents) are defined by the jurisdiction where the Customer is operating. In the United States, federal regulations related to the collection of personal information from children are codified at 15 U.S.C. 6501, et seq.

9. COLLECTION AND USE OF END USER ANALYTICS INFORMATION. The Platform provides information to you about how your End Users use their mobile applications as well as how applications are performing across different mobile devices (but the Platform does not collect personally identifiable information about your End Users). HasOffers obtains this information either directly from our Customers (typically with the use of advertising links) or from our Software Development Kit (“SDK”) if embedded by you in an End User's mobile application.

The data collected by our SDK may include: agent version, platform, SDK version, timestamp, API key (identifier for application), application version, device identifier—e.g., MAC address, Android ID, and IFA—Model (non-iOS), manufacture (non-iOS) and OS version of device (non-iOS), session start/stop time, locale (specific location where a given language is spoken), time zone, and network status (WiFi, etc.). The device identifiers may be hashed. In addition, HasOffers may collect the following data if you select the option for HasOffers to collect and provide such data to HasOffers: anonymous User ID, latitude and longitude (obfuscated by HasOffers for iOS to state/city), events, errors, and page views. Finally, we see the IP address of the user through the HTTP request. HasOffers uses this data to create reports for you to analyze your End Users and to create reports and/or metrics against which you can compare your user base. We may provide you with the option of exporting raw HasOffers data to your servers such as timestamp, platform, event, and user ID. You can also record errors that occur in your applications and receive an export of data containing the error information.

Your End User data is presented to you to analyze your applications. In addition, HasOffers may provide you with aggregated and anonymous benchmark data that includes your End User data and all other Customers' End User data. But while HasOffers assists you with the organization and collection of End User data, HasOffers specifically disclaims ownership of this data. The End User data stored by our servers belongs exclusively to our Customers and may be deleted any time at their request.

10. CUSTOMER USE OF END USER DATA. HasOffers is not responsible for any use by you of any data about your End Users, even if HasOffers helped you collect the data. You should allow End Users to review your policies to understand your use of End User data. You are prohibited from using the Platform, Services, or Website to independently collect any personally identifiable information about any End User. Further, you must provide a privacy agreement to your End Users in which written notice is given to the End Users that they may opt out of HasOffers Analytics tracking by going to our End User Opt-Out page at

In the event that you are aware, or should be aware of, the potential for users of your Subscription website to access such from any European Union state, you agree to comply with the 2009/136/EC of the European Parliament and of the Council Directive, commonly known as the “EU Cookie Directive”, that requires websites to obtain informed consent from internet users before storing information on such internet users’ computers or any web-connected devices. Further, you agree to amend your privacy policy as necessary to maintain compliance with any supplemental laws, regulations or directives that may be enacted from time to time by legislative bodies and that may pertain to your use of the Services and your Subscription website.

11. END USER OPT-OUT PROVISION. Your End Users can opt-out of HasOffers Analytics tracking and personalized ads/recommendations from HasOffers by clicking going to our End User Opt-Out Page at

The opt-out is specific to MobileAppTracking’s activities and does not affect the activities of other ad networks or analytics providers that you use. If an End User opts-out, HasOffers will stop tracking data for that device identifier going forward. The HasOffers Analytics tracking will stop across all applications. HasOffers will stop providing recommendations to the device identifier across all publishers.

There may be a short delay of up to several business days while the request is being verified, processed, and deployed across our system.

12. USE OF COOKIES AND WEB BEACONS. Cookies: To enhance your experience with the Website, we use “cookies.” You cannot use this Website or the Services without agreeing to accept the cookies that we use with the Site. For more specific information on the cookies we use, please see Exhibit A below.

Cookies are small packets of data stored on your computer. Cookies are used by your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information. We use cookies to understand Website usage and to improve the content and offerings on the Website. When someone visits our Website, we may place a cookie on the user's device (if the user accepts cookies) or may read a cookie already in place if the user has visited the Website previously. You may set your browser to warn you that cookies are in use, or to block the use of cookies. Most browsers are set to accept cookies by default. If your browser is not set to accept cookies, certain uses of the Website may require you to go to your browser user preferences to enable cookies. If you choose to not have your browser accept cookies from this Website, you will be able to view the text on the screens. However you may not be able to experience a personalized visit. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. If you change computers, operating systems or browsers, or use multiple computers or browsers, you will need to repeat this process for each computer and each browser. To find out more about cookies, please visit the links at the end of this privacy policy.

The use of third party cookies is not covered by our privacy policy. We do not have access or control over these cookies.

Web beacons: We may or our third party tracking utility partner may collect information using Web beacons. Web beacons are electronic images that may be used on our Website, in our Services, or in our emails. Our use of Web beacons includes to deliver cookies, to count visits and to tell if an email has been opened and acted upon. (A Web beacon is also sometimes called a Web bug or a pixel tag or a clear GIF.) We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

13. USE OF THIRD PARTY LINKS. The Website may contain links to third-party websites (“Third Party Websites”). Please be aware that HasOffers is not responsible for the privacy practices of Third Party Websites. We encourage you, when you leave our Website, to read the privacy policies of each and every website that you visit that collects personally identifiable information. This Privacy Policy applies solely to information collected by HasOffers.

Social Media (Features) and Widgets

Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Facebook Connect or other OpenID provider

You can log in to our support section of the site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.  Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.   

14. DATA RETENTION. We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at  We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

15. INTERNATIONAL TRANSFER OF DATA. In the process of providing services to you, we may transfer information that we collect about you or your End Users, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you or your End Users are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information and permitting the transfer of information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. You consent to the transfer of your information to the United States and the use and disclosure of information about you and your End Users, including personal information, as described in this Privacy Policy.

16. SAFE HARBOR. HasOffers complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. HasOffers has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view HasOffers’ certification, please visit

17. CONTACT INFORMATION. If you have any questions, comments or suggestions about this Privacy Policy or the practices relating to this Website, or other questions about privacy, please contact us at or by mail to HasOffers, Inc., 2220 Western Avenue, Seattle, WA 98121 or by telephone at 206-508-1318.

18. INFORMATION RELATED TO DATA COLLECTED THROUGH THE HASOFFERS PLATFORM HasOffers collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes.


We collect information for our clients, if you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly.

Service Provider, Sub-Processors/Onward Transfer

HasOffers may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.

Access to Data Controlled by our Clients

HasOffers has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to HasOffers Client (the data controller). If the Client requests HasOffers to remove the data, we will respond to their request within 30 business days.

Data Retention

HasOffers will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. HasOffers will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Exhibit A
More about cookies on

Using requires the use of cookies. If you do not want to accept the cookies for or from any of our third parties, you will not be able to use our service.

We use a cookie to remember your cookie preferences and this has a couple of consequences:

  • If you delete all your cookies you will have to update your preferences with us again.
  • If you use a different device, computer profile or browser you will have to tell us your preferences again.

The cookies used on are based on the International Chamber of Commerce guide for cookie categories:

For more information about cookies see the further reading link below.

Strictly Necessary

'Strictly Necessary' cookies let you move around the website and login to your secure account. These cookies don't gather any information about you that could be used for marketing or remembering where you've been on the internet.

We use these Strictly Necessary cookies to...

  • Identify you as being logged in to
  • Remember things like information you've entered on forms when you navigate to different pages in a single web browser session
  • Help you use specific features like testing tracking links
  • Make sure you connect to the right service on our website when we make any changes to the way the website works

Cookies we have defined as 'Strictly Necessary' cookies will NOT be used to...

  • Gather information that could be used to advertise products or services to you
  • Remember your preferences or username beyond your current visit

Accepting these cookies is a condition of using the website, so if you prevent these cookies we can't guarantee your security or predict how our website will perform during your visit.

Here is a list of the cookies we have defined as 'strictly necessary'. cookies


Cookies provided by 3rd parties


'Performance' cookies collect information about how you use our website e.g. which pages you visit, and if you experience any errors. These cookies don't collect any information that could identify you – all the information collected is anonymous and is only used to help us improve how our website works, understand what interests our users and measure how effective our advertising is.

We use performance cookies to...

  • Provide statistics on how our website is used
  • See how effective our adverts are (we don't use this information to target adverts to you when you visit other websites)
  • Provide feedback to partners that one of our visitors also visited their website. This can include details of any products bought. This lets our partners improve their website, but we don't allow our partners to reuse this information for further advertising
  • Help us improve the website by measuring any errors that occur
  • Test different designs of our website

Cookies we have defined as 'Performance' cookies will NOT be used to...

  • Remember your preferences or username beyond your current visit

In some cases, some of these cookies are managed for us by third parties, but we don't allow the third party to use the cookies for any purpose other than those listed above.

Using our site indicates that you accept the use of 'Performance' cookies.

Accepting these cookies is a condition of using the website, so if you prevent them we cannot guarantee how our site will perform for you.

Here is a list of the cookies we have defined as 'Performance'. cookies

  • aff_conversions
  • __utma
  • __utmb
  • __utmc
  • __utmz
  • _pmy_visit
  • _pmy_visitor
  • is_returning
  • chartbeat2

Cookies provided by 3rd parties


'Functionality' cookies are used to provide services or to remember settings to improve your visit.

We use 'Functionality' cookies to...

  • Remember settings you've applied such as layout, text size, preferences and colours
  • Remember if we've already asked you if you want to fill in a survey
  • Provide proactive live chat sessions to offer you support or submit a trouble ticket
  • Show you when you're logged in to the website
  • Share information with partners to provide a service on our website. The information shared is only to be used to provide the service, product or function and not for any other purpose

Cookies defined as 'Functionality' will not be used to...

  • Target you with adverts on other websites

Some of these cookies are managed for us by third parties – where this is the case we don't allow the third party to use the cookies for any purpose other than those listed above.

You can control whether or not these cookies are used, but preventing them may mean we can't offer you some services, and will reduce the support we can offer you. It's also possible that preventing these cookie stops us remembering that you didn't want a specific service.

Here is a list of the cookies we have defined as 'Functionality'. cookies

  • app_user
  • swidth

Cookies provided by 3rd parties

Cookie Host

Further reading

Information about cookies

Useful information about cookies can be found at:

Internet Advertising Bureau

A guide to behavioral advertising and online privacy has been produced by the internet advertising industry which can be found at:

International Chamber of Commerce United Kingdom

Information on the ICC (UK) UK cookie guide can be found on the ICC website section:

Copyright © 2013 by HasOffers, Inc., All rights reserved.