User Privacy

1. GDPR

Publishers using the Tapjoy Offerwall and associated Unity Technologies SF services, including the Unity Rewards offerwall, should ensure their consent mechanisms gather consent for these services and data processing where required. These measures must be reflective of any relevant legal requirements, and comply with the applicable Data Protection Addendum with Tapjoy.

Publishers using the Unity Rewards offerwall, should specifically ensure that their consent mechanisms collect consent for such services and the processing of data in accordance with Unity's Game Player and App User Privacy Policy.

2. CCPA

Tapjoy has features that help publishers comply with the California Consumer Privacy Act (CCPA). The “TJPrivacyPolicy” class allows you to manage all privacy flags (GDPR, user consent, below consent age, and US privacy).

3. Implementation

A setUserConsent function takes a TJStatus value of either TJStatus.False (user does not consent) or TJStatus.True (user does consent). The default value is TJStatus.Unknown.

An optional "subject to GDPR" flag takes a TJStatus value of either TJStatus.True (if the user is subject to GDPR rules) or TJStatus.False (if the user is not subject to GDPR rules) The default value is TJStatus.Unknown. This function should only be called if the application has made its own determination as to whether GDPR is applicable to the user or not. If this function is not called, Tapjoy assumes the application has not made such a determination, and therefore Tapjoy makes its own determination of GDPR applicability.

A belowConsentAge flag takes a TJStatus value of either TJStatus.True, TJStatus.False, with the default value being TJStatus.Unknown. This flag can be used to inform us of COPPA compliance and/or other applicable laws (e.g. the GDPR age compliance). It will also inform Tapjoy’s ad tracking policy.

Finally is the USPrivacy flag. This flag takes a string value. The string that this flag takes is derived from the IAB’s US Privacy String Format and encodes the string in an enum.

1YNN where 1 is char in string for the version, Y = YES, N = No, – = Not Applicable See: IAB suggested US Privacy String Format

This example shows the setting of all privacy flags:

Tapjoy.getPrivacyPolicy().setSubjectToGDPR(TJStatus.trueStatus);
Tapjoy.getPrivacyPolicy().setUserConsent(TJStatus.falseStatus);
Tapjoy.getPrivacyPolicy().setBelowConsentAge(TJStatus.unknownStatus);
Tapjoy.getPrivacyPolicy().setUSPrivacy('1---');

4. GDPR FAQ

If a user does not consent or withdraws existing consent, will the Tapjoy SDK still send advertising identifiers to Tapjoy?

Yes. The functions listed above are designed for interest-based advertising, and they send the user consent status for interest-based advertising to Tapjoy. Therefore, the status of the consent does not disable Tapjoy SDK from sending advertising identifier at SDK initialization or during ad requests.

Tapjoy’s legal basis for compliance is ‘legitimate interest’. However, the publisher’s legal basis for compliance, and consequently their requirement for advertiser identifier collection, could be different than Tapjoy’s.

It is left to application to determine if the Tapjoy SDK should be initialized or not, depending on the application’s compliance need. For example, if an application’s legitimate basis for collection of advertising identifier is consent, and user has not consented, then the Tapjoy SDK should not be initialized for such users.

If a user from a country that is not covered by GDPR does not consent or withdraws consent, would Tapjoy limit advertising to non-interest-based ads for such a user?

The Tapjoy SDK provides flexibility to handle different types applications, including applications that have no in-app method for determining whether the user is subject to GDPR or not.

Therefore, when an Application does not make any determination (i.e. the subjectToGDPR function is not called), Tapjoy servers determine whether the user is subject to GDPR. Then, Tapjoy honors the user’s consent preferences only for ad requests that Tapjoy determines are coming from GDPR-covered users.

If the intent is to allow users from any country to withdraw consent as if they were governed by GDPR, this can be done by calling the subjectToGDPR method with TRUE for all non-consenting users. In this case, Tapjoy’s servers will honor the content of the subjectToGDPR method call, and will not make its own determination as to whether or not the user is covered by GDPR. The publisher may also contact support@tapjoy.com and request that Tapjoy honor the consent preferences of all users of their application, regardless of whether they are covered by GDPR or not.